RMR has been registered with the SEC as an investment adviser since 2009. Philip Rabinovich is the principal owner of RMR. Brian Mayer is the Chief Compliance Officer. RMR provides investment advisory services and has access to a wide range of non-affiliated investment advisers ("third-party money managers") via SEI, Fountainhead Asset Management (Fountainhead), and the Envestnet ENV2 platform. RMR is responsible for all advice and suitability of such advice regarding these accounts. A full description of all services is provided in the account services agreement. RMR provides discretionary account management with ongoing investment advice and monitoring for the Client's security holdings and will manage the account according to the Client's objectives. RMR offers multiple Managed Account Programs ("Program"), which consists of:
• Separately Managed Account Program (SMA)
• Multi-Manager Account Program (MMA)
• ETF/Mutual Fund Portfolio Program (ETF)
• Rep as Portfolio Management (Rep as PM)
• Retirement Plans Management (RPM) Under the program, the Client and the IAR compile pertinent financial and demographic information to develop an investment program designed to meet the Client's goals and objectives. IARs use systems offered through Envestnet, SEI Investments, and Fountainhead to analyze the client information and recommend an appropriate strategy based on the Client's needs and objectives, investment time horizon, risk tolerance, and any other pertinent factors. Separately Managed Account Program (SMA) SMA allows the IAR to select and create a portfolio of separate account managers. For clients under the Separately Managed Account Program (SMA), the IAR recommends individual asset managers from a database provided through a third-party vendor – Envestnet or SEI that correspond to the proposed asset classes and styles. The IAR evaluates managers specializing in each of the asset categories listed, including equities (both domestic and foreign); corporate debt; commercial paper; certificates of deposit; municipal securities; mutual funds; real estate investment trusts; government securities; options; and futures. The program includes performance reporting, associated services, and support (trading, reconciliation, fee calculation, etc.). Multi-Manager Account Program (MMA) MMA provides portfolios based on the Client's risk/needs profile. Separate managers within the portfolio are selected, monitored, and replaced when deemed necessary by Envestnet or SEI. Envestnet and SEI have developed and implemented a program to collect and report data on investment style and philosophy, past performance, and the personnel of Money Managers. Envestnet or SEI handles all asset allocation and trading. MMA includes performance reporting, associated services, and support. ETF/Mutual Fund Portfolio (ETF) This is a mutual fund and ETF wrap program where, based on the Client's risk/needs profile, mutual funds and ETF's are selected, monitored, and managed by Envestnet, SEI, or Fountainhead. This program is sponsored by Envestnet, SEI, or Fountainhead. This program includes quarterly performance reporting, associated services, and support. RMR will furnish you with an additional Wrap Fee Brochure which will provide additional information on these programs. Rep as Portfolio Manager (Rep as PM) With Rep as Portfolio Manager, the IAR manages the Client's account and creates, monitors, and adjusts customized portfolios. For clients under the Rep as Portfolio Management (Rep as PM), the IAR recommends investment vehicles that correspond to the proposed asset classes and styles. The Client is provided with an initial allocation that corresponds to the individual Client's goals and objectives. Once the Client's assets are invested, IARs may add, remove, or replace investments at their discretion. The program includes a rebalancing and multiple report capability. The Client may also utilize monitoring and reporting services on assets

held at outside custodians using the Black Diamond Portfolio Aggregation platform. Clients that participate in the program are required to grant full discretionary investment authority to the IAR. The IARs use their discretion to replace investment vehicles, including sub-managers, when such a change is deemed necessary, rebalance a client's account and liquidate sufficient assets to pay the Program Fee when necessary any other actions that the IAR deems appropriate. The IAR recommends an asset allocation and constructs a portfolio based upon the Client's needs and objectives. In some cases, managers supply the IAR with a model portfolio, and the IAR invests client assets accordingly. Each Client has the ability to impose reasonable restrictions in writing on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should not be sold if held in the account. If a client's instructions are unreasonable or an investment advisor representative believes that the instructions are inappropriate for the Client, RMR will notify the Client that, unless the instructions are modified, it may cancel the instructions in the Client's account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. From time to time, managers of non-traditional or alternative investment strategies are recommended to clients meeting the appropriate suitability criteria. Retirement Plans Management (RPM) Businesses choose to have IAR review and select both a platform and investment choices for retirement plan participants. Clients have numerous options to choose how the plan is administered, who will be record keeper, types of investments, and plan features. The IAR will perform an initial inquiry to determine which types of plans the Client chooses and will continue to monitor the plan on an ongoing basis for performance, fees, and plan features. ERISA and Individual Retirement Accounts Disclosure 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 interests 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. General Consulting In addition to the preceding services, RMR may provide general consulting services to clients. These services are generally provided on a project basis and usually include, without limitation, cash flow analysis, estate planning analysis, benefits consulting, and insurance analysis, as well as other matters specific to the Client, as and when requested by the Client and agreed to by RMR. The scope and fees for consulting services will be negotiated with each Client at the time of engagement for the applicable project. Assets under Management As of December 31, 2023, RMR held $109,589,300 in discretionary assets under management and $7,869,624 in non-discretionary assets under management.