A. Stepp & Rothwell, Inc. (Stepp & Rothwell) is a corporation formed on July 13, 1992, in the state of Kansas. Stepp & Rothwell became registered as an Investment Adviser Firm in 1995. Stepp & Rothwell is owned by Kenneth Joseph Eaton and Amy Marie Guerich.
Kenneth Eaton is Stepp & Rothwell's Managing Partner.
B. Stepp & Rothwell offers to its clients (individuals, business entities, trusts, estates, and charitable organizations, etc.) both financial planning and related consulting services and investment advisory services.
The client can engage Stepp & Rothwell to provide combined financial planning and consulting services, including discretionary investment advisory services, on a fee-only basis. Stepp & Rothwell's financial planning and consulting services may include retirement planning, estate tax planning, income tax planning, cash flow planning, risk management (insurance) planning, education planning, and investment planning based upon the specific needs of the client. MISCELLANEOUS Stand-Alone Investment Supervision Services. Stepp & Rothwell may provide investment supervision services on a stand-alone basis in accordance with its Investment Supervision fee schedule (see Item 5). Please Note: In such event, Stepp & Rothwell shall not provide any financial planning and consulting services. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, Stepp & Rothwell will generally provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Stepp & Rothwell does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, Stepp & Rothwell 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). The client is under no obligation to engage the services of any such recommended professional and 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) (ie attorney, accountant, insurance agent, etc), and not Stepp & Rothwell, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client's responsibility to promptly notify Stepp & Rothwell if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Stepp & Rothwell's previous recommendations and/or services. PLEASE NOTE: RETIREMENT ROLLOVERS-No Obligation/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 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 client’s age, result in adverse tax consequences). If Stepp & Rothwell recommends that a client roll over his or her retirement plan assets into an account to be managed by Stepp & Rothwell, such a recommendation could create a conflict of interest if Stepp & Rothwell would earn new (or increase its current) compensation as a result of the rollover. However, this is rarely the case, because Stepp & Rothwell’s annual retainer fee is based on all the client’s investment assets regardless of the type of account in which they are held. When acting in such capacity, Stepp & Rothwell serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. ANY QUESTIONS: Stepp & Rothwell's Chief Compliance Officer, Howard Rothwell, remains available to address any questions that a client or prospective client may have regarding the above and the corresponding conflict of interest presented by such engagement. Unaffiliated Private Investment Funds. Stepp & Rothwell may also provide investment advice regarding unaffiliated private investment funds. Stepp & Rothwell, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Stepp & Rothwell's role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of "assets under management" for purposes of Stepp & Rothwell calculating its investment advisory fee. Stepp & Rothwell's clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund's offering documents, which will be provided to each client for review

and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Stepp & Rothwell references private investment funds owned by the client on any account reports prepared by Stepp & Rothwell, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If no post-purchase valuation is provided by the Fund Sponsor, then the valuation shall reflect the initial purchase price. If the valuation reflects initial purchase price (or a value as of a previous date), the current value (to the extent ascertainable) could be significantly more or less than the original purchase price. The client's advisory fee shall be based upon reflected fund value(s). Please Note-Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a client can obtain many of the mutual funds that may be recommended and/or utilized by Stepp & Rothwell independently of engaging Stepp & Rothwell as an investment advisor. However, if a prospective client does so, then he/she/they will not receive Stepp & Rothwell's initial and ongoing investment advisory services. Many mutual funds offer a number of share classes that differ only with respect to their level of management and other fees. It is Stepp & Rothwell’s practice to use the appropriate share class for its clients. This is usually the share class with the lowest fees for which the client qualifies. However, there could be situations in which the use of a higher-fee share class is appropriate, such as using a share class that would avoid transaction fees. Stepp & Rothwell and its supervised persons never receive compensation from commissions or 12b-1 marketing fees from mutual funds. Charles Schwab. As discussed below at Item 12, when requested to recommend a broker- dealer/custodian for client accounts, Stepp & Rothwell generally recommends that Charles Schwab & Co, Inc. serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Charles Schwab & Co, Inc. 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/custodian (While certain custodians, including Charles Schwab & Co, Inc., do not currently charge fees on individual equity transactions, others do). These fees/charges are in addition to Stepp & Rothwell’s investment advisory fee at Item 5 below. Stepp & Rothwell does not receive any portion of these fees/charges. Portfolio Activity. Stepp & Rothwell has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Stepp & Rothwell 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, mutual 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 Stepp & Rothwell determines that changes to a client’s portfolio are neither necessary nor prudent. Clients are still subject to the fees described in Item 5 below, even during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Stepp & Rothwell will be profitable or equal any specific performance level(s). Client Obligations. In performing its services, Stepp & Rothwell 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 his/her/its responsibility to promptly notify Stepp & Rothwell if there is ever any change in his/her/their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Stepp & Rothwell's previous recommendations and/or services. Please Note: 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 Stepp & Rothwell) will be profitable or equal any specific performance level(s). C. Stepp & Rothwell shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client's investment objective(s). Thereafter, Stepp & Rothwell 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 Stepp & Rothwell's services.
D. Stepp & Rothwell does not participate in a wrap fee program.
E. As of December 31, 2023, Stepp & Rothwell had $842,488,217 in assets under management on a discretionary basis and $ 48,212,724 on a nondiscretionary basis.