A. Riggs Asset Management Company, Inc. (“Riggs”) is a corporation formed on November 27, 1990 in the Commonwealth of Pennsylvania. Riggs became registered as an Investment Adviser Firm in January 1991. Riggs is principally owned by Robert H. Graham and Elizabeth B. Graham. Robert J. Graham is Riggs’ Founder. B. As discussed below, Riggs offers to its clients (individuals, business entities, pension and profit sharing plans, trusts, estates and charitable organizations, etc.) investment m a n a g e m e n t services, and, to the extent specifically requested by the client, limited consultation services to its investment management clients on investment and non- investment related matters (See Limitations below). Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis. Riggs has a family office function for high net worth individuals and families. Riggs provides bill paying, bookkeeping and record keeping, assistance with budgeting and cash flow management. Pricing is on an individualized basis and is directly correlated to the service need of the client. C. Riggs shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Riggs shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Riggs’ services. D. Riggs does not participate in a wrap fee program. E. As of December 31, 2022, Riggs had $366.8 Million in assets under management on a discretionary basis and $56.8 Million in assets under management on a non- discretionary basis or a total of approximately $4 2 4 Million in assets under management. MISCELLANEOUS Limitations Consulting/Implementation Services: Riggs does not hold itself out as a financial planner, nor does it provide comprehensive financial planning services. To the extent specifically requested by a client (and depending on the nature of the issue presented), Riggs may provide limited financial planning and related consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. Riggs does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, Riggs does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). You are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation that we make.
Please Note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Riggs, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify Riggs if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Riggs’ previous recommendation and/or services. Retirement Plan Rollovers Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the 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 client’s age, result in adverse tax consequences). If Riggs recommends that a client roll over their retirement plan assets into an account to be managed by Riggs, such a recommendation creates a conflict of interest if Riggs will earn new (or increase its current) compensation as a result of the rollover. If Riggs provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Riggs is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Riggs, whether it is from an employer’s plan or an existing IRA. Riggs’ Chief Compliance Officer, Susan Shoemaker, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. ERISA / IRC Fiduciary Acknowledgment: If the client is: (i) a retirement plan (“Plan”) organized under ERISA; (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an IRA acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then Riggs represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by Riggs or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account. Tradeaway/Prime Broker Fees: As discussed below at Item 5, relative to its discretionary investment management services, when beneficial to the client, individual fixed income transactions may be often be effected through broker-dealers other than the account custodian, in which event, the client generally will incur the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and, potentially, a separate “tradeaway” and/or prime broker fee charged by the account custodian (generally Schwab). Cash Positions: Riggs continues to treat cash as an asset class. As such, unless determined to the contrary by Riggs, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Riggs’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Riggs may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending

upon current yields, at any point in time, Riggs’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Riggs’ Chief Compliance Officer, Susan Shoemaker, remains available to address any questions that a client or prospective may have regarding the above fee billing practices. Portfolio Activity: Riggs has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Riggs will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Riggs determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Riggs will be profitable or equal any specific performance level(s). Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Riggs generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker- dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, generally do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab will not change their transaction fee pricing in the future). When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom Riggs and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab ). These fees/charges are in addition to Riggs’ investment advisory fee at Item 5 below. Riggs does not receive any portion of these fees/charges. ANY QUESTIONS: Riggs’ Chief Compliance Officer, Susan Shoemaker, remains available to address any questions that a client or prospective client may have regarding the above. Please Note-Use of Mutual and Exchange Traded Funds: Riggs utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Riggs’ investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Trustee Directed Plans: Riggs may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Riggs will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Riggs will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement with the Plan. Client Obligations: In performing our services, Riggs shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains the client’s responsibility to promptly notify us if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and/or services. Investment Risk: Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Riggs) will be profitable or equal any specific performance level(s). Disclosure Brochure: A copy of Riggs’ written Brochure as set forth on Part 2 of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral; These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Riggs does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Riggs does not recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Riggs:
• by taking the loan rather than liquidating assets in the client’s account, Riggs continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Riggs, Riggs will receive an advisory fee on the invested amount; and,
• if Riggs’ advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), Riggs will earn a correspondingly higher advisory fee. This could provide Riggs with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. .