Our Advisory Business Rossby is a Registered Investment Adviser that offers investment advisory services to clients. The firm is a limited liability company organized under the laws of the State of Delaware on January 5, 2023. Rossby is principally owned by Andrew Evans and Christopher Marsico, the Adviser’s Managing Members (“the Principals”). The firm provides investment advice through Investment Adviser Representatives (IARs) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all our IARs are required to have an associate degree or commensurate business experience. We provide portfolio management services to individuals including high net worth individuals, charitable organizations, pension plans/profit sharing plans, corporations, and other business entities. The firm is committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long-term relationships with our clients whom we regard as strategic partners in our business. Wealth Management Consulting We can work with you, in a consulting capacity, to create a formal Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. Financial Planning and Consulting As part of our investment advisory relationship with our clients, we also provide financial planning services. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other professionals (e.g., attorneys, accountants, etc.) as necessary. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant, or other professionals. If you engage us to perform these services, you will receive a written agreement specifying the services, fees, terms, and conditions of the relationship. An IAR can make various recommendations through the financial plan, including but not limited to recommending the services of other professionals for Rossby Financial, LLC ADV Part 2A Page 5 of 33 implementation purposes. The IAR can recommend using or select Private Client Services, LLC’s brokerage services, or Rossby Insurance L.L.C.’s insurance services, an affiliate of Rossby. A conflict of interest exists if you engage us to provide additional services for compensation. You retain absolute discretion over all decisions regarding implementation and are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. It is your responsibility to promptly notify us of any change in your financial situation or investment objectives to review, evaluate, or revise our recommendations and/or services. Asset Management Services We manage client investment portfolios on a discretionary or non-discretionary basis. We tailor our advisory services to meet the needs of our individual clients and seek to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. We consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if we determine, in our sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the firm’s management efforts. We primarily allocate client assets among various mutual funds, equities, exchange-traded funds (ETFs), debts, futures, options, and other securities in accordance with their stated investment objectives. Where appropriate, we may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage us to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, we direct or recommend the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. We tailor our advisory services to meet the needs of our individual clients and seek to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Upon request, we may also provide services related to client assets “held-away” at other custodians, administrators, or product providers. This service generally applies to ERISA and non-ERISA plan assets, such as 401(k)s and 403(b)s, and variable insurance products and other client accounts where we are providing very limited services. Regarding ERISA and non-ERISA plan assets, investment selection is limited to the investment options approved by the plan administrator or product provider. Because of this, our advisory services to held-away accounts are limited to those available investment options and may be subject to other service limitations, as disclosed to the client in a separate written agreement. Rossby Financial, LLC ADV Part 2A Page 6 of 33 Pension Consulting Services On occasion, we offer consulting services to pension or other employee benefit plans (including 401(k) plans). Pension consulting

may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators, and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Retirement Consulting Services To comply with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. 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 an exemption that requires we act in your best interest and not put our interest ahead of yours. Under this exemption, 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. We benefit financially from the rollover of the clients’ 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 the client’s best interest. Selection of Other Advisers We and our IARs recommend and/or select third-party investment managers to handle all or a portion of the asset management process. These third-party investment managers, sometimes referred to as sub- advisors or third-party asset managers, may be selected directly by our IARs or made available to us through a custodian-sponsored program. Certain sub-advisory arrangements require the client to engage Rossby Financial, LLC ADV Part 2A Page 7 of 33 the third-party investment manager directly and we help facilitate that arrangement. Under this scenario you will enter a separate, written agreement with the third-party investment manager, detailing the fees and expenses that you will pay to such third-party investment manager. Turnkey Asset Management Platforms (“TAMPs”) Services We may recommend and/or select Turnkey Asset Management Platforms (“TAMPs”) to handle all or a portion of the asset management process. TAMPs typically include technology, investment research, portfolio management and other outsourcing services. TAMPs generally provide services that enable the Advisors to integrate multiple providers, programs, products, and custodians. We currently offer advisory services through TAMPs sponsored by, among others, AssetMark, Inc. and SEI Investment Management. We may offer the advisory services of other TAMPs in the future. For more information regarding these programs, including additional information on the advisory services and fees that are applicable, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please refer to the information provided by us, including, but not limited to, the applicable TAMP sponsor’s Form ADV Part 2A brochure, Wrap Fee Program brochure or the applicable program’s Form ADV Part 2A brochure, Wrap Fee Program brochure and applicable agreement(s). Family Office Services We support their overall financial needs and provide to an ultra-high-net-worth family a selection of personalized services that include, but are not limited to, the following:
• Portfolio review and evaluation
• Cash flow analysis
• Budgeting
• Divorce planning
• Tax projections
• Tax planning
• Philanthropic planning
• Retirement planning
• Planning for special needs family member
• Education funding planning
• Risk management analysis (i.e., insurance policy review)
• Client meetings
• Organization of client documents
• Investment policy design
• Access to financial planning tools
• Retirement account investment analysis and allocation
• Estate analysis and planning
• Behavioral coaching and wealth mentoring Rossby Financial, LLC ADV Part 2A Page 8 of 33 Wrap Fee Programs We offer a Wrap Fee Account which is administered through a clearing broker/dealer. The Wrap Fee Program is designed to assist you in clarifying your investment needs and obtaining professional asset management for a convenient single "wrap" fee on a discretionary account. Under the Wrap Fee Program, an inclusive fee covers account management, brokerage, clearance, custody, and administrative services. We will receive a portion of the WRAP fee for our services. We typically manage wrap accounts similarly to non-wrap accounts. However, several factors may influence the selection of the account structure, including but not limited to: 1. The client’s preference for a “wrap” vs. transaction charges per trade on certain or all securities. 2. Account size. 3. Anticipated trading frequency. 4. Anticipated securities to be traded. 5. Management style. 6. Long term investment goals. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by paying transaction costs separately. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged by other broker/dealers, and the advisory fees charged. We will review with clients any separate program fees that may be charged to clients. We receive the advisory fee set forth in the Wrap Fee Program Brochure. Assets under Management As of December 20, 2023, the firm has $170,360,824.12 in discretionary and $0 in non-discretionary regulatory assets under management.