A. Description of Firm RVW Wealth, LLC, dba RVW Insurance Solutions LLC, The Jerusalem Portfolio, and RVW Investing LLC (collectively “RVW”) is a Los Angeles, California-based investment advisory firm, founded in 2006 RVW offers investment management services to individuals, high net worth individuals, trusts, estates, charitable organizations, pension and profit sharing plans, and various business entities like corporations, partnerships and limited liability companies. We are currently registered with the Securities and Exchange Commission ("SEC") as an investment adviser and with the State of California as a Limited Liability Company (“LLC”). We conduct business in a number of states, which are reflected in Part 1 of our Form ADV, a copy of which can be found on www.adviserinfo.sec.gov. B. Principal Owners Jonathan L. Gerber and Selwyn Gerber are the principal owners (Jonathan L. Gerber owning 40% and Selwyn Gerber owning 60%) of the firm, and as such are control persons of RVW. C. Types of Advisory Services Offered RVW offers investment management services on a discretionary basis. At the beginning of the client relationship, a representative of RVW generally meets with a client to discuss, evaluate and document the client’s investment objectives, individual risk tolerance, investment timeline, tax situation, specific restrictions and any other information relevant to the management of the client’s account (“Investment Guidelines”). Based on each client’s written Investment Guidelines, RVW will determine an appropriate asset allocation plan designed to diversify a client’s assets (“Managed Assets”) among various types of investments, including both U.S. and foreign equities, and fixed income (e.g., corporate and municipal bonds). For the equity portion, we utilize exchange traded funds (ETFs) and Mutual Funds (MFs) that invest in those types of securities. We do not invest clients’ assets directly in equity securities. Please refer to Item 8 for detailed information on our method of analysis and the risks involved with the types of securities we invest in. RVW provides continuous supervision and management of each client’s Managed Assets in accordance with the client’s Investment Guidelines and selected asset allocation plan. At least annually, RVW shall communicate with clients (either in writing or by scheduling a meeting) to review their Investment Guidelines to determine if there have been any material changes. However, clients are responsible for informing us anytime there are changes to the information in their written Investment Guidelines and should not wait for the annual meeting. In addition, we do not assume any responsibility for the accuracy of the information provided to us by the client. Prior to entering into an investment management agreement with RVW, a client should carefully consider: (a) committing to management only those assets that the client believes will not be needed for current purposes and that can be invested on a long-term basis; (b) that volatility from investing in the stock market can occur; and (c) that over time the client’s assets may fluctuate and at anytime may be worth more or less than the amount invested. RVW is licensed as an insurance agency with the State of California and certain of RVW employees are licensed agents and appointed with various non-affiliated insurance carriers. Depending on the Client’s overall investment guidelines and needs, RVW may recommend that a client purchase certain life insurance

or annuity products and implement such recommendation through RVW or one of the non-affiliated insurance carriers. This creates a conflict of interest since RVW and its licensed agents will receive regular and customary insurance commissions and other compensation should a client purchase the life insurance through RVW or one of the non-affiliated insurance carriers. Clients are under no obligation to implement such recommendation and/or implement the recommendation through RVW or the non-affiliated insurance carriers and should understand that other insurance agencies may offer similar services and the costs of such services may be higher or lower than those obtainable from RVW or the non-affiliated insurance carriers. Subscription Services RVW provides subscription services for free. These services include a newsletter that will offer recommendations on purchasing and selling specific securities, sectors, asset classes, or other specific groupings of securities at a stated time. D. Advisory Agreements Prior to engaging RVW to provide investment management services, clients are required to enter into an Investment Management Agreement (the “Agreement”) with us setting forth the terms and conditions of the engagement, the fees to be paid and the scope of the services to be provided. In accordance with Rule 204-3 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), RWV will provide a Brochure and one or more Brochure supplements (Form ADV Part 2B) to each client or prospective prior to or at the same time of the execution of an Agreement. The Agreement between RVW and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. RVW’s annual fee shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner, and with thirty (30) days advance written notice from the client. Neither RVW nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of RVW shall not be considered an assignment. E. Written Acknowledgement of Fiduciary Status 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 interest 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. F. Assets Under Management As of December 2023, the following represents the amount of client assets under management by RVW on a discretionary and non-discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $ 1,090,498,003 Non-Discretionary $ 22,882,207 Total: $ 1,113,380,210