A. Firm Information RM Financial Services, LLC ("RMFS" or the "Advisor") is a registered investment advisor located in Falmouth, Maine. The Advisor is organized as a Limited Liability Company ("LLC") under the laws of Maine. RMFS was founded in January 2007 and became a register investment advisor in October 2019. RMFS is owned and operated by Aaron P. Rugh (Chief Executive Officer) and Mark L. Macleod (President).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by RMFS. For any questions regarding this Disclosure Brochure, please contact the Chief Compliance Officer, Cayla Moore at (207) 781-7637.
B. Advisory Services Offered RMFS offers investment advisory services to individuals, high net worth individuals, trusts, estates, charities, and businesses, (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. The Advisor'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 RMFS provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services.
RMFS works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. RMFS will then construct an investment portfolio, consisting of diversified mutual funds, exchange-traded funds ("ETFs"), individual stocks, alternative investments and individual bonds to achieve the Client's investment goals. The Advisor may retain certain types of investments based on a Client's legacy investments based on portfolio fit and/or tax considerations.
RMFS will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, RMFS will select, recommend and/or retain a mutual fund share class that does not have trading costs, but do have higher internal expense ratios than other share classes. RMFS will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client's financial objectives and stated investment guidelines.
RMFS'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 as a result of market conditions. RMFS will construct, allocate and monitor the portfolio to meet the goals, objectives, circumstances, and risk tolerance agreed to by the Client.
RMFS evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. RMFS may recommend redistributing investment allocations to diversify the portfolio. RMFS 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. RMFS 4 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 RMFS 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.
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.
Financial Planning Services RMFS will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client's financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client's financial goals and objectives. This planning or consulting may encompass

one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client's financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. RMFS may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client's financial situation, observations, and recommendations. For consulting or ad- hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly.
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 5 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.
C. Client Account Management Prior to engaging RMFS 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. 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. These services may include:
•Establishing an Investment Strategy - RMFS, in connection with the Client, will develop a strategy that seeks to achieve the Client's goals and objectives.
•Asset Allocation - RMFS will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
•Portfolio Construction - RMFS will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
•Investment Management and Supervision - RMFS will provide investment management and ongoing oversight of the Client's investment portfolio. D. Wrap Fee Programs RMFS does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by RMFS.
E. Types of Investments We offer advice on equity securities, certificates of deposit, corporate bonds, treasury bonds, municipal securities, mutual fund shares, money market funds, alternative investments, ETFs and leveraged ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
F. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue 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); 6
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
G. Assets Under Management As of December 29, 2023, RMFS manages $201,043,670 in client assets which are managed on a discretionary basis, and $6,741,367 in client assets on a non-discretionary basis.
Clients may request more current information at any time by contacting the Advisor.