River City Wealth Management was established in 2021. The owner of River City Wealth Management, Michelle Lynn Barron, has been providing comprehensive financial planning and wealth management services to individuals, professionals, business owners, retirement plans, and businesses since 2009. As a registered investment adviser subject to Section 206 of the Advisers Act, River City Wealth Management acts as a Fiduciary related to the conduct of its investment advisory services. As such, River City Wealth Management has an obligation to act in the best interest of its clients, guided by the core fiduciary duties of loyalty and care. Wealth Management Services River City Wealth Management provides discretionary wealth management services to a broad range of clients. River City Wealth Management determines the investment objectives and risk tolerance for each wealth management client during the account opening process and reassesses periodically thereafter. Once the client’s risk tolerance, time horizon, and investment objective are established, River City Wealth Management will recommend an investment strategy or individually design a portfolio of investments that include one or a combination of stocks, bonds, mutual funds, ETFs, and other securities including short-term money market instruments. We encourage clients to inform us in the event of any significant life changes, such as setting a retirement date, having a child, etc., so that we can perform an assessment to determine the proper investment strategy from that point forward. Typically, we review accounts internally and no less than annually with our clients, which should be sufficient given our long-term strategic approach to money management. Each client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by River City Wealth Management. River City Wealth Management’s investment strategies are primarily long-term focused, but we may buy, sell, or reallocate positions that have been held for less than one year to meet the objectives of a particular strategy or due to market conditions. Management of Held-Away Assets River City Wealth Management offers asset allocation review, rebalancing, and management services for accounts that are not held in the custody of the qualified custodian(s) recommended by our firm. These services are provided through an account aggregation service called Pontera Inc. (“Pontera”). This service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody of the plan custodian(s). We regularly review the available investment options in these accounts, monitor them, and periodically rebalance and implement our strategies using different tools as necessary. Services and fees will be clearly set forth in the advisory agreement between you and River City Wealth Management. Financial Planning Services River City Wealth Management will provide financial planning services to assist clients with long- term goal planning for those clients who choose. Before we begin managing client portfolios, we engage a new or potential client in a pre-advisory consultation to better understand the client’s financial situation and expectations. During this consultation, we:
• Review the individual’s goals, tax situation, financial needs, and limitations
• Gauge the individual’s tolerance for risk
• Analyze current investment strategies and asset allocation By understanding each of these financial characteristics and communicating our investment philosophy, we can proceed with developing a financial plan for the client and setting expectations for our client-advisor relationship. Based on this conversation, the client typically selects a targeted allocation. We will also take into consideration special situations such as restrictions on certain securities or asset classes, liquidity

needs, and tax situations when managing portfolios. We continuously manage the investments in the portfolios and the guidelines for each account are reviewed, as needed, with clients for any changes in the basic assumptions. 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, 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 interests 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. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and can engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. River City Wealth Management encourages you to discuss your options and review the above-listed considerations with an accountant, third-party administrator, investment adviser to your Employer Plan (if available), or legal counsel to the extent you consider necessary. By recommending that you rollover your Employer Plan assets to an IRA advised by River City Wealth Management, we will earn fees as a result. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by your new employer will result in no compensation to us. River City Wealth Management has an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by us. Investors can face increased fees when they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by River City Wealth Management, the underlying investment (mutual fund, ETF, annuity, or other investment) can also include fees. Custodial and trading fees also apply. Investing in an IRA with River City Wealth Management will typically be more expensive than an Employer Plan. As of December 31, 2023, River City Wealth Management has $133,582,938 in discretionary regulatory assets under management. We do not manage assets on a non-discretionary basis.