RFS is a fee-based registered investment adviser with its principal place of business located in Medway, Massachusetts. We have been in business since 1997, with Steven Michael Richardson as the majority owner and President. We currently offer the following advisory services: Financial Planning Services Financial planning is an evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern: Personal: Family records, budgeting, personal liability, estate information and financial goals; Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. We will illustrate the impact of various investments on a client's current income tax and future tax liability; Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis; Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals; Investments: Analysis of investment alternatives and their effect on a client's portfolio; Estate: Analysis of financial issues with respect to living trusts, wills, estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law; and Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. We gather required information through in-depth personal interviews. Information gathered includes a client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should a client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. Clients have the option of implementing their financial plan through our firm. Our planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding exchange-listed and over-the-counter securities, corporate debt securities, certificates of deposit, municipal securities, United States governmental securities, variable life insurance, variable annuities, and mutual funds. Typically, the financial plan will be presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided by the client. AssetMark Inc. Platform We advise on client portfolios by utilizing the AssetMark Inc. ("AssetMark") wrap fee program ("AssetMark Platform"). AssetMark, an unaffiliated independent SEC- registered investment adviser, is the sponsor of the AssetMark Platform. The AssetMark Platform provides a selection of investment managers and strategies that represent a diversification of asset classes and investment approaches. We select the appropriate investment managers to construct a client’s investment portfolio that is consistent with their individual risk profile. We engage AssetMark to conduct initial and ongoing due diligence on the investment managers available on the AssetMark Platform. Annually we conduct due diligence on AssetMark and their oversight of the third-party managers we utilize on their platform. If granted investment discretion by the client, we may hire and fire these managers, move, or re-allocate client funds from one manager to another, or from one model to another. Clients should refer to AssetMark’s Form ADV Part 2A and Part 2A Appendix I wrap fee brochure for additional information about the AssetMark Platform. Envestnet Asset Management, Inc. Platform We also advise on client portfolios by utilizing the Envestnet Asset Management, Inc. ("Envestnet") wrap fee program ("Envestnet Platform"). Envestnet, an unaffiliated independent SEC-registered investment adviser, is the sponsor of the Envestnet Platform. The Envestnet Platform provides a selection of investment managers and strategies that represent a diversification of asset classes and investment approaches. We

select the appropriate investment managers to construct a client’s investment portfolio that is consistent with their individual risk profile. We engage Envestnet to conduct initial due diligence on the managers we utilize on the Envestnet Platform. In addition, at least annually, we conduct due diligence on Envestnet and their oversight of the third- party managers on their platform. Through the Envestnet Platform, our firm provides mutual fund and exchange traded fund (“ETF”) allocation services, including access to the Separately Managed Accounts (“SMA”), ActivePassive Portfolios, PMC Sigma Mutual Fund Solutions (“MFS”), PMC Strategic ETF Solutions, Unified Managed Account (“UMA”), PMC Multi Manager Account (“PMC MMA”), PMC Impact Quantitative Portfolios™ and Third-Party Fund Strategists programs available within the Envestnet Platform. If granted investment discretion by the client, we may hire and fire these managers, move, or re-allocate client funds from one manager to another, or from one model to another. Clients should refer to Envestnet’s Form ADV Part 2A and Part 2A Appendix I wrap fee brochure for additional information about the Envestnet Platform. Services in General We tailor all of our financial planning and portfolio management recommendations to the individual needs of each client. All such recommendations are based on information gathered through client questionnaires, telephone and in-person discussions. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Retirement Rollover Recommendations When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the individual’s age, result in adverse tax consequences). If your designated investment adviser representative recommends that you rollover your retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. As of December 31, 2023, RFS had approximately $167,203,907 in regulatory assets under management on a discretionary basis. Separately from assets under management, RFS has $12,840,667 under advisement on a non-discretionary basis.