The Firm offers a variety of advisory services, which include consulting, investment management and wealth management services. In dealing with clients, RCM seeks first to evaluate a client’s current, holistic financial situation prior to managing their investments. The Firm designs and implements an investment plan aimed at achieving a client’s financial goals and objectives. Prior to RCM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). RCM was founded in May 2012, and is owned by its Managing Members, Douglas Pyle and Pierce Archer. As of December 31, 2023, RCM had approximately $709,312,648 in assets under management, all of which are managed on a discretionary basis. While this brochure generally describes the business of RCM, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on RCM’s behalf and is subject to the Firm’s supervision or control. Wealth and Investment Management Services RCM provides clients with wealth and investment management services which include management of investment portfolios. The Firm’s investment supervisory services include, but are not limited to, the following: (i) interpreting investment objectives and risk tolerance, including asset selection and allocation, (ii) documenting an individualized investment policy and investment strategy; and (iii) translating that policy and strategy into an ongoing client-focused investment process. Investment Supervisory Services RCM has two main approaches to investment management: (i) providing customized portfolio management and advice to wealthy and high-net worth individuals, their families and trusts (HNW); and (ii) the “Small-Midcap” equity product, a more structured portfolio product focusing on the small to mid- cap equity. While the investors end investment goals and tolerances will differ by client and product (HNW and Small- Midcap), RCM’s disciplines and strategies are readily adaptable to both individuals and institutions. As an organization, RCM strives to maintain commonalties for all investment programs and strategies. These commonalities would include: using individual

securities to build client portfolios (rather than primarily using mutual, index and exchange-traded funds (“ETFs”)); an orientation toward quality as evidenced by better balance sheets for equities and higher quality ratings for fixed income securities, generally limiting the number of equity positions to approximately 50 issues, that is, a more concentrated portfolio; and a fundamental approach to security analysis, making independent assessments of value, worth, and suitability. An individualized approach is applied to each HNW client. The Firm takes into careful consideration, among other factors, client risk tolerances and the allocation between equities, fixed income obligations and cash, the financial requirements and cash flow needs of beneficiaries, estate planning considerations, and securities cost basis and other related tax issues. RCM’s investment approach to Small-Mid equities, while well- defined in process, is eclectic in its output relative to various style analysis definitions. For this reason, and therefore by default, RCM is deemed to have a “core style” approach. Philosophically, the Firm is contrarian in nature, believes in concentrating the client’s portfolio in a limited number of positions (approximately 50), and is agnostic to benchmark industry weightings. For these reasons, RCM may sometimes be out of synchronization with the market benchmarks. The Firm’s specific investment strategies and associated risks are described in more detail in Item 8 (below). Serving as a Sub-Advisor RCM may from time to time participate and serve as a sub-advisor under other firms' advisory programs, including separately managed accounts (“SMA”). RCM receives a fee for account management services provided to clients of outside firm as outlined in a sub-advisory agreement. This agreement may also outline items such as the advisory services to be provided, the responsibilities of RCM and the other firm, and the terms of engagement including, but not limited to, fees and termination. Responsibilities such as collecting the clients’ investment objectives, determining the strategy best suited for the clients, and communication with the clients will be the responsibility of the outside firm. RCM has no responsibility to assess the value of services provided by the outside firm; therefore, the clients should evaluate whether such a program is suitable for their needs and objectives, and whether comparable or similar services are available at a lower cost elsewhere including by engaging RCM directly.