RDG CAPITAL MANAGEMENT LLC

20 Office Parkway Suite 140 Pittsford, New York 14534 (585) 673-2690 kkenney@rdgcm.com www.rdgcapitalmanagement.com Form ADV Part 2A Firm Brochure April 14, 2026 This brochure provides information about the qualifications and business practices of RDG Capital Management LLC (“RDGCM” or “firm” or “we”). If you have any questions about the contents of this brochure, please contact us at (585) 673-2611 or kkenney@rdgcm.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Acting as a registered investment adviser does not imply a certain level of skill or training. Additional information about RDG Capital Management LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 Material Changes Item 4: RDG Capital Management LLC has the following material changes to report since its last annual updating amendment: Office Relocation RDG Capital Management LLC has relocated its principal office to: 20 Office Park Way, Suite 140 Pittsford, NY 14534 The firm’s previous principal office address was 10 Winthrop Street, Rochester, NY 14607. Chief Compliance Officer Appointment and Outside Business Activities Update Kate Kenney has been appointed Chief Compliance Officer of RDG Capital Management LLC and serves as an Investment Adviser Representative of the firm. Ms. Kenney has divested her ownership interest in Anderson Kenney Associates, LLC and no longer maintains any affiliation with an insurance agency. As a result, Ms. Kenney no longer engages in insurance-related business activities. Investment Adviser Representative Update Whitney Baniewicz serves as an Investment Adviser Representative of RDG Capital Management LLC. Ms. Baniewicz has divested her ownership interests in RDG & Partners, LLP and Hustle Firm, LLC and no longer maintains any affiliation with those entities. Ms. Baniewicz does not engage in any outside business activities that would create a material conflict of interest with clients of RDG Capital Management LLC. 2  Item 3 Table of Contents Form ADV Part 2A Item 1 Cover Page Item 2 Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-based Fees and Side-by-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies 1 2 3 4 5 6 6 6 and Risk of Loss Item 9 Disciplinary Information Item10 Other Financial Industry Activities and Information Item11 Code of Ethics, Participation, or Interest in Client 9 9 10 Transactions and Personal Trading Investment Discretion Item12 Brokerage Practices Item13 Review of Accounts Item14 Client Referrals and Other Compensation Item15 Custody Item16 Item17 Voting Client Securities Item18 Financial Information 11 11 12 12 12 13 13 Form ADV Part 2B Item19 Brochure Supplement: Kate Kenney, Whitney Baniewicz & Amy Ryan 14 3  Item 4 Advisory Business RDGCM is an SEC-registered investment advisor. All services are provided through a fee-only arrangement that precludes RDGCM from earning income from commissions, referral fees, or any other forms of compensation in connection with advice provided to clients. RDG Capital Management LLC was formed in New York State on December 28, 2023, by Kate Kenney and Whitney Baniewicz and both are owners of the firm. Process RDGCM works with clients to set up investment solutions and provide ongoing portfolio management services. We start by meeting to discuss our philosophy and to gather information about the client’s personal and financial circumstances. Later, we propose what we believe will be an appropriate investment plan, based upon the client’s unique risk tolerance and return objectives. This plan lays out our recommended asset mix among stocks, bonds, cash, and alternative investments. We try to maintain this asset mix through time, rebalancing to meet asset allocation targets as taxes and other constraints allow. Each portfolio is customized to an individual client’s goals and needs. As described in Item 8, clients’ tax circumstances and other personal preferences are factored into how a portfolio is constructed. For example, if a client expresses a preference to hold a certain security, we will adjust our portfolio management strategy accordingly, while informing the client of the potential risks of such a holding. As a registered investment advisor, RDGCM acts as a fiduciary in all aspects of its business, including when recommending the rollover or transfer of retirement accounts. Portfolio Management RDGCM’s core business is the discretionary management of investment portfolios. With a basis in academic research and through our sub advisory relationship with Armbruster Capital Management we pursue the general objectives of broad diversification, risk control, low costs, and tax efficiency in client portfolios. We generally use index or asset class funds. These may take the form of exchange-traded funds (ETFs) or index mutual funds. We use index-based funds because of their broad diversification, low costs, and tax efficiency. Financial Planning RDGCM does not charge additional fees for the financial planning advice it offers. Additionally, we do not sell any products or earn any commissions for products recommended to clients. To discern an appropriate investment plan, it is necessary for us to ask our clients questions about their personal and financial circumstances. Often this information raises financial planning issues that need to be addressed. While we are not Certified Comprehensive Financial Planners (CFP®), RDGCM will discuss these matters with clients and will help align other professional resources if required. For example, we are not able to give 4  tax or legal advice, but we are familiar with many of these issues. We can help identify areas in estate plans, tax strategy, or insurance coverage that could be improved. If the client would like to follow up, we enlist the help of their attorney for legal concerns, and other related parties for tax and estate planning, and insurance products to implement the recommendation. Assets Under Management As of December 31, 2025, RDGCM manages approximately $76.9 million on a discretionary basis and $54.9 million on a non-discretionary basis. Item 5 Fees and Compensation RDGCM is compensated solely based on fees for its services. Assets under management are billed at 0.85% annually. Fees may be waived for employees of RDGCM, their families, and in unique situations. All accounts within a single immediate family relationship may be grouped when calculating fees. Fixed fees may be used depending on individual circumstances. Fees may be negotiable in some cases. RDGCM charges fees on all assets held within managed accounts, including cash. If the cash balance is negative, because of a margin loan, the aggregate value of all other securities will be summed for billing purposes. Fees are generally deducted directly from client accounts, but clients can request an invoice and pay via check. We will accommodate any reasonable client request regarding method of billing. Accounts are billed monthly in arrears. The fees we charge are the only fees that accrue to RDGCM. However, there are other costs implicit in the investment process. These include mutual fund management fees, alternative investment purchasing and custody fees, and trading commissions paid to the custodial firm. Other Costs We strive to keep investment-related costs low wherever possible, but all ETFs and mutual funds have management fees. These fees will vary depending on the specific investment plan recommended for each client, but generally they average around 0.10% for traditional portfolios (such as stocks and bonds) and 0.40% for portfolios that include specialty investments (such as commodities, currencies, and private real estate funds). For accounts holding mutual funds, RDGCM only uses “no load” mutual funds that do not charge distribution fees. Specific fees for each of the funds used are described in the fund’s prospectus, which is available to clients from the fund company or by request from RDGCM. The primary custodial firm we use is Charles Schwab and they do not charge explicit custodial fees. However, clients may be charged trading commissions by these custodians when we execute trades in their 5  accounts. Trading commissions are minimized by keeping trading activity to a minimum, and by selecting custodians with low commission rates. Please see Item 12 of this brochure for more information about brokerage fees. All costs are exclusive of and in addition to RDGCM’s fee. RDGCM does not receive any portion of these commissions, fees, or costs. RDGCM does not accept compensation for the sale of securities or other investment products. Item 6 Performance-Based Fees and Side-by-Side Management RDGCM does not manage any portfolios with performance-based fees. Item 7 Types of Clients Our firm offers advisory services to high-net-worth individuals, pension and profit-sharing plans, employer sponsored retirement plans, trusts, estates, charitable organizations, corporations, and other business entities. Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss RDGCM employs long-term, buy-and-hold strategies to gain exposure to the returns of the various segments of the global investment markets. We rebalance when needed to ensure each client’s risk and return profile remains in line with what has been agreed upon. We review the statistical properties of many different asset classes to help us determine which may be appropriate for client accounts. This includes looking at historical return, standard deviation (a measure of risk or volatility), and the correlation of each asset class compared with the other asset classes included in client portfolios. This allows us to get a sense of whether the asset class has a positive expected return, how much risk we will have to take to earn those returns, and whether the returns are complimentary to the returns of other portfolio holdings. Next, we figure out how best to allocate capital among these asset classes for each individual client. This process means looking at a client’s personal income, time horizon, goals and objectives for their money, risk preferences and ability to take risk, and current cash needs. We then construct a customized portfolio based on a combination of the client’s financial profile and our statistical analysis of asset class risk and return characteristics. 6  Portfolio Strategies Once we arrive at the desired asset allocation plan, we need to select which investments to use for the implementation of the plan. Our preferred approach is to invest a client’s portfolio using a “core and satellite” approach. This includes a core of pure index funds and a satellite portfolio of factor-based funds. This type of portfolio will capture the returns of many different segments of the capital markets, including the various sub-segments of the domestic and foreign stock, bond, real estate, and alternative investment markets. However, it is not unusual for clients to fund their accounts through the in-kind transfer of stocks, bonds, mutual funds, and other securities. Frequently we are not able to sell these investments because of adverse tax consequences. For example, a client may bring an account to RDGCM that holds several stocks with low-cost basis in a taxable account. If we believe the risk of holding the individual stocks is outweighed by the taxes to be paid by selling these stocks, we will hold them for clients and build an asset allocation plan around them. Additionally, we may purchase individual bonds to control risk in client portfolios. In other instances, clients would like to keep a portion of their portfolio in individual securities for personal reasons. Either way, under a hybrid approach, we will complement individual securities with highly diversified, index-based ETFs and mutual funds. We review each account regularly to ensure adherence to the client’s risk tolerance, return objectives, and unique preferences. Security Selection For each portfolio using mutual funds or ETFs, we select funds that invest efficiently in our target asset classes. We look at the legal structure of the investment funds, how well the funds track to the asset class they represent, their fees, and how efficiently they trade in the market. The legal structure of the fund, such as whether it is an open-end mutual fund, unit investment trust, grantor trust, LLC, or something else, can have an impact on how returns are generated. Additionally, some funds do a good job of tracking their index or asset class, while others can deviate significantly from their targets. We want to make sure the funds we use are tracking closely with their underlying market benchmarks, so we compare the funds’ actual returns with the returns of their market benchmark to see if the funds are successfully carrying out their mission. Fees discussed above in Item 5, can also vary meaningfully from fund to fund, and that will have an impact on expected return. Finally, we want to make sure the funds we use trade efficiently and do not incur undue market frictions such as wide bid/ask spreads. By focusing our analytical effort on these issues, we believe we can help our clients keep a portion of their returns that might otherwise be lost to financial intermediaries. Most investments we purchase are designed to be held for a long period of time. For these sorts of investments, we are not overly concerned with short-term market fluctuations. Rather, we want to capture the long-term returns of the market in a sensible, risk-controlled way. We accomplish this through disciplined portfolio construction. In some cases, we will purchase securities designed to be held for a 7  period of five years or less. These securities are usually either short duration individual fixed income securities, as part of a laddered bond portfolio, or short duration, high quality fixed income mutual funds. The purpose of holding these securities will be to limit short-term fluctuations in a portion of a portfolio to accommodate either short-term cash needs or risk aversion. Risks Involved The major risk involved with our mutual fund and ETF positions is systematic risk, or the risk that markets decline in value. For example, a major pullback in the domestic stock market would have an adverse impact on our clients until the market recovers. Recoveries can take time and are not guaranteed. This may cause significant loss, especially over the short term. Rising interest rates, inflation, or a declining stock market are examples of this type of risk. Clients who own individual stock or corporate debt securities in their accounts will also face idiosyncratic or security-specific risks. This is a risk that is limited to a specific company or industry. For example, an oil spill by a major oil company could affect clients who own stock in that oil company. With individual securities, the prospect of permanent loss of capital is always present. While we try to limit or even eliminate idiosyncratic risk through diversification, there is no guarantee that this risk will not cause losses in a portfolio consisting of individual securities. Clients who own international securities, either through individual equities or through ETFs and mutual funds, will face another set of risks. First, foreign securities are exposed to different market conditions than U.S. securities, and the price of these securities can change quickly because of economic, political, or regulatory conditions. Furthermore, markets for foreign securities can be smaller and more tumultuous than markets for U.S. securities, leading to rapid changes in price. During any period when foreign securities underperform domestic securities, the performance of a client’s overall investment portfolio may lag broad market benchmarks. Moreover, there may be additional fees to holding international investments, through extra brokerage, tax, and custody costs. Currency risk can also create price fluctuations for owners of international securities, as well as for investors in funds that invest directly in foreign-currency strategies, which we have used in the past and may use in the future. We try to limit these risks by investing in international securities primarily through ETFs and mutual funds, but the risks are always present for those wishing to gain exposure to international markets. Some of the mutual funds we buy make use of derivative securities, creating derivatives risk. Derivative securities present to varying degrees, market risk that the performance of the underlying assets, interest rates or indices will decline; credit risk that the dealer or other counterparty to the transaction will fail to pay its obligations; and high volatility because of the use of leverage. Much of this risk is mitigated by the fact that these securities are not held directly by clients, and that any derivatives used by these mutual funds are both liquid and marked-to-market daily. Nevertheless, derivatives could result in unexpected losses in client portfolios. For clients who own bonds, there is credit risk. Non-government bonds face the risk of downgrade, default, or widening credit spreads that could adversely impact the price of the security. Bonds, both individually 8  and through mutual fund vehicles, are also exposed to interest rate risk, the risk that bond prices can fluctuate as interest rates increase or decrease. During periods when interest rates are low or expected to increase, current yields and total returns for fixed income investors may also be low. Moreover, clients who own mortgage-backed securities, either through individual securities or a mutual fund, face prepayment risk that could negatively affect the price of the investment. RDGCM sometimes uses funds that do not trade daily. Some mutual funds, for example in our alternative investment portfolio, have quarterly or less frequent redemption dates. These securities are priced daily. However, clients may not be able to immediately liquidate their positions and receive cash and therefore are subject to liquidity risk. This risk consists of the lack of marketability of an investment that cannot be sold quickly enough to prevent or minimize a loss. Some of the alternative funds we use also employ “gates”, which may prevent sales of the funds by investors for periods longer than regularly published liquidity dates. This can happen when too many investors want to redeem their shares at the same time, and the fund sponsor limits the amount of redemptions. We mitigate liquidity risk by limiting these types of securities to small parts of a client’s portfolio. Another risk our clients face is the risk of any fund failing to execute on its strategy. Most of the funds we use are passive index funds, but some of the alternative investments we use are more actively managed. These funds may not be successful at carrying out their investment strategy, and this could result in investment losses. Clients should understand that investing in any securities, including ETFs and mutual funds, involves a risk of loss of both income and principal. Before investing, clients should understand and be prepared to bear these risks. Item 9 Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of RDGCM or the integrity of RDGCM’s management. Neither RDGCM, nor any of its employees, has reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Armbruster Capital Management, Inc. is the subadvisor for RDGCM. RDGCM has retained ACM as the sub-adviser to perform investment management and related administrative services, provided that the Sub- Adviser is duly registered with the Securities and Exchange Commission. This means that ACM will be the discretionary investment manager to supervise and direct the investment of the client’s accounts in accordance with the terms of the Investment Management Agreement (IMA) and the Investment Policy Statement (IPS). RDGCM will provide ACM with an IPS for each client and update ACM if there are any 9  changes needed to the IPS. RDGCM will monitor and supervise that ACM is managing client portfolios appropriately and according to the IPS. ACM shares part of the client fees to provide these services. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As an SEC-registered investment advisor, RDGCM maintains a code of ethics outlining acceptable standards of professional conduct. This code of ethics describes RDGCM’s high standard of business conduct and fiduciary duty to clients. A copy of this document can be provided to any client or prospective client upon request. RDGCM employees may purchase securities for their personal accounts that they recommend to clients. While we believe it makes sense for us to want to invest the same way as our clients, this could present a conflict of interest. For example, if RDGCM executes trades in personal accounts before client accounts, we could effectively “front run” our clients and benefit personally (or cause disadvantage to clients) from the subsequent buying we do in client accounts. We believe there are significant safeguards to prevent this. In general, we try to make trades in personal accounts only after trades have been made in the same securities for client accounts, and we do not take positions on the opposite side of our clients’ positions (for example, we will not short a security in a personal account when a client has a long position in that security). Nevertheless, all personal transactions in individual securities will be reviewed by the Chief Compliance Officer (CCO) and/or the Managing Partner on a case-by-case basis. In their review, the CCO and/or the Managing Partner will ensure that these trades in individual securities do not cause harm to or disadvantage clients. There is a significant section of RDGCM’s policies and procedures manual that describes the firm’s trading policy and prohibits employees from trading ahead of clients. Additionally, we typically invest in mutual funds, ETFs, and individual securities that are very large and liquid. It is unlikely that anyone at RDGCM will be able to do trades large enough to impact the market price of any of these securities. Also, open-ended mutual funds trade at their net asset value, so their valuations will not be impacted by trading activity. RDGCM maintains a restricted list of companies where RDGCM employees may have access to inside information. RDGCM employees are not allowed to trade these securities for their personal accounts or for client accounts without approval from the restricted company’s legal department unless the trade was directed by the client (who does not have insider information) and no advice or insider information was shared with the client. In such cases of client directed trades, the trade will be executed by the subadvisor so long as they do not have the insider information. Item 12 Brokerage Practices RDGCM requires clients to establish brokerage and custody accounts with Charles Schwab, which is a registered broker-dealer, and member of SIPC. The basis of this decision is the strength of the firm, efficiency of trade execution, commission rates, ability to hold a diverse range of securities, client service, 10  and the ability to interface with our portfolio management system. Commission rates are compared with other large industry providers to ensure our clients receive competitive rates for the size and frequency of trading. Research provided by custodial firms is not a significant consideration in our decision to use their services. RDGCM does not participate in any “soft dollar” arrangements where commissions are rebated back to us in the form of research services. Apart from some individual bond trades, almost all trading is done with the custodial firm to avoid “trade away” fees. RDGCM may aggregate trades or engage in block trading. Each client account has a unique asset allocation plan and is therefore managed individually. However, it is common for two or more clients on the same day to have trades made that are of the same security and trade direction (buy or sell). If these trades are to be executed at the same time, RDGCM will aggregate the trades into a “block” at each custodian and execute one trade through a block account. The block trade is then allocated on the same day as execution to each client account according to their individual modeled trade amounts. When this allocation occurs, each client receives the exact same execution price. This ensures that no client is placed at an advantage or disadvantage over another when it comes to realized trade values. Item 13 Review of Accounts Client accounts are reviewed by the firm’s Portfolio Management Team, which is managed by Armbruster Capital Management, Inc. on a regular basis. RDGCM receives daily downloads of client transactions from its custodians. Any material day-to-day changes, such as cash inflows and outflows, are acted upon as they are identified. We recommend that most clients meet with us on a regular basis to review performance, asset allocation, and any material changes in the clients’ personal or financial circumstances. At these meetings, we provide written reports on performance, asset allocation versus targets, holdings, realized gains and losses, and others as appropriate. RDGCM agrees to provide the Subadvisor with prompt written notice of any modifications, changes, or investment restrictions applicable to client accounts. RDGCM will notify the Subadvisor in writing if RDGCM believes that any investments recommended or invested in client accounts are in violation of the investment objectives, restrictions, or the Investment Policy Statement. Clients receive a quarterly newsletter with an account statement, statement of account performance, and a report of their asset allocation versus established targets. Other, more detailed reports are available directly from RDGCM by request or electronically via internet portals set up for each client. 11  Item 14 Client Referrals and Other Compensation RDGCM does not receive remuneration from outside parties for client referrals, nor does RDGCM directly or indirectly compensate any person who is not a supervised person for client referrals. Item 15 Custody Custodial firms are generally bank or brokerage firms that maintain client accounts and physically hold the securities in them. RDGCM generally does not take custody of client accounts; therefore, custodial relationships must be established for all accounts opened with RDGCM. The custodian RDGCM uses, sends statements on a periodic basis, generally monthly, a minimum of quarterly, and provides trade confirmations after trades are executed. These documents are sent to clients directly from the custodial firm, not through RDGCM. RDGCM provides reports of client account holdings that match reports from the custodians. If that is not the case, clients should contact RDGCM immediately. Clients can set up online access to their accounts through the custodians’ websites. We believe this separation of management and custody is an important safeguard for our clients. While RDGCM does not take practical custody of client assets, it is deemed to have legal custody in situations relating to standing instructions on accounts that result in money movement to third parties. These instructions are only set up through signed documentation from account holders and acted upon when the client directs RDGCM to move the money. Item 16 Investment Discretion RDGCM generally has investment discretion on client accounts, except for some employer retirement plans. Clients sign an investment management agreement at the inception of our relationship, giving us the ability to trade their accounts. Additionally, the custodial paperwork specifies limitations clients may place on our discretion, such as whether or not we can draw fees directly from the account and whether or not we will be authorized to request distributions on the client’s behalf. In some cases, clients like to have a more active role in the management of their accounts. While we maintain legal discretion, we are flexible on how we work with clients. We welcome client involvement in the investment process. 12  Item 17 Voting Client Securities RDGCM shall not take any action or render any advice with respect to the voting of proxies. Clients will receive the proxy information directly from their custodian. When assistance on voting proxies is requested, RDGCM will provide recommendations to the client. Item 18 Financial Information Financial information is not required since RDGCM does not bill clients in advance of providing services. 13  Part 2B of Form ADV Brochure Supplement Kate Kenney RDG Capital Management LLC 20 Office Parkway Suite 140 Rochester, New York 14607 (585) 673-2611 aryan@rdgcm.com www.rdgcapitalmanagement.com March 03, 2026 This brochure supplement provides information about Kate Kenney that supplements the RDGCM brochure. You should have received a copy of that brochure. Please contact Kate Kenney, Chief Compliance Officer if you did not receive RDG Capital Management LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Kate Kenney is available on the SEC’s website at www.adviserinfo.sec.gov. 14  Item 2: Educational Background and Business Experience Kate Kenney Year of Birth: 1974 Education Kate Kenney graduated from The State University at Oswego with a bachelor’s degree in accounting and a minor in Economics in 1997. Kate has also successfully passed the following securities examinations: Series 65 and the Life, Accident & Health Agent/Broker exam. Business Background RDG Capital Management LLC, Chief Compliance Officer, 2026 - Present RDG Capital Management LLC, Principal, 2024 - Present Path Advisory LLC, Principal, 2026 - Present 1RDG, Partner, 2025 Anderson Kenney Associates, DBA RDG HR Solutions, Partner, 2020 - 2026 ProNexus LLC, Partner, 2012 – 2020 Randstad, Account Executive, 2006-2012 Alstom Signaling, Project Controller, 2005 – 2006 Element K, Financial Reporting Manager, 1997 - 2005 Item 3 Disciplinary Information Kate Kenney has not been involved in any disciplinary events. Item 4 Other Business Activities Kate Kenney is the Chair of the Child Advocacy Center of Greater Rochester Board (formerly Bivona) and is on the board of FCA Upstate Lacrosse is not compensated for this work. Item 5 Additional Compensation Mrs. Kenney does not receive any additional compensation, beyond her salary and shareholder distributions, for providing investment advisory services. Item 6 Supervision Mrs. Kenney is the Chief Compliance Officer of RDG Capital Management LLC and can be reached at 585.673.2611. She is the representative of the firm and supervises all activities. RDG Capital Management LLC has implemented a Code of Ethics, an internal compliance document that guides each supervised person in meeting their fiduciary obligations to clients of RDG Capital Management LLC. Further, RDG Capital Management LLC is subject to regulatory oversight by various agencies. RDGCM is subject to examinations by regulators. Kate Kenney is also bound by all securities laws. 15  Whitney Baniewicz RDG Capital Management LLC 20 Office Parkway Suite 140 Rochester, New York 14607 (585) 206-2782 wbaniewicz@rdgcm.com www.rdgcapitalmanagement.com March 03, 2026 This brochure supplement provides information about Whitney Baniewicz that supplements the RDGCM brochure. You should have received a copy of that brochure. Please contact Kate Kenney, Chief Compliance Officer if you have not received RDG Capital Management LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Whitney Baniewicz is available on the SEC’s website at www.adviserinfo.sec.gov. 16  Item 2: Educational Background and Business Experience Whitney Baniewicz Year of Birth: 1982 Education Whitney Baniewicz graduated from University of Tennessee with a bachelor’s degree in 2006 with degrees in Accounting and Business Management. Whitney has also successfully passed the Certified Public Accounting Exam and securities examination Series 65. Business Background RDG Capital Management LLC, Principal 2024-Present RDG & Partners, CPA (previously RDHB CPA, and Rizzo DiGiacco CPA), Partner, 2012-2025 W.L.Baniewicz, CPA, Owner 2010-2012 Ross & Baniewicz, CPA 2010-2012 Gerald D. Ross, CPA PC, 2006-2010 Item 3 Disciplinary Information Whitney Baniewicz has not been involved in any disciplinary events. Item 4 Other Business Activities Whitney Baniewicz also serves as a board member for the Mary Cariola Agency and The Charles Finney School, she is not compensated for this work. Item 5 Additional Compensation Mrs. Baniewicz does not receive any additional compensation, beyond her salary and shareholder distributions, for providing investment advisory services. Item 6 Supervision Mrs. Baniewicz’s professional activities are monitored by the Chief Compliance Officer, and she must adhere to all securities laws, and RDG Capital Management LLC’s internal code of ethics. RDG Capital Management LLC has implemented a Code of Ethics, an internal compliance document that guides each supervised person in meeting their fiduciary obligations to clients of RDG Capital Management LLC. Further, RDG Capital Management LLC is subject to regulatory oversight by various agencies. RDGCM is subject to examinations by regulators. 17  Part 2B of Form ADV Brochure Supplement Amy Ryan RDG Capital Management LLC 20 Office Parkway Suite 140 Rochester, New York 14607 (585) 673-2683 aryan@rdgcm.com www.rdgcapitalmanagement.com March 03, 2026 This brochure supplement provides information about Amy Ryan that supplements the RDGCM brochure. You should have received a copy of that brochure. Please contact Kate Kenney, Chief Compliance Officer if you did not receive RDG Capital Management LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Amy Ryan is available on the SEC’s website at www.adviserinfo.sec.gov. 18  Amy Ryan Year of Birth: 1973 Education Amy Ryan graduated from Niagara University with a bachelor’s degree in 1995. Amy completed her master’s degree at Nazareth College in 1998. Amy has also successfully passed the following securities examinations: Series 6, Series 7, Series 22, Series 65, Series 66 and the SIE exam. Business Background RDG Capital Management LLC,Vice President, 2024-Present RDG Wealth Management, Vice President, 2023-2024 Halleran Financial Group, Vice President, 2016 - 2022 POST Magazine, Director of Sales, 2013 – 2016 Halleran Financial Group, Vice President, 2003 – 2013 Pittsford Capital Markets, Operations, 1998 – 2003 Item 3 Disciplinary Information Amy Ryan has not been involved in any disciplinary events. Item 4 Other Business Activities Amy Ryan also serves as a board member for various organizations, she is not compensated for this work. Item 5 Additional Compensation In addition to her salary, Mrs. Ryan may receive additional compensation or bonuses based on business development or client assets she services. Item 6 Supervision Mrs. Ryan’s professional activities are monitored by the Chief Compliance Officer, and she must adhere to all securities laws, and RDG Capital Management LLC’s internal code of ethics. RDG Capital Management LLC has implemented a Code of Ethics, an internal compliance document that guides each supervised person in meeting their fiduciary obligations to clients of RDG Capital Management LLC. Further, RDG Capital Management LLC is subject to regulatory oversight by various agencies. RDGCM is subject to examinations by regulators. 19