A. Firm Description RBF Capital Management, Inc. (“RBF” or the “Firm”) is a privately held company that is registered with the Securities and Exchange Commission as an investment adviser. The Firm is organized as a Georgia Corporation that was founded in 2012. Principal Owners:
• Rafal Baranski is the owner of RBF, holding 100% ownership. Rafal Baranski is also an Investment Adviser Representative of the Firm. B. Types of Advisory Services Portfolio Management Services RBF offers ongoing portfolio management services to Individuals, and high-net worth individuals, businesses, trusts, estates, and charitable organizations. The portfolio management services are based on individual goals, objectives, time horizon, and risk tolerance of each client. RBF creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
• Investment strategy • Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring RBF evaluates the current investments of each client with respect to primarily their risk tolerance levels and time horizon. RBF will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the client's Financial Plan or Individual Risk Tolerance Questionnaire. RBF seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RBF’s economic, investment or other financial interests. To meet its fiduciary obligations, RBF attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RBF's goal to allocate investment opportunities and transactions it identifies as being appropriate and prudent. RBF generally limits its investment advice to mutual funds, fixed-income securities, equities, ETFs (including ETFs in the commodities sector), treasury inflation-protected/inflation- linked bonds, and non-U.S. securities. Financial Planning Services Financial plans and financial planning may include, but are not limited to, investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Fiduciary and Non-Fiduciary for Qualified and Non-qualified Retirement Plan Services a. Plan Sponsor –ERISA (3)(38) Fiduciary Services
• The Firm provides discretionary investment advice to Plan Sponsors about investment alternatives available for the Retirement Plan in accordance with the Retirement Plan’s investment policies and objectives, under which RBF selects and monitors the Retirement Plan’s investment alternatives. RBF has the final decision- making authority regarding the initial selection, retention, and removal of investment options.
• The Firm selects a qualified default investment alternative (“QDIA”) (as defined in U.S. Department of Labor (“DOL”) regulations under ERISA Section 404(c)(5)) for participants who fail to make an investment election.
• RBF generates, in consultation with the Plan Sponsor, an Investment Policy Statement (“IPS”) that establishes the investment policies and objectives for the Retirement Plan, and that sets forth the asset classes and investment categories to be offered under the Retirement Plan, as well as the criteria and standards for selecting and monitoring the investments.
• Risk-Based Models - RBF may provide Risk Based Strategies to a qualified and/or a non-qualified retirement plan. The three Risk Based Strategies (conservative, balanced, and growth) are managed on a discretionary basis using the retirement plans' investment options. b. Plan Sponsor

– ERISA 3(21) Fiduciary Services
• The Firm provides non-discretionary investment advice to Plan Sponsors about investment alternatives available for the Retirement Plan in accordance with the Retirement Plan’s investment policies and objectives, in which we assist in the selection and monitoring of investment alternatives. The Plan Sponsor has the final decision-making authority regarding the initial selection, retention, and removal of investment options.
• The Firm assists in the development of an IPS. The Plan Sponsor has the ultimate responsibility and authority to establish and to adopt the IPS. c. Plan Sponsor – ERISA Non-Fiduciary Services
• The Firm assists with Retirement Plan governance and committee education by reviewing Retirement Plan documents, procedures, participant education and communications (including ERISA 404(c) requirements), and notices to assist in compliance with ERISA regulations and industry best practices.
• The Firm assists Plan Sponsors in the performance of their fiduciary duties by creating an online repository to store and organize key Retirement Plan and fiduciary documents.
• The Firm assists in the education of the Participants about general investing principles and the investment alternatives available under the Retirement Plan in accordance with Department of Labor rules. We will not be acting as an ERISA fiduciary in providing educational services.
• The Firm assists Plan Sponsors with Retirement Plan enrollment through communication campaigns that explain the benefits of the Retirement Plan. We will not be acting as an ERISA fiduciary in providing enrollment support services. The Firm assists Plan Sponsors in selecting and monitoring current providers of recordkeeping, trust, and custodial services to the Retirement Plan, but does not have the final authority to select and replace Retirement Plan service providers.
• The Firm assists Plan Sponsors in designing key provisions of their Retirement Plan, including but not limited to, default enrollment strategies, company match formulas, vesting schedules, and eligibility criteria. d. Plan Participant – ERISA Fiduciary Services
• RBF may provide investment advice to individual Participants through one-on- one consultations. e. Plan Participant – ERISA Non-Fiduciary Services
• RBF educates Participants and eligible employees about various features of the Retirement Plan.
• RBF assists eligible employees with enrollment in their Retirement Plan.
• RBF assists Participants with adjustments in their Retirement Plan deferral rates. C. Wrap Fee Programs RBF does not participate in and is not a sponsor of any Wrap Fee Program(s). D. Written Acknowledgement of Fiduciary Status 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. E. Assets Under Management RBF manages $107,071,947 on a non-discretionary basis and $4, 385,487 on a discretionary basis. This assets under management figure is based on calculations as of April 24, 2024.