RF&L has been providing advisory services since 2006. As of January 1, 2022, RF&L is owned by Andrew Hass and Ryan Hass. As of December 31, 2023, RF&L managed $262,427,869 on a discretionary basis, $24,660,487 on a nondiscretionary basis and advised on $6,685,844 of self-directed retirement account assets. Investment Management Services RF&L will work with the client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. RF&L may use investment and portfolio allocation software to evaluate alternative portfolio designs. RF&L evaluates the client's existing investments with respect to the client's investment policy statement. RF&L works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by RF&L. RF&L will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. RF&L will typically create a portfolio of passive and/or evidence-based mutual funds and/or Exchange Traded Funds (ETFs) and may use model portfolios if the models match the client’s investment policy. RF&L will allocate the client’s assets among various investments taking into consideration the overall management style and risk tolerance. The mutual funds and ETFs recommended generally follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities. RF&L manages portfolios on a discretionary or non-discretionary basis. A client may impose any reasonable restrictions on RF&L’s discretionary authority, including restrictions on the types of securities in which RF&L may invest client’s assets and on specific securities that the client may believe to be appropriate. RF&L may also recommend fixed income portfolios to advisory clients, which consist of fixed income funds or individual

fixed income securities. RF&L will request discretionary authority from new advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, RF&L may retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain RF&L’s consent prior to the sale of any client securities. On an ongoing basis, RF&L will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. RF&L will periodically, and at least annually, review client’s investment policy, risk profile and evaluate the re- balancing of each client’s accounts to the extent appropriate. RF&L will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. Participant-Directed Retirement Account Services RF&L also offers advisory services to participant-directed retirement plans. RF&L will analyze the plan's current investment platform and assist the plan sponsor or trustee in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. RF&L will recommend investment options to achieve the plan's objectives, offer to provide participant education meetings, and monitor the performance of the plan’s investment vehicles. RF&L will recommend changes in the plan's investment vehicles as may be appropriate from time to time. RF&L generally will review the plan's investment vehicles and investment policy as necessary.