A. Description of Firm RCS was formed on November 27, 2002 in the State of California as a corporation. RCS first registered as an investment adviser with California in 2006. Since January 2010, RCS has been an SEC registered investment adviser.1 Effective December 14, 2022, Thomas Vaughan, CEO/President is the sole owner of RCS. For more information on Mr. Vaughan’s qualifications and business background, please refer to his respective Form ADV Part 2B Brochure Supplement. As further described in Item 4.B. below, RCS offers financial and retirement planning and investment management services to individuals and high net worth clientele. RCS believes in passive investing and primarily recommends exchange traded funds (“ETFs”) for client portfolios. Dependent upon the client’s unique goals and objectives, will recommend other investments, including mutual funds, equity stocks, bonds, treasuries, and money market instruments. B. Types of Advisory Services Offered RCS provide two primary types of advisory services: Financial and Retirement Planning and Investment Management Services, both of which are more fully described below. 1. Financial and Retirement Planning Services RCS offers Financial and Retirement Planning Services, which are more fully detailed in our written agreement with each client. When discussed and mutually agreed upon by RCS and the client, RCS provides consultation regarding the management of the client’s financial resources, based upon an analysis of the individual client’s needs. The Financial and Retirement Planning Services range from comprehensive financial planning to more focused consultations, depending on the needs of each client. Generally, RCS first conducts a complimentary initial consultation during which pertinent information about the client’s financial circumstances and objectives is collected. For more comprehensive services, the Firm reviews and analyzes the information provided by the client and then typically offers a written financial plan containing recommendations designed with the intention of achieving the client’s stated financial goals and objectives. Financial and Retirement plans are based on the client’s financial situation at the time the plan is presented and are based on the information disclosed by the client to RCS. Clients are advised that certain assumptions are made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. RCS cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the clients are strongly urged to promptly notify the Firm. For more information on the risks associated with investing, please refer to Item 8, below. 1 Note: Michael Philipp held 20% ownership from 3/19/19 to 12/14/22. Mr. Philipp retired from RCS on 12/31/22. Clients are free at all times to accept or reject any or all Financial and Retirement Plan recommendations made by the Firm and clients retain the authority and discretion on whether to implement RCS’ recommendations. If the client decides to follow the recommendations, the client has the option, but is under no obligation, to request that RCS implement such recommendations through the Firm’s Investment Management Services Should a client request RCS to implement such recommendations, the client will receive the services outlined in Item 4.B.2., below. To the extent requested by the client, RCS will provide consulting regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither RCS, nor any of its representatives, serves as an attorney or accountant, and no portion of RCS’s services should be construed as same. To the extent requested by a client, RCS will recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including representatives of RCS in their separate registered/licensed capacities as discussed below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from RCS. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please refer to Item 5 for important information relating to RCS’s Financial and Retirement Plan Services fees. For those clients who engage RCS to perform investment management services, the initial Financial and Retirement Plan Services analysis is conducted on a complementary basis. 2. Investment Management Services RCS provides clients with ongoing Investment Management Services, performed on a fully discretionary basis. RCS uses a passive indexing approach to investing. RCS makes portfolios with 10 different risk levels from 10% equity to 100% equity, in 10% increments (e.g., a 10% equities / 90% fixed income model portfolio would represent a conservative strategy, whereas a 90% equities / 10% fixed income model portfolio would represent an aggressive growth strategy).Within these risk levels, RCS has designed multiple base portfolio models for different strategies such as: low cost globally diversified portfolios, ESG (environmental, social, governance) portfolios, high dividend yield portfolios and portfolios with taxable or tax-free bond positions. RCS then customizes these base portfolios when appropriate to meet specific client requests or needs. The model portfolios typically consist of ETFs, but also can hold other positions, such as equities, fixed-income, mutual funds, cash management instruments and other financial products. In addition, upon client request and when appropriate, RCS also can use certain private funds to mitigate market risks. Note that RCS can hold cash as a stand-alone asset class and in times of a turbulent market, it is possible that the Firm can move to an all-cash position. RCS’s recommendation of a particular model is dependent upon the individual client’s risk tolerance, time horizon and specific goals. Prior to engaging RCS to provide investment management services, RCS conducts an initial financial and retirement plan analysis. During this process, RCS will use various software (including Money Guide Pro, Right Capital and Riskalyze) to determine the client’s risk tolerance and analyze what investment strategies should be weighed and considered to achieve the client’s goals. Based on this, RCS customizes the client’s portfolio based on the investment needs of that individual. Each RCS client is required to enter into a formal investment advisory agreement with the Firm prior to the commencement of any investment management services. This agreement sets forth the terms and conditions, including the scope of services to be provided and specific amount of investment advisory fees, under which RCS manages the client’s assets. Please refer to Item 5 below for important information. The client can, at any time, impose reasonable restrictions, in writing, on RCS’s services. As stated above, cash positions can be a tactical asset, and there are times when RCS recommends that a client go to a money market fund (cash) for some or all of the account for tactical reasons. Client portfolios are rebalanced daily as needed using the iRebal technology system. As part of RCS’s advisement, RCS, at times, will provide investment advice regarding unaffiliated private investment funds. RCS’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence regarding RCS’s investment advisory services. If a client wishes to become a private fund investor, RCS’s investment adviser representatives will work with the client and manage the other portfolio assets around that private fund investment. RCS’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike other liquid investments that a client can maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please refer to Item 8 for additional important Risk considerations. At times, as part of a risk mitigation and income strategy and when appropriate for a client’s portfolio, the firm will make use of derivatives. A derivative, primarily an option, is a contract to buy or sell a specific financial product officially known as the option's underlying instrument or underlying interest. For equity options, the underlying instrument is a stock, exchange-traded fund (“ETF”), or similar product. The contract itself is very precise. It establishes a specific price, called the strike price, at which the contract can be exercised, or acted on. And it has an expiration date. When an option expires, it no longer has value and no longer exists. Options come in two varieties, calls and puts, and you can buy or sell either type. RCS uses Covered Call type options and buys option contracts (calls and puts) in the portfolios where it utilizes options. A covered call is an options strategy that involves both stock and an options contract. The trader buys (or already owns) a stock, then sells call options for the same amount (or less) of the stock and then waits for the options contract to be exercised or to expire. If the options contract is exercised, the trader will sell the stock at the strike price, and if the options contract is not exercised the trader will keep the stock. For a covered call, the call that is sold is typically out of the money (OTM). This allows for profit to be made on both the options contract sale and the stock if the stock price stays below the strike price of the OTM option. If you believe the stock price is going to drop, but you still want to maintain your stock position for the time being, you can sell an in the money call option (ITM). For this, you will receive a higher

premium from the buyer of your call option, but the stock must fall below the ITM option strike price, otherwise, the buyer of your option will be entitled to receive your shares if the share price is above the option's strike price at expiration (you lose your share position). The buyer of call options has the right, but not the obligation, to buy an underlying security at a specified strike price. Buying a put option gives you the right to sell a given stock at a certain price by a certain time. For that privilege, you pay a premium to the seller ("writer") of the put, who assumes the downside risk and is obligated to buy the stock from you at the predetermined price. When buying calls and puts, the maximum risk (maximum loss) is the premium paid to own the option contract. Additional information on options can be found on the web at www.optionseducation.org. Tax accounting for options can be complex and can require the assistance of a qualified tax adviser. Please see Item 8 below for more information regarding our options strategy. a. Management of Variable Annuity Sub-Accounts Under the Firm’s investment management services, RCS offers discretionary management of clients’ new variable annuity contracts and will make selections and exchanges between sub- accounts available from the insurance company issuing the variable annuity. RCS will assist the client in completing a questionnaire which details the client’s financial goals, risk tolerance and time horizon. The client will have the opportunity to place reasonable restrictions on the sub-accounts available for selection. Model allocations are strategically developed utilizing the sub-accounts available within the variable annuity products. RCS may limit the product offerings at insurance companies on which investment management services are available. The limitations may be due to variable annuity sub-account options, annuity riders added to contracts or other factors. Total portfolio expenses may be higher than other mutual fund or managed portfolios based on the product, mortality and expenses and additional riders that may be added to the policy. In some cases, fees for managing the subaccounts can be deducted from the annuity. Fee deductions are generally considered distributions from the annuity, and will affect the annuity contract terms, and typically have tax consequences. Clients are encouraged to consult with a tax professional regarding any tax ramifications related to the variable annuity. Please see Item 5 below for additional information relating to fees. b. Management of 529 College Savings Plans RCS offers discretionary management of clients’ new 529 College Savings Plans and will make selections and exchanges between investments available from the plan sponsor. Also, when appropriate, RCS will provide clients advice regarding the use and implementation of non-discretionary 529 College Savings Plans. A 529 plan is a tax-advantaged investment vehicle designed to encourage saving for the future higher education expenses of a designated beneficiary. All education savings plans are sponsored by state governments, but only a few have residency requirements for the saver and/or beneficiary. State governments do not guarantee investments in education savings plans. Education savings plan investments in mutual funds and ETFs are not federally guaranteed, but investments in some principal-protected bank products may be insured by the FDIC. As with most investments, investments in education savings plans may not make any money and could lose some or all of the money invested. When appropriate, RCS will consult with the client and gather information regarding the client’s educational planning needs including ages of children, types of education plans, tuition forecasts, and tax implications. Based on this information, RCS will work with the client to determine which state-sponsored 529 plan will best match the client needs and assist the client with particular applications. RCS will monitor the account on an ongoing basis, making changes or recommendations on investment and allocation. 529 plans are considered part of the client’s overall portfolio and fees for RCS consultation on 529 plans is in accordance with the RCS investment management fee schedule. However, there are fees internal to 529 plans and the investments therein that can or will be assessed by the State’s 529 plan sponsor. 529 plan sponsors can or will charge an enrollment/application fee, annual account maintenance fees, and ongoing program management fees. Some of these fees are collected by the state sponsor of the plan and some are collected by the plan manager. Clients are highly encouraged to read all 529 plan disclosures provided by the particular 529 plan sponsor. Please see Item 5 below for information regarding the fees associated with 529 plans. c. Employer-Sponsored Retirement Plan Investment Management RCS offers discretionary investment management for clients’ employer-sponsored qualified retirement plans and will make selections from investments available through the plan sponsor. The client’s qualified retirement plan investment sponsor will maintain custody of all the account funds and securities. Previous advice arrangements for existing clients will be grandfathered. RCS will make investment selections and recommendations based on the client’s financial situation, investment objective, time horizon, tax status and risk tolerance. RCS cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. For more information on the risks associated with investing, please refer to Item 8, below. RCS will trade securities in a client’s qualified retirement plan using a third-party trading order management system which will then be communicated to the plan sponsor for execution. RCS is not able to aggregate these orders and trade alongside other client trades that are executed through RCS’s qualified custodian and may receive less favorable prices and execution. Order processing and execution times between the third-party trading order management system and investment plan sponsor that hold custody of the retirement plan may vary. Employer-sponsored qualified retirement plans that RCS provides discretionary investment management are considered part of the client’s overall portfolio. Fees for RCS’s investment management services on employer-sponsored qualified retirement plans are in accordance with the RCS investment fee schedule as stated in the Investment Advisory Agreement. However, there are fees internal to employer-sponsored retirement plans and the investments therein that can or will be assessed by the plan sponsor. Clients are highly encouraged to read all employer- sponsored retirement plan material and disclosures provided by the particular plan sponsor. Please see Item 5 below for information regarding the fees associated with employer-sponsored retirement plan investment management. C. Important Information Relating to RCS’s Advisory Services 1. Client Obligations and Responsibilities RCS offers our clients a selection of services. Clients who engage us for one of the services we provide are under no obligation to engage us for any of the other services. RCS is not required to verify any information we receive from the client or from the client’s other professionals, and the Investment Advisory Agreement expressly authorizes us to rely on information provided to us. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that the Firm may have relied upon in rendering its services. If a client notifies the Firm of such changes, RCS will review the changes and may recommend revisions to the client’s Financial and Retirement Plan and/or portfolio. 2. Courtesy (Non-Managed) Accounts As a matter of accommodation and convenience to existing RCS clients who have other managed assets with us, we may allow clients to establish courtesy accounts (“Courtesy Accounts”) at our custodian broker-dealer, Charles Schwab. Such Courtesy Accounts can only be established after the client signs a Courtesy Account Agreement. RCS does not assume the responsibility to monitor, trade or report on these accounts, or any securities that they may hold. Clients are strongly encouraged to effectuate their own trading in these Courtesy Accounts. RCS typically does not accommodate non-solicited trade requests from clients for Courtesy Accounts; only upon a client’s explicit written and/or verbal instructions and after review and approval by a member of RCS’s management team would this be considered. Clients who wish to establish a Courtesy Account should review the Courtesy Account Agreement carefully prior to signing it. RCS will not charge any fees on Courtesy Accounts. Clients can elect to have advisory fees withdrawn from a Courtesy Account for assets held in their other “Managed Accounts”. 3. Zero Fee Managed Accounts Advisory fees charged by RCS are negotiable at the sole discretion of RCS. Upon the approval of the Firm’s CEO, RCS may open a “Zero Fee Managed Account” for existing clients who have other managed assets with us at our existing custodian, Charles Schwab, in situations deemed appropriate by the CEO (i.e. where a client has a low yielding ultra-short-term bond investment portfolio). In such situations, (i) the client assets will not be counted towards the Firm’s assets under management, (ii) the Firm will provide discretionary Investment Management Services on behalf of the client assets held within the zero fee managed account as stated in the Firm’s Investment Advisory Agreement; and (iii) the Firm will not receive an advisory fee on such assets held in the zero fee managed account. Clients can elect to have advisory fees withdrawn from a non-qualified zero fee managed account for assets held in their other “Managed Accounts”. Prior to opening the Zero Fee Managed Account and providing investment management services, the Firm’s Investment Advisory Agreement signed by the client is required. The personnel responsible for opening client accounts are responsible for ensuring that a signed Investment Advisory Agreement is obtained and complete before any Investment Management Services will be provided. D. Assets Under Management As of December 31, 2023, the following represents the amount of client assets under management by RCS on a discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $265,206,130.00 Non-Discretionary $0.00 Total: $265,206,130.00 E. Wrap Programs RCS does not participate in any wrap programs at this time.