Raffa Investment Advisers is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and a corporation formed under the laws of the State of Maryland and domiciled in Washington, D.C. Raffa Investment Advisers has been registered with the SEC as an investment adviser since July 2005. Raffa Investment Advisers is owned by the following individuals:  Dennis Gogarty – Managing Member and Chief Compliance Officer  Thomas J. Raffa – Member General Description of Primary Advisory Services The following are brief descriptions of Raffa Investment Advisers’ primary services. A detailed description of our services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the services and description of fees in a side-by-side manner. Investment Supervisory Services - Raffa Investment Advisers provides advisory services in the form of Investment Supervisory Services. Investment Supervisory Services involve providing clients with comprehensive portfolio management and continuous and on-going supervision over client accounts. This means we will continuously monitor a client’s account and make trades in client accounts when necessary. Qualified Plan Consulting Services - Raffa Investment Advisers provides several advisory services for corporate retirement plans, separately or in combination. While the primary clients for these services will be pension, profit sharing, and 401(k) plans, we will also offer these services, where appropriate, to individuals and trusts, as well as charitable organizations. Investment Consulting Services – Raffa Investment Advisers provides Investment Consulting Services in several ways.  We provide investment consultations on accounts not managed or maintained by our Firm. This service is similar to Investment Supervisory Services in that we will provide specific investment recommendations to clients; however, unlike Investment Supervisory Services, we will not have trading authorization or direct access to the accounts being reviewed under this service.  We provide investment consulting to the staff and volunteers at nonprofit organizations to support their effort to meet their fiduciary responsibility related to the management and oversight of their nonprofit’s investment reserves or endowments. These consulting engagements typically involve a process to develop or make recommendation to change their investment policies and procedures.  Other consulting engagements for nonprofits may involve presentations intending to educate nonprofit staff or volunteers on a variety of investment management or policy topics as well as providing assessments of an existing investment advisors performance, fees, or performance evaluation reports. In all cases where RWM is solely providing Investment Consulting Services, all trade implementation under this service is the responsibility of the client. Retirement Income Planning –

While RWM provides Retirement Income Planning services to clients that are individuals or couples as part of the overall portfolio management process, RWM does not charge separately for this service. The fee for this service, which is provided on a client-by-client basis, is included in the fee related to RWM’s Investment Supervisory Services. Limits Advice to Certain Types of Investments. Raffa Investment Advisers provides investment advice on the following types of investments.  No-Load (i.e., no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares  Exchange-listed securities (i.e., stocks)  Fixed income securities (i.e., bonds)  Exchange Traded Funds (ETFs)  Money market sweeps and funds  Certificates of deposit  Municipal securities  United States government securities RWM’s advice is primarily focused on open-ended mutual funds and exchanged traded funds that invest in the security types outlined above. We may utilize unaffiliated third-party investment managers when managing client portfolios and therefore will provide advice on other investment managers. We do not provide advice on foreign issue, warrants, commercial paper, variable life insurance products, options, futures, and interests in partnerships investing in real estate or oil and gas interests. Please refer to each program’s description at Item 5 – Fees for additional details regarding the types of investments recommended specific to the program. Please also refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and/or questionnaires to determine the client’s investment objectives and suitability information. When managing client accounts through the Firm’s Investment Supervisory Services program, we may manage a client’s account in accordance with one or more investment models. When client accounts are managed using models, investment selections are based on the underlying model and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Client Assets Managed by Raffa Investment Advisers As disclosed on Form ADV Part 1A, Item 5.F., the amount of client’s assets managed by Raffa Investment Advisers totaled $1,283,866,208 as of 12/31/2023. $1,132,622,810 is managed on a discretionary basis and $151,243,398 is managed on a non-discretionary basis. In addition, we provide reporting or consulting services on an additional approximately $412,050,354 in assets.