____________________________________________________________________________________________________ Overview RMR Wealth Builders, Inc. (hereafter “RMR” or the “Adviser”) is an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). The firm, headquartered at 111 Grove Street, Suite 203, Montclair, New Jersey, was founded in 1986 and incorporated in New Jersey. The Adviser also maintains additional office locations in AZ, CA, CT, FL, MA, NJ, NY, PA, & RI. For over 35 years, RMR, through its founding partners, has embraced the discipline and practice of aligning fiduciary standards and professional principles. The owners of the privately owned company are Ryan P. DeGrau (Chief Executive Officer), Douglas R. Roth (Co-Chairman), Joseph J. Russo (Co-Chairman) and Edward A. Majitenyi (President), who undertake all of the Adviser's significant strategic and administrative decisions. None own 25% or more interest in RMR. Their combined experience in the industry is over 100 years. (Please refer to each Principal’s Form ADV Part 2B Brochure Supplement for additional details on their formal education and business background.) RMR serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. As used in this brochure, the words "we," "our," or "us" refer to RMR and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to RMR’s Covered Persons and Supervised Personnel: the firm’s Officers and Directors (“Control Persons”), employees, and Investment Professionals - the Registered Investment Advisor Representatives (hereinafter “IARs”) who, as either employees or independent contractors of the firm, are licensed, supervised, and approved by RMR to provide investment advice or advisory services on behalf of the Adviser. RMR’s investment advisory services are designed to help our clients strive to attain their financial goals. RMR’s IARs perform a critical role in each client’s account's introduction, communication, and management. Clients are introduced to us by these experienced IARs, and each advisory relationship at RMR will be managed by one or more such IARs registered with the firm, who serve as the primary point of contact between the Adviser and client. IARs are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their IAR may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the Investment Professionals providing advisory services, clients should refer to their IAR’s Form ADV 2B Brochure Supplement, a separate disclosure document delivered to them, along with this Brochure, before or at the relationship inception. If the client did not receive these items, they should contact their IAR or RMR’s Chief Compliance Officer at 201.836.2460 for a copy of these essential and informative disclosure documents.) IARs will collect financial profile information from clients at the onset of the advisory relationship, make a reasonable effort to confirm or update the written client information no less than annually to keep the data current and recommend specific advisory services or programs deemed appropriate for each client’s financial circumstances, goals, objectives and situation. RMR offers access to a wide range of services and products to aid clients in the pursuit of their financial goals and a variety of investments from which to choose, including but not limited to mutual funds, exchange-traded funds ("ETFs"), variable annuities, business development companies ("BDCs"), real estate investment trusts ("REITs"), equities, fixed-income securities and Digital Assets. (Please refer to the description of each type of advisory service, as well as Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss, for additional information.) Non-Exclusive Relationship RMR supports and maintains an open environment where its Associates and IARs have access to the technology, tools, products, and support we believe necessary to meet our goal of providing diverse and quality client services. Together with the assistance of our preferred Qualified Custodian(s), we aim to deliver a white-glove approach with respect to the resources, support, operations, technology, compliance, guidance, oversight, business development, investment selection, and platform access we make available to our Investment Professionals and clients. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred Qualified Custodians and custodial practices.) RMR's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client may differ or conflict with that provided for the same security or investment for another. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss.) Other Professional Service Provider Recommendations If requested by the client, RMR may recommend the services of other professionals for implementation purposes. These professionals, who may be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Unless disclosed otherwise, RMR is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any RMR client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract, including fees and charges. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from RMR. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities RMR's advisory services depend on and rely upon the information received from our clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Investment Management Agreement contract (hereafter, the “Advisory Agreement,” or “Agreement”). Regardless of whether the client has provided discretionary authority or retains the right to make the final decision, it is the client’s responsibility to ensure their RMR IAR has all the information necessary to make recommendations and/or manage the account in the client's best interest. Clients will acknowledge and consent to this obligation to promptly notify RMR in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. Our IARs will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - RMR will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. RMR reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided. Description of Advisory Services RMR is a financial planning and investment management firm; it does not sell advisory securities on a commission basis. RMR's Investment Professionals emphasize personal client contact and interaction in providing the following individually tailored investment advice and advisory services:  Portfolio Management Services* - Traditional Portfolio Management Services Program - IAR Client Investment Portfolio Non-Wrap Fee Program (hereafter “CIP Program”) - Wrap Fee Portfolio Management Services Programs - IAR Client Investment Portfolio Wrap Fee Program (hereafter “CIP Program”), or - Third-Party Manager Wrap Fee Program (hereafter “TPM Wrap Fee Program,” with RMR as investment adviser and the TPM as sub-adviser)  Annuity Management Services  Digital Asset Management Services  Financial Planning Services - Single Engagement - Ongoing Planning  Retirement Plan Services  Educational Seminars Services  Pontera Services (*Portfolio Management Services are offered to prospective and existing advisory clients with the option to make investment management services and transaction/commission costs available via a convenient single "Wrap Fee,” in conjunction with RMR as Wrap Fee Program Manager and Sponsor for the CIP and TPM Wrap Fee Programs. Please see RMR’s Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for complete details.) RMR’s advisory services are designed and aimed to complement each client's specific needs, as described within its written Advisory Agreement that discloses, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to us - either discretionary or non-discretionary. (Refer to Item 16: Investment Discretion for complete details on the kinds of discretionary authority clients may choose.) All advisory clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create this customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, and realistic and measurable goals are set based on the disclosed information and objectives to define those goals. According to the selected service(s), the client’s written Agreement will document the details of the advisory relationship and final advisory fee structure. Following the Agreement's provisions, fees are calculated via BlackDiamond, RMR’s online electronic trading and reporting system. According to the client’s Agreement, custody of client assets will be held by one of RMR’s chosen independent and separate Qualified Custodians who will take possession of the cash, securities, and other assets within the client's portfolio account. RMR delivers a report to the Qualified Custodian, and fees are then automatically directly debited from the client's account. RMR urges clients to review Qualified Custodial account statements received promptly upon receipt and compare them against the client’s executed Advisory Agreement, the appropriate benchmark for their portfolio, and any periodic portfolio report, data or statement they may request from us to ensure the accuracy of account transactions. (See Item 5: Fees & Compensation for further details on advisory services fees and Item 16: Investment Discretion for more information about account management styles.) IARs are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in RMR's advisory services, and clients may engage the Adviser for additional services at any time. Revisions to existing Advisory Agreements will be made following the terms of the existing Agreement. Following is a summary description of advisory services covered by this Brochure. Clients should consult with their IAR and the applicable client Agreement and Disclosure Brochure fee schedules for additional details regarding each service. Wrap Fee Program services clients should refer to RMR’s Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for additional details. Portfolio Management Services RMR’s portfolio management services, available as traditional or Wrap Fee Program options, are personalized and designed to accommodate diverse investment philosophies and objectives while intending to complement each client's specific needs, as described in each Advisory Agreement. After completion of the initial client suitability profile (as previously detailed), if requested for use with the client’s investment management program, we will develop an Investment Policy Statement (“IPS”) for the portfolio using the client’s identified and approved investment parameters and other relevant information. We will then consider the information gathered and the approved IPS to recommend the portfolio management service believed to be in the client’s best interest. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their IAR. Clients are ultimately responsible for establishing their investment policy. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. After clients have received and reviewed their IAR’s recommendation(s) and have agreed to proceed, their IAR will work with them to implement the portfolio management services they approved. RMR does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from advisory accounts. According to the client’s Agreement, custody of client assets will be held by one of RMR’s chosen independent and separate Qualified Custodians who will take possession of the cash, securities, and other assets within the client's portfolio account. Fidelity Investments Institutional Services Company, Inc. (“Fidelity”), or Charles Schwab & Co., Inc. (“Charles Schwab”), both independent and separate registered Broker-Dealers, Members of The Financial Industry Regulatory Authority (“FINRA”) and The Securities Investor Protection Corporation (“SIPC”), will take possession of the cash, securities, and other assets within the client's portfolio account unless the client directs otherwise. While Fidelity and Charles Schwab are RMR’s preferred Qualified Custodians, RMR has relationships with various mutual fund custodians who may also be used if appropriate for the type of account opened. These relationships are disclosed to the client before any investment is made. (For example, certain 529 Plan accounts are held with American Funds. Contact us directly for a current list of additional Custodians used.) Digital Asset services clients will maintain their assets with Gemini Trust Company, LLC (“Gemini Trust”) and their Individual Retirement Account (“IRA”) Digital Assets account assets with Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves, which remain custodied with Gemini Trust. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred Qualified Custodians and custodial practices.) RMR will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS as applicable to the type of account opened and according to the Adviser’s standard Fee Schedule as reflected herein and more fully explained in each client’s executed Agreement. Clients should consult their Agreement for complete details. (See Item 5: Fees & Compensation for additional information.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and IAR review their financial situation and portfolio through regular contact and annual meetings to determine fluctuations in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Model Portfolio Selections Under RMR’s portfolio management services option, when customizing an investment portfolio and if appropriate for the client’s situation, IARs can recommend one or more of RMR’s Model Portfolio Selections in which the IAR, as Investment Manager, will make appropriate changes to the allocation, investments, and holdings to align the Model Portfolio with each client’s stated investment criteria, written restrictions or other instructions received. Clients can choose from the three Model Portfolio options that RMR manages and/or sponsors: 1. CIP Non-Wrap Fee Program, 2. CIP Wrap Fee Program , or 3. TPM Wrap Fee Program. A description of each Model Portfolio follows: IAR Client Investment Portfolio (“CIP”) Non-Wrap Fee Program - RMR’s CIP Program is offered to prospective and existing advisory clients following our customary interview and discussion process. Client investment management services and transaction costs will be assessed separately (i.e., in a “non-Wrap Fee” manner). IAR Client Investment Portfolio (“CIP”) Wrap Fee Program - RMR’s CIP Program is offered to prospective and existing advisory clients following our customary interview and discussion process. However, with this option, clients can elect to have their investment management services and transaction/commission costs made available via a convenient single "Wrap Fee.” (See “Wrap Fee Program” within this section and RMR’s Form ADV 2A Appendix I - Wrap Fee Program Brochure for additional details.) The Third-Party Manager (“TPM”) Wrap Fee Program - under RMR’s TPM Program, RMR retains the ability to select, recommend and provide access - after appropriate due diligence, to independent third-party manager advisers from the group of approved managers participating in its TPM Program service option, with whom RMR has entered a written agreement to make their sub-advisory services available, to guide and administer clients' accounts. The minimums for unaffiliated referred manager accounts generally range between $25,000 and $1,000,000. RMR will refer only those individuals or entities suitable for its TPM Program services, offered as Wrap Fee Accounts. RMR carefully selects the TPMs it deems suitable for this Program based on the client’s investment objectives and other specified account parameters. Typically, to enroll in this Program, Clients will sign an Agreement with RMR selecting the TPM Program. Occasionally, an agreement between the client and the TPM is required. In such instances, the additional contract requirement will be explained to the client at the time of relationship inception. The client will receive copies of all material operative documentation and disclosures related to such arrangements detailing the nature of the relationship, compensation to RMR, and other general terms of the referred manager’s contract. RMR's role in the relationship is to verify that clients are appropriate to become TPM clients, determine if the potential referred client has assets to invest in, and confirm that they have a minimum understanding of financial investing. IARs will assist clients in completing their investor profile to aid the TPM in determining the appropriate account allocation strategy and help with any questions they may have about the manager or Program. Clients who elect to participate in the TPM Program are offered a selection of Model Portfolios with varying levels of risk using various investment strategies as described in each independent manager’s Form ADV. The type of contract will dictate specific account management, authority, and any limitations therein the client enters and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The client's investor profile will also determine any adjustments made. RMR and the referred manager will provide all investment advice to the client, bear fiduciary responsibility, and maintain responsibility for these items. TPM accounts will typically be placed at RMR’s Qualifying Custodian, who will take possession of the account's cash, securities, and other assets. The TPM is required to have the ability to access the account. While RMR will have discretion, it will not trade the client’s account but can decide to hire or fire the TPM from providing services. According to the referred manager's review parameters, client accounts will be reviewed within the context of the client's stated investment objectives and guidelines. The client’s IAR will monitor the TPM to ensure the TPM’s selections and account strategy maintain consistency with the client’s investment objectives. The TPM will also be replaced to align with portfolio parameters and objectives as necessary. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for communicating to their referred manager and RMR all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship promptly and as they occur. (Please refer to Item 15: Custody for additional details on custodial practices.) RMR does not maintain the authority to accept any client on behalf of any referred manager, and referred managers are not responsible for accepting any prospective investor (and possible future client) referred to them by RMR. Each manager has the right to reject any referred client for any reason or no reason at all. It is the client’s responsibility to review and understand all applicable disclosure brochures before participating in any TPM Program. TPM Program advisers are subject to review by RMR's standards for inclusion and subject to future change from time to time. Clients should refer to their referred manager’s contract for complete details. Further, clients should be aware that the referred third-party managers we recommend receive their compensation directly from RMR according to our business arrangment with that particular TPM. Depending on the compensation arrangements, a conflict of interest can exist if we have a strategy benefit to recommend the services of the referred manager. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended managers. Annuity Management Services RMR offers annuity management services for a flat advisory fee not to exceed the guidelines reflected within the Adviser’s Disclosure Brochure and IRS Private Letter Ruling Number 202104001. To participate in this service, following our customary interview, discussion and analysis process, clients will execute RMR’s Annuity Management Services Agreement to appoint RMR as Adviser and their appropriately licensed IAR as Investment Manager to review, recommend and service their annuity contracts, including but not limited to Fixed, Variable, and Indexed annuities, and effect investment transactions believed to meet fiduciary, best interest, and impartial conduct standards for the annuity contract assets. With this service, clients will authorize and appoint RMR and its IAR as attorneys and agents-in-fact for their annuity contract assets and grant full discretionary authority to buy, sell, or otherwise effect investment transactions for the assets in their name and annuity contract. Clients will authorize RMR to instruct the Insurance Company product provider holding each of their annuity contracts of focus to liquidate investments and mail or wire specific monies to the client’s address of record - or another pre- designated bank account, according to the client’s written instructions. At the Insurance Company product provider’s request, clients may also be required to execute additional documentation to grant this discretionary authority to RMR and their Investment Professional. For annuity contracts recommended or serviced that are subject to security buy, sell, or hold recommendations, investment allocations will be selected based on the available investments specified in the annuity contract issued by the Insurance Company. RMR will not maintain custody of any of the assets associated with the client’s annuities; the client, at all times, will retain full and complete ownership rights to all assets held in their Insurance Company annuity contract. However, clients should be aware that recommendations related to annuity sub-account holdings of securities subject RMR and IARs to potential conflicts of interest, which can subject recommendations involving securities to require the pre-approval of any Broker-Dealer with which RMR and their IAR are licensed or affiliated in any capacity. It is the client’s responsibility to have received, read, and understand all additional and other applicable fees and charges separately disclosed by the Insurance Company, any insurance-related entity, or unrelated third-party entities that provide services and receive compensation arising from or related to the annuity contracts recommended by RMR, which fee schedules and charges are provided directly to the client by the Insurance Company before or upon delivery of the Annuity Contract and are in addition to, separate, and distinct from RMR’s advisory Fees. (For example, the client may incur other charges imposed by the Insurance Company, including, but not limited to, mortality and expense (“M&E”) fees, annuity contract rider charges, and other expenses disclosed in the client’s Annuity Contract). Digital Asset Management Services Digital Assets, a new technology that generally refers to an asset issued and/or transferred using distributed ledger or blockchain technology (including virtual/cryptocurrencies, “coins,” and “tokens”), is recommended to clients, as appropriate, through RMR’s Digital Asset management services option. Clients wishing to participate in this service will execute RMR’s standard Advisory Agreement and a separate and additional contract (an “Advisory Agreement Digital Investment Management Experience (“DIME”) Agreement) to authorize the activity, select RMR as their Investment Adviser, and designate their IAR as Investment Manager. Due to the volatile nature of the digital assets market, clients are required to grant full discretionary authority within the Agreements to RMR and their IAR to execute the transactions deemed to be in their best interest. The authorization will also allow RMR to assist them with account registration, provide access to the Adviser’s Model Portfolio recommendations to construct and manage a customized Digital Assets investment portfolio and execute transactions, as necessary, to strive to achieve the client’s investment objectives while observing any noted account restrictions. Additionally, it is essential to note that while the digital assets market is open 24/7 for 365 days each year, RMR will be available to execute transactions between the hours of 9:30 a.m. - 4:30 p.m. Eastern time. Digital Assets management services accounts are offered through Gemini Trust Company, LLC (“Gemini Trust”) as custodian. For client Individual Retirement Accounts (hereinafter referred to as "IRAs”), Equity Trust Company (“Equity Trust”) generally serves as the third-party IRA account custodian but will not be the custodian of the digital assets themselves, which will remain custodied with Gemini. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under the DIME Agreement. Digital Assets accounts offered by RMR may incur additional charges, expenses, and miscellaneous fees separate from the client's Annual Advisory and Administrative Fees. It is the client’s responsibility to have received, read, and understand all documents and any additional fees and charges disclosed by their account custodian, which are separate and distinct from the RMR’s advisory Fees. (See Item 5: Fees & Compensation and Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Financial Planning & Consultation Services RMR offers financial planning and advisory consulting services individually tailored to each client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. In offering these advisory services, RMR will make certain assumptions for interest and inflation rates and use past trends and market and economic performance. Past performance does not indicate future results, and we do not offer any guarantees or promises that clients' financial goals and objectives will be met. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Service scope, as determined between the client and IAR, is available via the following personalized options: 1. Single Engagement 2. Ongoing Planning

A more detailed description of each service option follows: Single Engagement – Single Engagements for Financial Planning services are available to Clients as either a Comprehensive Financial Plan or an a la carte menu of Financial Planning services offered by RMR. The a la carte menu of services available includes, but is not limited to, Cash Flow Analysis, College Planning, Insurance and Needs Analysis Review, Investment Review, Tax Planning, and Estate Planning. A Comprehensive Financial Plan will include but not be limited to each planning service offered on the a la carte menu by RMR. Clients also have the option to build their own package of services from the a la carte menu. The fee for providing services under a Single Engagement is based on the cost of the services selected from the menu of services available. RMR charges a flat fee for a Comprehensive Financial Plan. Ongoing Planning - beyond a single engagement, we provide our clients with the option of Ongoing Planning assistance. RMR has set a minimum asset on the platform threshold of $250,000, including ongoing planning services, which is negotiable. We also offer ongoing planning services for $1,500, charged annually, or $150/month, charged monthly. Fees of continuing planning are negotiable. To participate in any of the above options, clients will execute a Financial Planning & Consulting Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and fees due before RMR commences services. The final fee structure will be documented within the executed contract. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning and consulting services can take approximately one week to six months. If services are not delivered within six months, any unearned revenue is pro- rated and refunded to the client following the terms and conditions of the executed Financial Planning Agreement. Financial plans are based on the client's financial situation when the plan is presented according to the financial information disclosed by the client to RMR at the time of Agreement execution. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Any subsequent financial planning services require the execution of a new Financial Planning & Consulting Agreement. Updating financial plans may be subject to an additional fee, which the client must approve in writing before further services commence. (See Item 5: Fees & Compensation for complete details.) As with all RMR advisory services, the client is expected to promptly notify us in writing of any material changes in assets, net worth, indebtedness, or planning objectives that RMR would not otherwise know. The client or their successor shall also promptly notify us in writing of (1) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (2) the occurrence of any other event that might affect the validity of their executed Agreement or RMR's authority thereunder. RMR reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning & Consulting Agreement for complete details. Financial planning services may be the only service provided to the client. Executing a Financial Planning & Consulting Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by RMR, or any insurance or other products or services provided by any RMR IAR as a result of any business activities in which they may participate outside their advisory activities with RMR. Neither RMR nor the client’s IAR will have discretionary investment authority when offering financial planning or consulting services. This service does not include implementing or monitoring IAR’s recommendations to the client. Further, written financial plans typically do not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Clients are not obligated to act on any RMR financial planning or consultation recommendations or implement any financial plan or recommendation through our firm. Clients may act on recommendations by placing securities transactions with any brokerage firm they choose. Retirement Plan Services As part of its portfolio management services, RMR also offers retirement plan services, wherein various levels of advisory and consulting services, investment due diligence, education, and other investment advisory services are provided, as described herein, to clients with employee benefit plans or other retirement accounts for a fee. These services are designed to assist Plan sponsors in meeting their management and fiduciary obligations to Plan Participants under the Employee Retirement Income Securities Act (“ERISA”). Under this service option, clients can participate in the following: 1. Plan Fiduciary Education Services 2. Participant Education Services 3. Service Provider Search Support 4. Plan Design Support Services 5. Plan Operation Support 6. Investment Adviser Services - 3(21) (i.e., Investment Policy Statement, investment selection, performance monitoring and reporting and additional services as specified from time to time within the client’s Agreement.) 7. Investment Manager - 3(38) (Investment Selection, performance monitoring and reporting, and additional services, if any, as specified from time to time within the client’s Agreement.) RMR is considered a fiduciary under ERISA and regulations under the Internal Revenue Code of 1986. In this capacity, our status is as an investment advisor registered under the Investment Advisers Act of 1940 and a fiduciary under ERISA Part 4 Title 1. In performing these services, RMR acts either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA or as a discretionary fiduciary of the Plan defined in Section 3(38) under ERISA. RMR is not subject to any disqualification under Section 411 of ERISA. In connection with such accounts and pursuant to adopted regulations of the U.S. Department of Labor (“DOL”), we are required to provide the plan’s Responsible Plan Fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) and clients with a written statement of the services we provide to the Plan, compensation we receive, any conflicts of interests present, our status as an ERISA fiduciary, and the following notice: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. How we are compensated creates 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: 1. meet a professional standard of care when making investment recommendations (give prudent advice), 2. never put our financial interests ahead of yours when making recommendations (give loyal advice), 3. avoid misleading statements about conflicts of interest, fees, and investments, 4. follow policies and procedures designed to ensure that we provide advice that is in your best interest, 5. charge no more than is reasonable for our services, and 6. give you basic information about conflicts of interest. RMR benefits financially from the rollover of a client’s assets from a retirement account to an account that we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Our policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are not obligated to have their retirement assets managed by RMR. If a client or a prospective client receives a recommendation to leave their plan assets with their old employer, RMR will receive no compensation. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, RMR will have discretionary account Plan Fiduciaries evidence of their authority to retain our advisory services and appoint us as an "Investment Manager" within the meaning of Section 3(38) of ERISA for those Plan assets that comprise the client's account. The Plan Fiduciary will confirm that RMR's Agreement services are consistent with Plan documents and furnish true and complete copies of all Plan governing documents. The Plan Fiduciary will provide us with a copy of all relevant documents requested, confirm, and agree that their selected advisory program is consistent with those documents, and will notify us, promptly in writing, of any changes to any of the Plan's investment policies, guidelines, restrictions, or other related documents regarding Plan investments. If the assets in the account constitute only a part of the Plan’s assets, the Plan Fiduciary will provide us with documentation of all Plan investment guidelines or policies that affect the account. Under ERISA requirements, the client will acknowledge that RMR has no responsibility for the overall diversification of all the Plan's investments and no duty, accountability, or liability for any partial Plan asset not under RMR’s advisement. The compliance of any recommendation or investment RMR’s IARs make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. RMR is not responsible or liable for Plan administration or the performance of any other duties not expressly outlined in the Agreement. Further, the client must obtain and maintain - at their own expense, any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, and agents concerning RMR’s Agreement. Plan fiduciaries will promptly provide appropriate documents evidencing such coverage upon request. If ERISA or other applicable law requires bonding for the account's assets, RMR will ensure bonding is in place to satisfy the obligation to cover RMR and all Associates whose inclusion is expected by law. ERISA & Retirement Plans Special Disclosures In this Brochure’s Section 5: Fees & Expenses, RMR has disclosed potential conflicts of interest, such as receiving additional compensation from third parties (e.g., 12b-1 fees) for marketing, recordkeeping, or other services connected with certain investments. RMR has adopted policies and procedures designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. (For example, RMR has taken several steps to address the potential conflict of interest of IARs, who receive compensation for services provided to ERISA Plans. First, an IAR negotiates the compensation with ERISA Plan sponsors or participants (“ERISA clients”), and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate.) As a covered service provider to ERISA plans, RMR will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). RMR does not allow IARs to provide advice or manage ERISA client assets if conflicts of interest exist that RMR believes are prohibited by ERISA. Thus, RMR’s practice is to disclose (1) direct compensation received from ERISA clients, (2) indirect compensation received from third parties, and (3) transaction-based compensation (i.e., commissions) or other similar compensation shared with related parties servicing ERISA plans. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending an ERISA client’s advisory service Agreement. RMR also provides participant and fiduciary education, vendor selection, reporting and technology services support, and other non-investment-related assistance for ERISA, retirement, and other qualified account clients. Retirement Account Rollover Considerations Individual participants in corporate Plans advised by RMR who are retiring or changing jobs can request that RMR provide additional educational information concerning tax-free transfer options and details on the benefits of keeping assets in the Plan as long as they remain eligible. RMR will not solicit Plan Participants to retire or change jobs. For Plan Participants who decide to leave the Plan of their own accord due to retirement or change to a new employer, we can be separately engaged to provide recommendations on the advisability of taking retirement Plan distributions. Any Plan Participant services that include discussions about individual distributions or how to invest distribution proceeds will be performed separately with the Plan Participant. In determining whether to make a retirement account rollover to RMR, Plan Participants and clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company Plans. Further, current employees can sometimes move assets from their company Plan before retiring or changing jobs. RMR will consider various factors before recommending retirement plan rollovers, including the investment options available in the Plan versus others available, the rollover options available, each individual's age, personal circumstances, investment options, Plan fees and expenses versus those of alternative account types, services, conflicts of interest, penalties, protections from creditors and legal judgments, required minimum distributions and employer stock tax consequences, the services and responsiveness of the Plan's Investment Professionals versus those of RMR, and employer stock tax consequences (if any), among others. To the extent the following options are available, clients should carefully consider the costs and benefits of the following:  leaving the funds in the employer's/former employer's Plan,  moving the funds to a new employer's retirement Plan,  cashing out and taking a taxable distribution from the Plan, and  rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for RMR to manage are encouraged to speak with their CPA or tax attorney before taking any action or changing. The following is also offered for your consideration before making a change: 1. Determine whether the investment options in your employer's retirement Plan address your needs or whether you might wish to consider other investment types: - Employer retirement Plans generally have a more limited investment menu than IRAs. - Employer retirement Plans may have unique investment options, such as employer securities or previously closed funds, unavailable to the public. 2. Consider Plan fees & expenses - your current Plan may have lower fees than RMR’s. - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement Plan and how the share class costs compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. RMR’s strategy may have a higher risk than your Plan's option(s). 4. Your current Plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. - Generally, federal law protects assets in qualified Plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so consult an attorney about protecting retirement Plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed anytime; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your Plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your Plan may allow you to hire RMR as the manager and keep the assets in the Plan name. Educational Seminars Services RMR provides complimentary investment educational seminars and workshop services and can speak at community events and conferences on various investment topics on an "as-announced" basis for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content will vary depending upon the attendees' needs and are purely educational – they do not involve selling any investment products. The information presented will not be based on any individual’s needs. RMR does not provide personalized investment advice to attendees during such events. RMR will only provide investment advice if engaged independently and only where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes and do not deliver specific accounting, investment, legal, tax, or professional advice. Attendees have no obligation to schedule a consultation, purchase services from RMR, or become clients. Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access plan participants' accounts where we do not have custody but can provide advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. RMR and its IARs will review these accounts at least annually and determine if any changes to the allocation are necessary. Available investment options are considered each time the account is reviewed. RMR and its IARs are not affiliated with Pontera in any way, and we do not receive any compensation from Pontera for using their platform. Clients who engage RMR and its IARs for this service will connect their account to the Pontera platform using a link provided to the client. Once the account is connected to Pontera, RMR and its IARs will have access to view account information, including but not limited to the allocation and available investment options. (See Item 5: Fees & Compensation.) This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to provide advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans that RMR and its IARs are the advisors of record. Wrap Fee Program Services As indicated within the preceding “Portfolio Management Services Model Portfolio Selections” section, RMR provides investment and portfolio management services via a Wrap Fee Program, a transaction fee rebate program that differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Clients will choose from RMR’s CIP Program or TPM Program. The assets in each Program are regularly monitored, and investment strategy purchases and sales transactions are based on the client’s specific needs and investment goals. Before participating in either of RMR’s Wrap Fee Program options, clients will be required to enter into a separate written Wrap Fee Program Agreement that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, and fees to be paid. Under our management, the annual “Wrap-Fee" for each Program participation depends upon the market value of the client’s assets. Clients will invest in the Wrap Fee Program by establishing one or more accounts (the "separately managed account" or "accounts") with the Wrap Fee Program’s Qualified Custodian, each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Wrap Fee Program's cost-effectiveness to the client, and RMR will receive a portion of the single Wrap Fee clients pay to participate in our Wrap Fee Program services. The SEC rules require that a Wrap Fee Program Brochure be provided to clients before or when entering a Wrap Fee Program Agreement. This Brochure provides clients with important information about the Wrap Fee Program, including further information about the services and fees participating clients will pay. The overall costs clients will incur if they participate in one of our Wrap Fee Programs can be higher or lower than they could incur by separately purchasing the types of securities available in our Wrap Fee Program. (Please refer to the adviser's Form ADV Part 2A - Appendix I, the Program Brochure, for a complete description of the Wrap Fee Program, fees, and services.) Clients should be aware that a conflict of interest exists whenever RMR recommends participating in its Wrap Fee Program services because RMR and its IARs could be financially incentivized to recommend services as non-Wrap Fee services. RMR could have a disincentive to purchase or sell securities in the client’s account because we pay the transaction costs associated with trades directed at the custodian. (For more information, see Item 5: Fees & Compensation and RMR’s Form ADV Part 2A Appendix 1 – Wrap Fee Program Brochure.) Client Tailored Services & Imposed Restrictions Client Tailored Services RMR offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at RMR's discretion, as detailed herein and defined in each client's written Agreement. (For more information, see Item 5: Fees & Compensation.) Client Imposed Restrictions Portfolio management services clients who engage RMR on a discretionary basis may, at any time, impose restrictions on RMR's discretionary authority. Clients may impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to RMR in writing. Clients may also amend/change such limitations by once again providing written instructions. Reasonable efforts are used to comply with client investment guidelines, including any client's reasonable limits by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client imposed restrictions within their account, and variations could result in positive or negative performance differences for the account compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Upon receiving a client's written restrictions, RMR will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the possible outcomes of the imposed restriction. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, RMR reserves the right to end the client relationship. In no event and regardless of the advisory service provided is RMR obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Clients may restrict TPM Program accounts according to the referred manager’s Wrap Fee Program Agreement. Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. RMR will generally provide investment advice and money management for a varied range of product offerings and securities including, but not limited to, business development companies, commercial paper, certificates of deposits, derivatives, digital assets, equities, exchange-traded funds (“ETFs”) exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships in real estate, oil, and gas, load and no-load mutual funds, options, real estate investment trusts, private placements, bonds (treasury inflation protected/inflation-linked), unit investment trusts, warrants, and non-U.S. securities. RMR typically avoids market timing but will increase cash holdings when necessary. When recommending investments in mutual funds, it is RMR’s policy to consider all available share classes and select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically have a lower cost than other share classes. Generally, institutional class shares do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost. Although RMR provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. (For additional information, see Item 8: Methods Of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Conflicts of Interest Clients should be aware that the specific advisory program selected by the client and the compensation to RMR and their IAR will differ according to the chosen advisory program. The compensation we received can be greater than the amounts otherwise received had the client participated in another program or paid separately for investment advice, brokerage or other relevant services. Due to the differences in fee schedules among the various advisory programs and services offered by RMR and the client’s IAR, a conflict of interest exists when there is a financial incentive to recommend a particular program or service over others. Factors that bear upon the cost of a specific advisory program in relation to the price of the same services purchased separately include, but are not limited to, the type and size of the account, the historical and expected size or number of trades for the account, and the number and range of supplementary advisory and client-related services provided to the account. Clients are under no obligation to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through RMR or any recommended third party. The client may act on recommendations received by placing their business and securities transactions with any brokerage of their choice. RMR does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how RMR mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). RMR's Code is available for review free of charge to any client or prospective client upon request. If you have questions regarding this Brochure’s content or any RMR Agreement, document, statement, or other firm material received from us or do not understand an explanation, please ask your IAR or contact our Compliance Department at 201-836- 2460 for assistance. Assets Under Management As of December 31, 2023, RMR’s assets under continuous management total $1,695,730,206. The following represents client assets under management by account type: Account Type Assets Under Management Discretionary $ 1,447,964,680 Non-Discretionary $ 247,765,526 Total $ 1,695,730,206