Rf&l Wealth Management, LLC

Item 1 – Cover Page RF&L Wealth Management, LLC 525 Massachusetts Avenue, Suite 205 Acton, MA 01720 (978) 263-3435 August 11, 2026 www.rflwealth.com This Brochure provides information about the qualifications and business practices of RF&L Wealth Management, LLC (“RF&L”). If you have any questions about the contents of this Brochure, please contact us at (978) 263-3435. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. RF&L is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. information about RF&L also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for RF&L is 140210. i  Item 2 -Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since the last annual update and provide clients with a summary of such changes. This other than annual updating amendment reflects minor revisions to disclosure language and the updated legal name of Focus Advisor Solutions. Our last annual updating amendment filing included the following changes: • Added language to disclose the use of AQR as an Independent Manager in Item 4 and Item 5; • Assets Under Management information was updated within Item 4. (Brochure Date: 08/11/2026) (Date of Most Recent Annual Updating Amendment: 03/10/2026) We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Andrew Hass, Chief Compliance Officer at (978) 263-3435. Additional information about RF&L is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with RF&L who are registered, or are required to be registered, as investment adviser representatives of RF&L. ii  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 Item 5 – Fees and Compensation ................................................................................................................................................................. 5 Item 6 – Performance-Based Fees and Side-By-Side Management............................................................................................ 7 Item 7 – Types of Clients ................................................................................................................................................................................. 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................... 8 Item 9 – Disciplinary Information............................................................................................................................................................ 10 Item 10 – Other Financial Industry Activities and Affiliations .................................................................................................. 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 10 Item 12 – Brokerage Practices ................................................................................................................................................................... 11 Item 13 – Review of Accounts .................................................................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation ...................................................................................................................... 13 Item 15 – Custody ............................................................................................................................................................................................ 14 Item 16 – Investment Discretion .............................................................................................................................................................. 14 Item 17 – Voting Client Securities ............................................................................................................................................................ 14 Item 18 – Financial Information ............................................................................................................................................................... 15 Brochure Supplements (provided to clients) iii  Item 4 – Advisory Business RF&L has been providing advisory services since 2006. As of January 1, 2022, RF&L is owned by Andrew Hass and Ryan Hass. As of December 31, 2025, RF&L managed $352,398,448 on a discretionary basis, $28,686,857 on a nondiscretionary basis and advised on $9,927,121 of self-directed retirement account assets. Investment Management Services RF&L will work with the client to determine the client's investment objectives and investor risk tolerance and will design a written investment policy statement. RF&L may use investment and portfolio allocation software to evaluate alternative portfolio designs. RF&L evaluates the client's existing investments with respect to the client's investment policy statement. RF&L works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by RF&L. RF&L will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. RF&L will typically create a portfolio of passive and/or evidence-based mutual funds and/or Exchange Traded Funds (ETFs) and can use model portfolios if the models match the client’s investment policy. RF&L will allocate the client’s assets among various investments taking into consideration the overall risk tolerance. The mutual funds and ETFs recommended generally follow a passive asset class investment philosophy with low holdings turnover. Client portfolios can also include some individual equity securities. RF&L manages portfolios on a discretionary or non-discretionary basis. A client may impose reasonable restrictions on RF&L’s discretionary authority, including restrictions on the types of securities in which RF&L may invest client’s assets and on specific securities that the client may believe to be appropriate. RF&L can also recommend fixed income portfolios to advisory clients, which consist of fixed income funds or individual fixed income securities. RF&L will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, RF&L can retain a third-party independent manager (“Independent Manager”) to manage portions or all of the account assets. RF&L utilizes Focus Advisor Solutions (“FAS”) as its fixed income securities manager. The fixed income Independent Manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Investment Policy Statement. The Independent Manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The Independent Manager will obtain RF&L’s consent prior to the sale of any client securities.  Additionally, in certain circumstances, as determined by RF&L and the client, RF&L can engage AQR Capital Management, LLC (“AQR”) as an Independent Manager to manage portfolios of individual securities for clients. In these instances, AQR’s sub-advisory fees are separate, distinct, and in addition to RF&L’s advisory fees. On an ongoing basis, RF&L will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. RF&L will periodically, and at least annually, review client’s investment policy, risk tolerance and evaluate the re- balancing of each client’s accounts to the extent appropriate. RF&L will communicate to all Independent Managers any updated client financial information or account restrictions. Participant-Directed Retirement Account Services RF&L also offers advisory services to participant-directed retirement plans. RF&L will analyze the plan's current investment platform and assist the plan sponsor or trustee in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. RF&L will recommend investment options to achieve the plan's objectives, offer to provide participant education meetings, and monitor the performance of the plan’s investment vehicles. RF&L will recommend changes in the plan's investment vehicles as may be appropriate from time to time. RF&L generally will review the plan's investment vehicles and investment policy as necessary. Item 5 – Fees and Compensation Investment Management Services The annual fee for investment management services will be charged as a percentage of the clients’ assets under management, according to the schedule below: Range of Assets Annual Fee (%) Up to $200,000 1.25% $200,001 to $1,000,000 1.00% $1,000,001 to $2,500,000 0.90% $2,500,001 or greater 0.80% (This is a blended fee schedule in which assets within each range are charged the corresponding fees represented in the table.) For 529 College Savings Accounts, RF&L charges a flat rate fee of 0.50% per annum for the management of these assets. In very limited circumstances, RF&L can charge a fixed fee if mutually agreed upon.  Independent Manager Fees As stated above in Item 4, RF&L (in coordination with the client) may decide to implement AQR as an Independent Manager for the management of portfolios of individual securities. In these instances, AQR will charge its own separate and distinct fee from RF&L’s advisory fees, which are noted above. Clients grant AQR authority at the client’s custodian for AQR to directly debit client accounts for AQR’s fee. Additionally, clients are required to sign an advisory agreement addendum with RF&L which outlines these additional fees. Participant-Directed Retirement Account Services The annual fee for plan services will generally be 0.80% of assets within the plan. Additional Information In certain circumstances, all fees and account minimums may be negotiable. Fees may vary based on individual or family relations or may be negotiated for members of an organized affinity or industry groups. Individual accounts for members of the same family can be assessed fees based on the total account balance of all family accounts. Accounts for business entities and related accounts, including those of the business owner are assessed fees based on the total account balances of all such related accounts. RF&L has contracted with FAS for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. RF&L has also contracted with FAS for sub-advisory services with respect to clients’ fixed income accounts. RF&L pays a fee for FAS’ services based on management fees paid to RF&L on accounts administered through FAS. The fee paid by RF&L to FAS consists of a portion of the fee paid by clients to RF&L and varies based on the total client assets participating in FAS’ solutions through RF&L. These fees are not separately charged to advisory clients. For separately managed accounts, the Independent Manager will charge the client its own fee for services, which is in addition to RF&L’s fees. Advisory fees are billed quarterly in advance and are deducted directly from client accounts at the beginning of each calendar quarter. Fees are calculated based on the value of the client's account as of the last valuation date of the preceding calendar quarter, which is generally the last day of the quarter. Account values are determined using market values obtained from independent third-party sources or, where market values are unavailable, fair market value. The account values used to calculate advisory fees may differ from those reflected on custodial statements due to independent asset valuations and other accounting adjustments, including the treatment of accrued interest. RF&L will request authority from the client to receive quarterly payments directly from the client’s account held by an independent custodian. Clients will provide written limited authorization to RF&L or its designated service provider, FAS, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s).  For the retirement plan clients, certain third-party administrators will calculate and debit RF&L’s fee and remit such fee to RF&L. All fees paid to RF&L for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds/ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and possibly a distribution fee. A client could invest in mutual funds/ETFs directly without the services of RF&L. In that case, the client would not receive the services provided by RF&L which are designed, among other things, to assist the client in determining which ETFs/mutual fund are most appropriate to each client's financial condition and objectives. Some funds also may not be available to clients directly. Accordingly, the client should review both the fees charged by the funds and the fees charged by RF&L to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. RF&L’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Such charges, fees and commissions are exclusive of and in addition to RF&L’s fee, and RF&L shall not receive any portion of these commissions, fees, and costs. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. Management of the account commences upon the signing of the agreement, unless otherwise agreed. If the agreement commences other than at the beginning of a quarter, a pro rata charge will be made for the initial period the portfolio is under the advisor's management prior to the beginning of a quarter. A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Item 6 – Performance-Based Fees and Side-By-Side Management RF&L does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Item 7 – Types of Clients RF&L manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations, and small businesses. Generally, RF&L will require a minimum account size or client relationship of $250,000 for  Investment Management Services. A separate minimum account size of $500,000, in most instances, is required for fixed income portfolio management services consisting of individual fixed income securities. These minimum account requirements may be waived under certain circumstances. Client accounts, where the total balance of all accounts is less than the required minimum, will be accepted only on a case by case basis. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy RF&L's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. RF&L's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. RF&L recommends diversified portfolios, principally through the use of passively managed, asset class mutual funds and ETFs. RF&L selects or recommends to clients portfolios of securities, principally broadly-traded open end mutual funds and ETFs or conservative fixed income securities to implement this investment strategy. Although all investments involve risk, RF&L's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate for particular clients the investment directly in conservative fixed income securities to represent the fixed income class. RF&L's investment philosophy is designed for investors who desire a buy and hold strategy. Frequent trading of securities may increase brokerage and other transaction costs that RF&L's strategy seeks to minimize. In the implementation of investment plans, RF&L therefore primarily uses mutual funds/ETFs and, as appropriate, portfolios of conservative fixed income securities. Clients may hold or retain other types of assets as well, and RF&L may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. RF&L’s strategies do not utilize securities that we believe would be classified as having any unusual risks, and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. RF&L receives supporting research from FAS and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). RF&L utilizes DFA and other mutual funds in client portfolios. As previously noted, mutual funds and ETFs utilized follow a passive asset class investment philosophy with low holdings turnover. DFA and other fund companies may provide historical market analysis, risk/return analysis, and continuing education to RF&L. Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, RF&L relies on an analysis of the client’s financial objectives, current and estimated  future resources, and tolerance for risk. To derive a recommended asset allocation, RF&L may use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other method used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • The risk that expected future cash flows will not match those used in the analysis • The risk that future rates of return will fall short of the estimates used in the simulation • The risk that inflation will exceed the estimates used in the simulation • For taxable clients, the risk that tax rates will be higher than was assumed in the analysis Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by RF&L may include funds invested in domestic and international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities. Equity securities may include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds used in RF&L’s investment strategies funds are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities, or TIPS) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds. Certain funds utilized by RF&L may contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. More information about the risks of any particular market sector can be reviewed in representative fund prospectuses managing assets within each applicable sector. Direct indexing strategies are subject to market risk and may underperform the benchmark index they seek to replicate due to factors such as transaction costs, borrowing costs, cash holdings, tax- management techniques, portfolio customization, and the exclusion or weighting of certain securities. Tax-related benefits, including tax-loss harvesting, are not guaranteed and will vary based on an investor's individual tax circumstances. Investors should consult their tax adviser regarding the potential tax consequences of a direct indexing strategy.  On occasion, clients may access margin loans or securities based loans (‘SBLs’) through their custodian. SBLs and margin loans increase portfolio risk and decrease portfolio liquidity and clients should consider those risks prior to undertaking such a transaction. 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 your evaluation of RF&L or the integrity of RF&L’s management. RF&L has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Focus Partners Advisor Solutions As described above in Item 4, RF&L may exercise discretionary authority provided by a client to select an independent third-party investment manager for the management of portfolios of individual fixed income securities. RF&L has selected FAS for such fixed income management. RF&L also contracts with FAS for back-office services and assistance with portfolio modeling. RF&L has a fiduciary duty to select qualified and appropriate managers in the client’s best interest and believes that FAS effectively provides both the back-office services that assist with its overall investment advisory practice and fixed income portfolio management services. The management of RF&L continuously makes this assessment. While RF&L has a contract with FAS governing a time period for back-office services, RF&L has no such fixed commitment to the selection of FAS for fixed income management services and may select another investment manager for clients upon reasonable notice to FAS. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading RF&L has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. RF&L's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth RF&L's practice of supervising the personal securities transactions of employees with access to client information. Individuals associated with RF&L may buy or sell securities for their personal accounts identical or different than those recommended to clients. It is the expressed policy of RF&L that no person employed by the firm shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on investment decisions of advisory clients. To supervise compliance with its Code of Ethics, RF&L requires that all Supervised Persons of this advisory practice with access to advisory recommendations provide annual securities holding reports and quarterly transaction reports to the firm's Chief Compliance Officer. RF&L also requires such access persons to receive approval from the Chief Compliance Officer prior to investing in any IPO's or private placements (limited offerings). RF&L's Code of Ethics further includes the firm's policy prohibiting the use of material non- public information and protecting the confidentiality of client information. RF&L requires that all individuals must act in accordance with all applicable Federal and State regulations governing  registered investment advisory practices. Any individual not in observance of the above may be subject to discipline. RF&L will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices Investment Management Services RF&L arranges for the execution of securities transactions with the assistance of FAS. Through FAS, RF&L participates in the Fidelity Institutional Wealth Services (FIWS) program, sponsored by Fidelity Brokerage Services, LLC ("Fidelity"). Fidelity is a FINRA member broker dealer. The Fidelity brokerage program will generally be recommended to advisory clients for the execution of mutual fund and equity securities transactions. RF&L regularly reviews the program to ensure that its recommendations are consistent with its fiduciary duty. This trading platform is essential to RF&L’s service arrangements and capabilities, and RF&L may not accept clients who direct the use of other brokers. As part of this program, RF&L receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). As RF&L will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid in these situations, clients must direct RF&L as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that RF&L will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. RF&L will not exercise authority to arrange client transactions in individual fixed income securities. Clients will provide this authority to a fixed income Independent Manager retained by RF&L on client’s behalf by designating the portfolio manager with trading authority over client’s brokerage account. Clients will be provided with the Disclosure Brochure (Form ADV Part 2 and Form CRS) of the portfolio manager. FIWS does not generally charge clients a custody fee and is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through the broker or that settle into the clients’ accounts at the brokers. Trading client accounts through other brokers may result in fees (including mark-ups and mark-downs) being charged by the custodial broker and an additional broker. While RF&L will not arrange transactions through other brokers, the authority of the fixed income portfolio manager includes the ability to trade client fixed income assets through other brokers. RF&L generally does not aggregate or block client transactions in mutual fund, ETF, or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which RF&L arranges transactions. FAS, in the management of fixed income portfolios, will aggregate certain transactions among client accounts that it manages, in which case an RF&L client’s orders may be aggregated with an order for  another client of Focus Partners Advisor Solutions who is not an RF&L client. See Focus Partners Advisor Solutions Form ADV Part 2. When trading client accounts, errors may periodically occur. RF&L does not maintain any client trade error gains. RF&L makes client whole with respect to any trade error losses incurred by client and caused by RF&L. RF&L also does not have any arrangements to compensate any broker dealer for client referrals. Participant-Directed Employee Benefit Retirement Plan Services: RF&L does not arrange for the execution of securities transactions for retirement plans as a part of this service. Transactions are executed directly through employee plan participation. Item 13 – Review of Accounts Reviews: Investment Management Services Account assets are supervised continuously and formally reviewed bi-annually by the Members/Owners of RF&L. The review process contains each of the following elements: a. assessing client goals and objectives; b. evaluating the employed strategy(ies); c. monitoring the portfolio(s); and d. addressing the need to rebalance. Additional account reviews may be triggered by any of the following events: a. a specific client request; b. a change in client goals and objectives; c. an imbalance in a portfolio asset allocation; and d. market/economic conditions. For fixed income portfolios, certain account review responsibilities are delegated to a third-party investment manager as described above in Item 1.D. Participant-Directed Employee Benefit Retirement Plan Services: Plan assets are reviewed on a quarterly basis, and according to the standards and situations described above for investment management accounts. Reports: Investment Management Services  All clients receiving investment management services will receive quarterly performance reports, prepared on the Orion platform and reviewed by RF&L, which summarize the client’s account and asset allocation. Clients will also receive statements from their account custodian, which will outline the client’s current positions and current market value. Participant-Directed Employee Benefit Retirement Plan Services: Plan clients may only receive statements from their account custodian. Item 14 – Client Referrals and Other Compensation As indicated under the disclosure for Item 12, FIWS provides RF&L with access to services, which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services benefit RF&L but may not benefit its clients' accounts. Many of the products and services assist RF&L in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of RF&L's fees from its clients’ accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of RF&L's accounts. Recommended brokers also make available to RF&L other services intended to help RF&L manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. RF&L does not, however, enter into any commitments with the brokers for transaction levels in exchange for any services or products from brokers. While as a fiduciary, RF&L endeavors to act in its clients’ best interests, RF&L's requirement that clients maintain their assets in accounts at FIWS may be based in part on the benefit to RF&L of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the brokers, which can create a potential conflict of interest. Dimensional Fund Advisors (“DFA”) has provided its own personnel and outside consultants for purposes of continuing education for RF&L, and provides RF&L with certain administrative and marketing tools. DFA, through its web-based service, may provide referrals of investor clients to RF&L. DFA makes such referrals to many investment advisors based upon the geographic location of the prospective client. DFA does not provide help to RF&L in recruiting investor clients in any other way. DFA also provides continuing education for RF&L personnel including participation in an annual DFA Conference. These services are designed to assist RF&L plan and design its services for business growth. The Firm does not maintain any active solicitor, promoter, or referral arrangements and does not compensate any person or entity, directly or indirectly, for client referrals or introductions. Any referrals received by the Firm are unsolicited and no cash or non-cash compensation is provided in exchange for such referrals.  In certain circumstances, and upon agreement by both parties, a member of RF&L can assume the position of Trustee or Executor on behalf of a client. In addition to the customized trustee or estate documents assigning this role, clients will be required to sign an agreement retaining a member of RF&L for this position. This service will be provided at an agreed upon hourly rate upon commencement of the services. Such services are provided by the individual in their separate capacity, which is separate and distinct from the services provided by RF&L under the advisory agreement. Item 15 – Custody Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. RF&L urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. RF&L has custody of certain client accounts due to a related person serving as a trustee, and due to authority it has received authorizing asset disbursement to client accounts pursuant to standing authorization that clients provide to custodians. RF&L complies with the requirements of Rule 206(4)-2 including arranging for an annual surprise examination by an independent public accountant. Item 16 – Investment Discretion RF&L requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. For fixed income securities, this authority will include the discretion to retain a third-party money manager for fixed income accounts generally exceeding $500,000. Clients may give RF&L discretionary authority to execute purchases and sales of securities on their behalf. The discretionary authority is exercised within the parameters established in the client's Investment Policy Statement. RF&L does not receive any commissions. Item 17 – Voting Client Securities As a matter of firm policy and practice, RF&L does not generally accept authority to and does not vote proxies on behalf of advisory client. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in clients’ investment portfolios. RF&L, upon client request, may provide advice to clients regarding the clients' voting of proxies.  RF&L will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct RF&L to transmit copies of class action notices to the client or a third party. Upon such direction, RF&L will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about RF&L’s financial condition. RF&L has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.