RubinBrown Advisors, LLC is a SEC-registered investment adviser with its principal place of business located in St. Louis, Missouri. Additional offices are located in Denver, Colorado, Kansas City, MO, Leawood, KS and Chicago, IL. RubinBrown Advisors, LLC began conducting business in 2002. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). • RubinBrown, LLP, Owner RubinBrown Advisors, LLC offers the following advisory services to our clients: Investment Advisory Services Rubin Brown Advisors will: 1. Design an investment policy that reflects the client's current financial condition, long-term needs and risk tolerance. 2. Assist in developing an appropriate strategic asset allocation to achieve the client's objectives. 3. Assist the client in selecting suitable investment products and/or money managers to implement their asset allocation. 4. Periodically assess the ongoing performance of the client's portfolio based on the client’s objectives, and helping the client determine any necessary adjustments to their investment policy. 5. Based on our supervision, recommend changes to the asset allocation and/or replacement of investment products or money managers where appropriate. For example, a change in the characteristics supporting the initial decision to select the product or investment manager; any changes in a manager; or, whether the product or manager continues to meet the requirements for inclusion in the client's portfolio. Depending on the best interests of the client, RubinBrown Advisors will either provide ongoing management services itself and, if needed, will recommend the use of independent third party advisers, or will recommend the use of third party service platform providers, as described below. Advice provided directly by RubinBrown Advisors: Investment Advisory Services by RubinBrown Advisors: RubinBrown Advisors will design a portfolio consisting of mutual funds, exchange-traded funds ("ETFs"), and/or third party managers to run a separately managed account ("SMA") of stocks or bonds, and an investment advisor representative will review and suggest changes to that portfolio on at least a P a g e 5 | 30 semiannual basis or as market conditions and client needs dictate. Accounts will be managed on a nondiscretionary basis; in other words, we will contact the client with our recommendation prior to placing any trade in the client’s portfolio. For those clients with legacy objectives focused on charitable giving, we often recommend the use of and help establish a Donor Advised Fund sponsored by one of the custodians we utilize, such as Charles Schwab & Co. Inc., TD Ameritrade, Fidelity Charitable Gift Fund, or SEI Private Trust Company. WE do not typically provide ongoing and continuous advice on the investment within the Donor Advised Fund. However, there are occasions where the Donor Advised Fund is treated as any other investment account managed by RubinBrown Advisors. The clients’ intention for the fund and size determines whether more personalized investment advice is warranted and desired by the client. RubinBrown Advisors’ investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-traded funds ("ETFs")
• Mutual fund shares
• Investments held by the client at the start of the advisory relationship.
• Separately Managed Accounts ("SMAs")
• Certificates of deposit
• U.S. Government Issued Bonds
• Investment elections within variable life insurance
• Investment elections within variable annuities Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. We have recommended to some clients the use of a fixed annuity through an unaffiliated insurance company. These annuities are commission free products for clients of registered investment advisors versus being sold by a broker-dealer. We do not typically make recommendations to purchase equity securities of individual companies, however, on occasion clients make specific requests and we will facilitate these trades and potentially included in the managed portfolio. Third Party Investment Advisers/Separately Managed Accounts ("SMAs") When consistent with the needs of the client (typically in situations where management of individual corporate securities (fixed income and/or equity) is appropriate), RubinBrown Advisors will suggest the use of one or more independent investment advisers. The client will enter into a separate agreement with these independent advisers. RubinBrown Advisors will periodically review the performance of these advisers and recommend changes based on the performance of the independent investment adviser and the need for direct management of individual corporate securities in the client’s overall asset allocation. P a g e 6 | 30 Any decision to hire, fire, or reallocate assets to an independent investment adviser is made by the client based on our recommendation, as RubinBrown Advisors does not have the discretionary authority to do so. Advice provided through third-party platform: Investment Advisory Services/Portfolio Management through the SEI Asset Management Program: RubinBrown Advisors, LLC used this method of advice when first starting in 2002 and several years thereafter, and many of those clients continue to be served in this manner. New clients are not set up using this service. RubinBrown Advisors manages client portfolios through the SEI Asset Management Program (the "Program"). In this program, SEI provides advisory services to RubinBrown Advisors (but not to the client) involving the structure and design of asset allocation portfolios comprised solely of mutual funds advised by SEI. SEI also advises RubinBrown Advisors with respect to reallocation and rebalancing of investments within such asset allocation programs. The Program is designed as followed: RubinBrown Advisors will determine the client's current financial situation, financial goals and attitudes towards risk through various analyses and questionnaires. This process will help RubinBrown Advisors review the client's situation and enable RubinBrown Advisors to recommend an initial asset allocation based on the client's specific needs and goals. In determining the initial allocation to be used, RubinBrown Advisors will use several model portfolios of no-load mutual funds provided to RubinBrown Advisors by SEI. RubinBrown Advisors will, if appropriate, suggest modifications to these models to more adequately address the client's individual needs. The client can place reasonable restrictions on the nature of the funds held in the portfolio or the allocation among the various classes, and RubinBrown Advisors will assist the client in understanding and evaluating the potential impact of these restrictions on the model portfolios. Once the client's asset allocation has been established, the portfolio will be implemented using the mutual funds advised by SEI. SEI Investments Management Corporation selects the investment managers of the underlying mutual funds. SEI utilizes institutional investment management firms. The fund managers are monitored by SEI to ensure that their investment styles and performance remain consistent with the objectives of the mutual funds. Accounts will be monitored quarterly and, when appropriate, RubinBrown Advisors will suggest a reallocation of the portfolio based on changing economic conditions or changes in the client's individual circumstances. As economic or market changes occur, SEI will make a quarterly review of its model allocations and will potentially recommend changes in these model allocations to RubinBrown Advisors. SEI will automatically reallocate all client holdings in model portfolios unless instructed to do otherwise by RubinBrown Advisors. If RubinBrown Advisors does not contact SEI prior to the first Friday of the month following the end of each calendar quarter, SEI will take RubinBrown Advisors' silence as a direction from RubinBrown P a g e 7 | 30 Advisors to make the recommended reallocations. SEI will not make any ongoing recommendations concerning portfolios which deviate from SEI's models ("custom portfolios"). RubinBrown Advisors is responsible for all reviews and must instruct SEI to make any changes to such portfolios. Clients can also instruct SEI to automatically rebalance the client's account if the allocation among the underlying mutual funds deviates from the prescribed quarterly allocation by greater than a 2% variance. For the tax-managed models, the variance is 3%. Rebalancing occurs monthly, with no transaction fees. Should the client's individual situation change, the client should notify RubinBrown Advisors, who will assist the client in revising the current portfolio and/or reevaluate their financial situation to determine if a different model portfolio would be appropriate to the client's new situation. Consulting through the SEI Managed Accounts Program: RubinBrown Advisors, LLC used this method of advice when first starting in 2002 and several years thereafter, and many of those clients continue to be served in this manner. New clients are not set up using this service. RubinBrown Advisors participates in the Managed Accounts Program (the Program) sponsored by SEI Investments Management Corporation (SIMC). To participate in the Program, RubinBrown Advisors, SIMC and each investor execute a tri-party agreement (hereinafter, a Managed Account Agreement) providing for the management of certain investor assets in accordance with the terms thereof. Pursuant to a Managed Account Agreement, the investor appoints RubinBrown Advisors as its investment adviser to assist the investor in selecting an asset allocation strategy, which would include a percentage of investor assets allocated to designated portfolios of separate securities (each, a Separate

Account Portfolio) and include a percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate thereof. The investor appoints SIMC to manage the assets in each Separate Account Portfolio in accordance with a strategy selected by the investor together with the Adviser. SIMC has the ability to delegate its responsibility for selecting particular securities to one or more portfolio managers. The Program seeks to provide a globally diversified portfolio in order to meet an investor's long-term goals. RubinBrown Advisors provides recommendations regarding a client’s asset allocation strategy and the choice of portfolio managers within the program. Upon the client’s approval of a recommended manager change, RubinBrown Advisors will instruct SEI to implement the agreed upon changes. The Managed Accounts Program offers the Integrated Equities Portfolio option. Under this option, an SIMC "Integration Manager" coordinates and implements the equity securities selections of the Separate Account Portfolio managers with the goals of providing clients with enhanced tax management, additional diversification and the simplicity of one equity account. Clients who elect to use Separate Account Portfolios should review the disclosure documents of the various managers of the Separate Account Portfolios to determine what types of investments will be included in the Separate Account Portfolio(s) selected by the client. P a g e 8 | 30 Consulting through Newport Group Securities, Inc.: RubinBrown Advisors also offers advisory services in association with Newport Group Securities, Inc. ("Newport"), an investment adviser firm not affiliated with RubinBrown Advisors. This service is offered to qualified retirement plans and non-qualified retirement plans. Newport will review client-specific information provided by RubinBrown Advisors and will prepare input to an investment proposal presented by RubinBrown Advisors based on the client's needs. RubinBrown Advisors will review this initial proposal with the client over a series of meetings in which the client's allocation and manager selection will be determined. Newport will recommend to RubinBrown Advisors and the client the use of mutual funds with whom Newport has entered into a sub-management agreement. RubinBrown Advisors will manage the portfolio of recommended mutual funds on a non-discretionary basis, and will review and suggest changes to that portfolio on a quarterly basis or as market conditions and client needs dictate. Newport will monitor the performance of all mutual funds that it recommends to RubinBrown Advisors' clients and will make recommendations to RubinBrown Advisors and the client with respect to the selection and retention of the mutual funds. The mutual fund managers will correspond to the proposed asset classes and investment styles of each client. Mutual funds are selected by Newport after an extensive evaluation and due diligence process that focuses on quantitative factors such as historical performance and volatility, and qualitative factors such as the mutual fund company’s reputation and approach to investing. Newport and RubinBrown Advisors will recommend mutual funds that are most appropriate for the client’s individual circumstances. Program clients will open a brokerage account with a brokerage firm that has contracted with Newport to provide brokerage, clearing and custody of securities purchased for the clients account and receive a monthly statement from the broker/custodian providing a detailed list of holdings with valuations and account activity as well as confirmations of all security transactions from the clearing firm. Newport will typically recommend the use of Fidelity Investments or Charles Schwab ("Schwab") to individual clients. The selection of the custodian for pension and profit sharing plans will be up to the plan trustees. Program clients should refer to Newport's disclosure document for any policy they have regarding selection of brokers, aggregation of trades, etc. RETIREMENT PLAN SPONSOR SERVICES We also provide several advisory services separately or in combination to retirement plan sponsors. While the primary clients for these services will be pension, profit sharing and 401(k) plans. Retirement Plan Sponsor Services are comprised of four distinct services. Clients are able to choose to use any or all of these services. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client (in person, video call or telephone call) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. P a g e 9 | 30 Selection of Investment Vehicles: We assist plan sponsors in constructing an appropriate lineup of investment options from which plan participants choose. We will then review various mutual funds (both index and managed) to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined by the client, based on the IPS and any other restrictions imposed by various service providers. Monitoring of Investment Performance: We monitor client investments continually, based on the procedures and timing intervals delineated in the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale of these investments. We make recommendations regarding the lineup of investment options provided by the plan sponsor as warranted. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we also provide periodic educational support and investment workshops designed for the plan participants when the plan sponsor engages our firm to provide these services. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report, which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. Financial planning is provided to investment advisory clients as part of their ongoing fee. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client's income tax and spending and planning for past, current and future years.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long- term care, liability, home and automobile P a g e 10 | 30
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• ESTATE: We assist the client in assessing and developing long-term strategies. These services include, review of basic estate planning documents (i.e. trusts, wills, powers of attorney, etc.), review estate tax, asset protection plans, etc. (As we are not practicing attorneys, we cannot draft documents for a client, but can recommend several attorneys should the client wish.) We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, but not hire us to provide ongoing advice, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or financial advisor/broker. Implementation of financial plan recommendations is entirely at the client's discretion. Financial Planning recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. Recommendations are of a generic nature; however, we will provide specific recommendations to potential clients CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This service includes advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. All recommendations are of a generic nature. AMOUNT OF MANAGED ASSETS As of our fiscal year end of May 31, 2023, RubinBrown Advisors, LLC's actively manages $2,341,084,197 on a non-discretionary basis, $5,948,252 on a discretionary basis and has Assets Under Advisement of $325,418,431. The value of the assets of the retirement plans RubinBrown Advisors provides services to the plan sponsors was $86,961,384 as of June 30, 2023. P a g e 11 | 30