RETIREMENT FINANCIAL SOLUTIONS, LLC

Form ADV Part 2A: Firm Brochure Item 1 – Cover Page Great Valley Asset Management, LLC 9725 Cogdill Road, Suite 201 Knoxville, Tennessee 37932 865-392-4260 www.greatvalleyassetmanagement.com Date of Disclosure Brochure: November 2024 ____________________________________________________________________________________ This disclosure brochure provides information about the qualifications and business practices of Great Valley Asset Management (also referred to as Great Valley, “GVAM”, “we” and “us” throughout this disclosure brochure). Great Valley Asset Management provides investment advisory services through Retirement Financial Solutions, LLC (also referred to as RFS). If you have any questions about the contents of this disclosure brochure, please contact Bradley Fugate at 865-392-4260. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Retirement Financial Solutions, LLC is also available on the Internet at www.adviserinfo.sec.gov. You can search this website by unique identifying number, known as CRD number. The CRD number for Retirement Financial Solutions, LLC is 285347. Retirement Financial Solutions, LLC is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. Great Valley Asset Management Page 1 Form ADV Part 2A: Firm Brochure  Item 2 – Material Changes This page will discuss the material changes made to the Great Valley Asset Management Form ADV Part 2A (“Brochure”). This is GVAM’s initial Disclosure brochure so there are no changes to list here. We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time, we will also offer or provide a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. Great Valley Asset Management Page 2 Form ADV Part 2A: Firm Brochure  Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Introduction................................................................................................................................................ 4 Description of Advisory Services .............................................................................................................. 4 Retirement Plan Rollover Recommendations ........................................... Error! Bookmark not defined. Limits Advice to Certain Types of Investments ......................................... Error! Bookmark not defined. Tailor Advisory Services to Individual Needs of Clients ............................ Error! Bookmark not defined. Client Assets Managed by Great Valley Asset Management ................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 5 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 5 Item 7 – Types of Clients .............................................................................................................................. 5 Minimum Investment Amounts Required .................................................. Error! Bookmark not defined. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 5 Methods of Analysis .................................................................................................................................. 5 Investment Strategies ............................................................................................................................... 6 Risk of Loss ............................................................................................................................................... 7 Item 9 – Disciplinary Information ................................................................................................................... 8 Item 10 – Other Financial Industry Activities and Affiliations ........................................................................ 8 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ................................. 9 Code of Ethics Summary .......................................................................................................................... 9 Affiliate and Employee Personal Securities Transactions Disclosure ...................................................... 9 Item 12 – Brokerage Practices ...................................................................................................................... 9 Directed Brokerage ................................................................................... Error! Bookmark not defined. Block Trading Policy .................................................................................. Error! Bookmark not defined. Item 13 – Review of Accounts..................................................................................................................... 10 Account Reviews and Reviewers ............................................................................................................ 10 Statements and Reports ........................................................................... Error! Bookmark not defined. Item 14 – Client Referrals and Other Compensation .................................................................................. 10 Item 15 – Custody ....................................................................................................................................... 10 Item 16 – Investment Discretion ................................................................................................................. 10 Item 17 – Voting Client Securities ............................................................................................................... 10 Item 18 – Financial Information ................................................................................................................... 10 Great Valley Asset Management Page 3 Form ADV Part 2A: Firm Brochure  Item 4 – Advisory Business Great Valley Asset Management and Blue Ridge Wealth Planners are d.b.a’s of Retirement Financial Solutions, LLC. Retirement Financial Solutions, LLC (referred to as RFS) is an SEC registered Investment Adviser, located in Knoxville, Tennessee. Blue Ridge Wealth Planners is the d.b.a. used for asset management services. Great Valley Asset Management is the d.b.a. used for Model Delivery services. For the purposes of this document, Blue Ridge Wealth Planners (or “BRWP”) will be used when referring to asset management services, and Great Valley Asset Management will be used when referring to model delivery services. Introduction Great Valley Asset Management provides advisory services to other investment advisory firms (these firms are referred to in this brochure as “Investment Advisory Firms” or “Firms” and their representatives are referred to as the “Financial Advisors” or “Advisor”) through a sub-advisory relationship. Representatives of third-party investment adviser firms consult with their clients to assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet the Client’s financial needs. In order to participate, clients and the Investment Advisory Firm will enter into an Investment Advisory Agreement (“IAA”) or other advisory agreement that outlines the services to be performed by the Investment Advisory Firm, the authority of the Investment Advisory Firm, the compensation payable by the Client, and other important provisions governing participation in the Platform. The Investment Advisory Firm evaluates the client’s investment needs and objectives, and is responsible for determining the suitability of various models for the Client’s investment objectives and financial condition. The Investment Advisory Firm, through its Financial Advisor, not GVAM, recommends the Strategy to the Client and monitors whether to recommend that the Client remain in the selected Strategy. Description of Advisory Services GVAM participates in a Model Delivery program, where Investment Advisory Firms are able to access GVAM created models on various custodial platforms or TAMPs. While GVAM makes investment decisions within the models, GVAM does not exercise investment discretion or trade client accounts. The Investment Advisory Firm is responsible for determining the timing of transactions, execution venue, and other trade execution decisions. GVAM's sub-advisory services also includes the following, as applicable: • Creation of Model Portfolios • Monitor performance of Model Portfolios; • Creation of Fact Sheets Client Assets Managed by Great Valley Asset Management As of December 31, 2024, Great Valley Asset Management had $201,231,521 in discretionary assets under management and $0 in non-discretionary assets under management. Great Valley Asset Management Page 4 Form ADV Part 2A: Firm Brochure  Item 5 – Fees and Compensation GVAM is compensated by the Investment Advisory Firm, with a portion of the fee paid by the Advisors client, in accordance to their fee schedule. GVAM enters into a contract with the Advisory Firm, not the client. The exact fees and other terms will be outlined in the agreement between GVAM and the Firm. All fees paid to GVAM are separate and distinct from certain charges imposed directly by third parties. Such charges include, but are not limited to, custodial fees, charges imposed directly by an ETF in the account, which shall be disclosed in the fund's prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, short-term redemption fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s Account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. Item 7 – Types of Clients GVAM clients are comprised of Investment Advisory and Brokerage firms. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Great Valley Asset Management uses the following methods of analysis in developing models and evaluating performance: Charting - This is a set of techniques used in technical analysis in which charts are used to plot price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users of these techniques, called chartists, believe that past trends in these indicators can be used to extrapolate future trends. Charting is likely the most subjective analysis of all investment methods since it relies on proper interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of Great Valley Asset Management Page 5 Form ADV Part 2A: Firm Brochure  performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future trading volume is unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. Investment Strategies Great Valley Asset Management utilizes the following strategies when developing models and evaluating performance: Long term purchases. Investments held at least a year. Short term purchases. Investments sold within a year. Value Investing. Value Investing can be described as a strategy of selecting stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, Great Valley Asset Management Page 6 Form ADV Part 2A: Firm Brochure  resulting in stock price movements that do not correspond with the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to- earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e., businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Investment Model Strategies. Great Valley Asset Management has created proprietary Model Portfolios. Based on the information you provide us, we consider multiple time horizons (long, medium and short-term) when determining investment strategies. Depending on our clients’ needs, we may recommend one or several of our investment management models. In the development and management of our Model Portfolios, Great Valley Asset Management uses industry standard techniques that include technical analysis, fundamental analysis and charting. We may engage various types of execution tactics such as long term and short-term buys and value investing as well as asset allocation strategies to achieve the Model Portfolios’ objectives. Each model engages in its own type of techniques, execution tactics and use of research tools to enhance the ability to manage its assets effectively to its stated philosophy. Great Valley Asset Management actively manages each model’s investment objective, driven by its investment philosophy and style. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that the future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: Great Valley Asset Management Page 7 Form ADV Part 2A: Firm Brochure  • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as an unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Item 9 – Disciplinary Information Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or integrity. Item 10 – Other Financial Industry Activities and Affiliations Great Valley Asset Management is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an Accountant or Great Valley Asset Management Page 8 Form ADV Part 2A: Firm Brochure  Accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. Great Valley Asset Management is a d.b.a. under SEC registered investment adviser Retirement Financial Solutions, LLC. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Great Valley Asset Management has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. Great Valley Asset Management’ Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Great Valley Asset Management requires its supervised persons to consistently act in your best interest in all advisory activities. Great Valley Asset Management imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Great Valley Asset Management. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Great Valley Asset Management or supervised persons of the firm can buy or sell for their personal accounts investments identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Great Valley Asset Management that all persons supervised in any manner by our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, Great Valley Asset Management and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, supervised persons). Any supervised person not observing our policies is subject to sanctions up to and including termination. Item 12 – Brokerage Practices Since Great Valley Asset Management does not trade client accounts, GVAM is not involved in directing brokerage practices. Advisors access GVAM Model Portfolios on the available platforms, and execute the model strategy utilizing the custodian/brokerage of their choosing. Great Valley Asset Management Page 9 Form ADV Part 2A: Firm Brochure  Item 13 – Review of Models Because GVAM does not trade client accounts, Account Review is the responsibility of the Firms Advisor on the account. GVAM reviews the performance of each model on a quarterly basis. The model review includes a quarterly overview with our Investment Committee, generally consisting of all members of GVAM, as well as a review of each individual holding within the models. Significant market events affecting the prices of one or more securities in a Model Portfolio or changes in the investment objectives or guidelines of a particular client may trigger the review of such Model Portfolio on a more than periodic basis. Item 14 – Client Referrals and Other Compensation Great Valley Asset Management does not directly or indirectly compensate any person for client referrals. Item 15 – Custody Custody, as it applies to investment advisors, has been defined by regulators as having access to or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. GVAM does not have custody, as we do not trade client accounts, or have access to client funds within our models. GVAM models are provided to platforms for advisors to utilize at their discretion, without Great Valley Asset Management involvement. Item 16 – Investment Discretion GVAM makes investment decisions within the models, however does not exercise investment discretion or trade client accounts. Item 17 – Voting Client Securities Great Valley Asset Management does not vote proxies on behalf of Clients. . Item 18 – Financial Information This Item 18 is not applicable to this brochure. Great Valley Asset Management does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, Great Valley Asset Management has not been the subject of a bankruptcy petition at any time. Great Valley Asset Management Page 10 Form ADV Part 2A: Firm Brochure