RSW Investments Holdings, LLC (“RSW” or the “Firm”) is a limited liability company formed in the State of Delaware. RSW Investments Holdings, LLC succeeded to the advisory business of its predecessor, RSW Investments, LLC (CRD#134261/SEC#801- 63947) on April 1, 2019, after entering into an ownership agreement with Resolute Investment Managers, Inc. (“RIM”). The predecessor’s business was founded in 2005. RSW’s advisory services and management personnel remained the same after the change of ownership. The Firm’s principal owners are RIM and Robert S. Waas, while Matthew T. Werner owns a minority interest in RSW. RIM is an indirect wholly-owned subsidiary of Resolute Topco, Inc., which is owned primarily by various institutional investment funds that are managed by financial institutions and other investment advisory firms. As of December 31, 2023, RSW managed $2.3 billion on a discretionary basis. RSW specializes in the management of municipal bond portfolios, as discussed further below. The majority of RSW’s clients are referred by a wrap-fee program sponsor or other financial institution that has selected or recommended RSW to manage the client’s assets. The program sponsor or financial institution acts as a financial intermediary between RSW and the client. A representative of the financial intermediary works with the client to determine the client’s investment objectives, risk tolerance, liquidity requirements, investment restrictions and other relevant suitability factors. Based on this information, the representative may then recommend placing all or a portion of the client's assets with RSW for management. For its services under a wrap-fee program, RSW receives a portion of the fee that the program sponsor collects from the client. Portfolio Management Services RSW's fixed-income investment management philosophy focuses on maximizing clients' after-tax total return while employing prudent and predictable risk through focusing on coupon selection, yield curve targeting and changes in portfolio duration. Through the use of a proactive credit research approach, optimal portfolio structure, and dynamic risk management, RSW attempts to maximize portfolio predictability and dependability. RSW manages municipal fixed income accounts on a discretionary basis only. RSW’s actively-managed strategies fall into three (3) broad categories -- Market Duration Portfolio, Low Duration Portfolio, and Enhanced Intermediate Duration Portfolio -- which are each designed to meet a particular investment goal. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). RSW can create a customized investment strategy consistent with the individual investment objectives and risk tolerances of a client, subject to RSW deeming the account to be large enough to support efficient portfolio management and trading. These separate accounts will be managed versus a customized benchmark. The Market Duration Portfolio has the following characteristics:
• It strives to provide the tax-exempt cash flow of a 10-15 year bond while maintaining a level of volatility that is normally associated with shorter maturity investments.
• A key determinant in RSW's maturity distribution is the slope of the municipal bond yield curve.
• Emphasizes high quality (AA-rated average) premium coupon callable municipal bonds with an approximate average maturity of 10-15 years.
• The average call date of each portfolio typically falls within the range of 4 to 6 years.
• Benchmark: Bloomberg 5-Year Municipal Bond Index.
• Available Mandates: National, State Preference and State Specific: o National Portfolios- comprised of bonds issued in any state without considering the client's state of residence o State Preference Portfolios - target a minimum of 50% state specific issues with the remainder invested in out-of-state securities o State Specific Portfolios - constructed for clients who reside in a variety

of states. o RSW's ability to achieve our desired level of investment in a particular state may be impacted by factors such as: high embedded capital gains, the relative value of the target state, and the availability of new issue and/or secondary supply of bonds.
• RSW employs a unique “sale discipline” during periods of rising interest rates. As market yields rise near the bond’s stated coupon rate, the price will decline towards par. RSW’s strategy targets these “current coupon” bonds for sale as they no longer represent superior income or price stability. RSW then seeks to reinvest the proceeds from the sales in higher coupon callable bonds, thus reinstating the original portfolio structure at current market levels. By executing these transactions and realizing a capital loss, an asset is created since the loss may be used to offset capital gains. This advantage may not have existed if a buy and hold strategy was in place. The Low Duration Portfolio exhibits the same characteristics as the Market Duration Portfolio, with the key differences being it can only invest in premium coupon callable bonds with stated maturities that cannot exceed 10 years (as opposed to 10-15 years for the Market Duration Portfolio). Furthermore, the average call date structure of each portfolio is shorter than the Market Duration mandate, and typically falls in the range of 2 to 4 years. The benchmark for the Low Duration Portfolio is the Bloomberg 3-Year Municipal Bond Index. The core discipline of the Enhanced Intermediate Duration Portfolio is founded on the investment characteristics of RSW’s Market Duration Portfolio (targeting high quality premium coupon callable bonds maturing between 10-15 years.) However, the Enhanced Intermediate Duration Portfolio is not held to its more stringent “sale discipline” and maintains broader levels of flexibility to preserve principal and enhance total rate of return opportunities, such as:
• Active duration management.
• Investments in bonds maturing up to 20 years.
• Coupon structure: may target discount, par, and premium coupon bonds.
• Short-term tactical US Treasury bond exposure as market conditions warrant. The benchmark for the Enhanced Intermediate Duration Portfolio is the Bloomberg 5-Year Municipal Bond Index. RSW can also manage each of these primary strategies in a tax-efficient manner for clients. Deeply embedded within our investment philosophy is an ability to convert a rising interest rate environment into an opportunity to harvest tax losses and increase coupon income. As a result of rising interest rates, certain securities are flagged to be sold as their prices drop to predetermined levels. By executing these transactions and realizing a capital loss, an asset is created since the loss may be used to offset capital gains. This advantage may not have existed if a buy and hold strategy was in place. For all portfolio strategies, RSW will ensure that the following conditions are met and maintained: 1. RSW manages each client's account to the strategy selected by the client and/or the client’s financial advisor, with any reasonable investment restrictions the client may impose. However, an intermediary may not provide clients the opportunity to impose investment restrictions on the RSW strategy available through the intermediary. 2. RSW obtains sufficient client information to be able to provide individualized investment advice to the client. At least annually, RSW (or a representative of the applicable financial intermediary) will contact the client to determine whether there have been any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. 3. RSW is reasonably available to consult with the client. 4. Each client retains indicia of ownership of the securities and funds in the account, including the ability to withdraw securities and vote securities, among others.