Rhs Financial, LLC

Part 2A of Form ADV: Firm Brochure Part 2A of Form ADV: Firm Brochure Item 1: Cover Page Item 1: Cover Page March 23, 2026 March 23, 2026 lam. I. 11100 FINANCIAL INVEST WITH PURPOSE"' RHS Financial, LLC RHS Financial, LLC 4171 24th Street, Ste 101 4171 24th Street, Ste 101 San Francisco, CA 94114 San Francisco, CA 94114 www.rhsfinancial.com www.rhsfinancial.com Firm Contact: Firm Contact: Risley Sams Risley Sams Chief Compliance Officer Chief Compliance Officer This brochure provides information about the qualifications and business practices of RHS Financial, LLC. This brochure provides information about the qualifications and business practices of RHS Financial, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at 415-495- If you have any questions about the contents of this brochure, please contact us by telephone at 415-495- 2900 or email risley@rhsfinancial.com. The information in this brochure has not been approved or verified 2900 or email risley@rhsfinancial.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. by the United States Securities and Exchange Commission or by any State Securities Authority. is available on the SEC's website at is available on the SEC’s website at Additional information about RHS Financial, LLC also information about RHS Financial, LLC also Additional www.adviserinfo.sec.gov. The CRD Number for RHS Financial is 149435. www.adviserinfo.sec.gov. The CRD Number for RHS Financial is 149435. Please note that the use of the term "registered investment adviser" and description of RHS Financial, LLC Please note that the use of the term “registered investment adviser” and description of RHS Financial, LLC and/or our associates as "registered" does not imply a certain level of skill or training. You are encouraged and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm's associates who advise you for more to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. information on the qualifications of our firm and our employees.  Item 2: Material Changes Item 2: f. - rial Changes The Form ADV Part 2a Brochure annual update was previously filed on March 31, 2025 (the "2025 The Form ADV Part 2a Brochure annual update was previously filed on March 31, 2025 (the “2025 Brochure Update"). The following contents of this Item 2 are limited to reflecting material changes to Brochure Update”). The following contents of this Item 2 are limited to reflecting material changes to the Form ADV Part 2a Brochure for RHS Financial, LLC ("RHS Financial") since the 2025 Brochure Update. the Form ADV Part 2a Brochure for RHS Financial, LLC (“RHS Financial”) since the 2025 Brochure Update. As of March 1, 2026, RHS Financial has undergone significant restructuring resulting in addition of new As of March 1, 2026, RHS Financial has undergone significant restructuring resulting in addition of new managers . Prior to the restructuring, RHS Financial was a single-member LLC managed by Risley H. managers . Prior to the restructuring, RHS Financial was a single-member LLC managed by Risley H. Sams. Pursuant to the restructuring, RHS Financial is now managed by Risley H. Sams, Colby G. Davis Sams. Pursuant to the restructuring, RHS Financial is now managed by Risley H. Sams, Colby G. Davis and Christian Oudard. Our firm's services and offerings will remain the same, only the structure of the and Christian Oudard. Our firm’s services and offerings will remain the same, only the structure of the organization has been broadened to allow for more ownership. organization has been broadened to allow for more ownership. As of the date of this Firm Brochure, RHS Financial has launched a subadvisory program that is currently As of the date of this Firm Brochure, RHS Financial has launched a subadvisory program that is currently partnered with Charles Schwabs' SMA platform. RHS Financial intends to expand this subadvisory partnered with Charles Schwabs’ SMA platform. RHS Financial intends to expand this subadvisory program to partner with more SEC-registered investment advisers (RIAs) in the future. program to partner with more SEC-registered investment advisers (RIAs) in the future. ADV Part 2A – Firm Brochure ADV Part 2A - Firm Brochure Page 2 Page 2 RHS Financial, LLC RHS Financial, LLC  Item 3: Table of Contents Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................... 1 Item 1: Cover Page 1 Item 2: Material Changes ................................................................................................................ 2 Item 2: Material Changes 2 Item 3: Table of Contents ............................................................................................................... 3 Item 3: Table of Contents 3 Item 4: Advisory Business ............................................................................................................... 4 Item 4: Advisory Business 4 Item 5: Fees & Compensation ......................................................................................................... 5 Item 5: Fees & Compensation 5 Item 6: Performance-Based Fees & Side-By-Side Management .................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management 7 Item 7: Types of Clients & Account Requirements ......................................................................... 7 Item 7: Types of Clients & Account Requirements 7 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ............................................... 7 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss 7 8 Item 9: Disciplinary Information ..................................................................................................... 8 Item 9: Disciplinary Information 8 Item 10: Other Financial Industry Activities & Affiliations ............................................................. 8 Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ....... 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 8 Item 12: Brokerage Practices .......................................................................................................... 9 Item 12: Brokerage Practices 9 Item 14: Client Referrals & Other Compensation ......................................................................... 13 Item 14: Client Referrals & Other Compensation 13 Item 15: Custody ........................................................................................................................... 14 Item 15: Custody 14 Item 16: Investment Discretion .................................................................................................... 14 Item 16: Investment Discretion 14 Item 18: Financial Information ..................................................................................................... 15 Item 18: Financial Information 15 (Continued on next page) (Continued on next page) ADV Part 2A – Firm Brochure ADV Part 2A - Finn Brochure Page 3 Page 3 RHS Financial, LLC RHS Financial, LLC  Item 4: Advisory Business Item 4: Advisory Business Advisory Firm Advisory Firm RHS Financial, LLC has been providing investment advisory services since 2009. Risley Sams is the founder, RHS Financial, LLC has been providing investment advisory services since 2009. Risley Sams is the founder, President, a managing member and the majority owner of RHS Financial. Colby Davis and Christian Oudard President, a managing member and the majority owner of RHS Financial. Colby Davis and Christian Oudard are both also managing members of RHS Financial. are both also managing members of RHS Financial. Risley Sams has been in the financial services industry since 2002 working with the same types of clients Risley Sams has been in the financial services industry since 2002 working with the same types of clients as he currently serves at RHS Financial. Risley Sams' background can be found in his Form ADV Part 2B. as he currently serves at RHS Financial. Risley Sams’ background can be found in his Form ADV Part 2B. Colby Davis has been an integral part of RHS Financial since 2013 and is the Chief Investment officer and Colby Davis has been an integral part of RHS Financial since 2013 and is the Chief Investment officer and Portfolio Manager of RHS. Colby Davis' background can be found in his Form ADV part 2B. Portfolio Manager of RHS. Colby Davis’ background can be found in his Form ADV part 2B. Christian Oudard is a computer programmer and has been instrumental in the development of RHS Christian Oudard is a computer programmer and has been instrumental in the development of RHS Financials' trading and rebalancing software over many years. Christian does not formulate investment Financials’ trading and rebalancing software over many years. Christian does not formulate investment advice for RHS Financial. advice for RHS Financial. Advisory Services Advisory Services  RHS Financial provides asset management and financial planning services under a single agreement. 0 RHS Financial provides asset management and financial planning services under a single agreement. As of December 31, 2025, RHS Financial has $214,000,000 of assets under management on a discretionary As of December 31, 2025, RHS Financial has $214,000,000 of assets under management on a discretionary basis and $9,000,000 of assets under management on a non-discretionary basis. basis and $9,000,000 of assets under management on a non-discretionary basis. Advisory services are based on the individual needs of the client. An initial interview and data gathering Advisory services are based on the individual needs of the client. An initial interview and data gathering questionnaire is undertaken to determine the client's financial situation and investment objectives, and questionnaire is undertaken to determine the client's financial situation and investment objectives, and to give the client the opportunity to impose reasonable restrictions on the management of the account. to give the client the opportunity to impose reasonable restrictions on the management of the account. Clients have the ability to leave standing instructions with the Investment Advisor ("IA") Rep to refrain Clients have the ability to leave standing instructions with the Investment Advisor (“IA”) Rep to refrain from investing in particular securities or types of securities or invest in limited amounts of securities. The from investing in particular securities or types of securities or invest in limited amounts of securities. The IA Rep will contact or attempt to contact the client annually on these matters. It is the client's IA Rep will contact or attempt to contact the client annually on these matters. It is the client's responsibility to notify the IA Rep at any time there are changes. Clients may call in at any time during responsibility to notify the IA Rep at any time there are changes. Clients may call in at any time during normal business hours to discuss directly with the IA Rep about the client's account, financial situation, or normal business hours to discuss directly with the IA Rep about the client's account, financial situation, or investment needs. Clients will receive from the custodian/brokerage firm timely confirmations and at investment needs. Clients will receive from the custodian/brokerage firm timely confirmations and at least quarterly statements containing a description of all transactions and all account activity. The client least quarterly statements containing a description of all transactions and all account activity. The client will retain rights of ownership of all securities and funds in the account to the same extent as if the client will retain rights of ownership of all securities and funds in the account to the same extent as if the client held the securities and funds outside the program. In addition to custodial statements, RHS Financial sends held the securities and funds outside the program. In addition to custodial statements, RHS Financial sends quarterly reports to the client. RHS Financial does not participate in wrap fee programs. quarterly reports to the client. RHS Financial does not participate in wrap fee programs. Additionally, the Adviser may provide clients receiving Advisory Services with financial planning and Additionally, the Adviser may provide clients receiving Advisory Services with financial planning and investment consulting services at no additional charge. investment consulting services at no additional charge. In O.2 2025, RHS Financial launched a subadvisory program to provide asset management services to other In Q2 2025, RHS Financial launched a subadvisory program to provide asset management services to other registered investment advisers and their clients. Through this program, RHS Financial acts as a sub-adviser, registered investment advisers and their clients. Through this program, RHS Financial acts as a sub-adviser, managing investment portfolios according to specific investment strategies RHS Financial has developed managing investment portfolios according to specific investment strategies RHS Financial has developed based on the stated objectives of the end client, while the primary financial adviser maintains the direct based on the stated objectives of the end client, while the primary financial adviser maintains the direct relationship with the end client. Under this arrangement, RHS Financial will have discretionary authority relationship with the end client. Under this arrangement, RHS Financial will have discretionary authority to select securities and execute transactions within the parameters agreed upon with the primary to select securities and execute transactions within the parameters agreed upon with the primary ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 4 Page 4 RHS Financial, LLC RHS Financial, LLC  investment adviser. The subadvisory program is designed to offer professional portfolio management investment adviser. The subadvisory program is designed to offer professional portfolio management services with customization options to meet the needs of various client types. Clients of the subadvisory services with customization options to meet the needs of various client types. Clients of the subadvisory program will receive reporting both from their primary financial adviser and have access to information program will receive reporting both from their primary financial adviser and have access to information about our investment strategies and portfolio decisions. about our investment strategies and portfolio decisions.  RHS Financial provides Financial Plans and Consultations consistent with the individual client's financial 0 RHS Financial provides Financial Plans and Consultations consistent with the individual client's financial and tax status and risk/reward objectives. Planning may be comprehensive or segmented and focus on and tax status and risk/reward objectives. Planning may be comprehensive or segmented and focus on investments, taxes, and/or estate plans. This planning or consulting may encompass Investment Planning, investments, taxes, and/or estate plans. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. In general, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. In general, these financial plans are provided for free as long as the client is a participant in RHS Financials' asset these financial plans are provided for free as long as the client is a participant in RHS Financials’ asset management program as described above. management program as described above. Item 5: Fees & Compensation Item 5: Fees & Compensation Fees for our asset management program stated in Item 4: "Advisory Services," are computed at an Fees for our asset management program stated in Item 4: “Advisory Services,” are computed at an annualized percentage of assets under management on a sliding scale. annualized percentage of assets under management on a sliding scale. Assets Under Management Assets Under Management Annual Advisory Fee Annual Advisory Fee $0- $500,000 $0- $500,000 $500,000 - $1,000,000 $500,000 - $1,000,000 $1,000,000 - $2,500,000 $1,000,000 - $2,500,000 $2,500,000 - $5,000,000 $2,500,000 - $5,000,000 Over $5,000,000 Over $5,000,000 1.00% 1.00% 0.95% 0.95% 0.90% 0.90% 0.80% 0.80% 0.70% 0.70% Financial planning and consultation services are available to clients receiving Advisory Services at no Financial planning and consultation services are available to clients receiving Advisory Services at no additional cost. Financial planning and consultation services are not available to clients not receiving additional cost. Financial planning and consultation services are not available to clients not receiving Advisory Services from RHS Financial. Advisory Services from RHS Financial. Our firm's fees are billed on a pro-rata annualized basis quarterly in advance based on the last day of the Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the last day of the previous month. You will be billed on the aggregate value of the accounts held at Charles Schwab & Co. previous month. You will be billed on the aggregate value of the accounts held at Charles Schwab & Co. Inc. or the aggregate value of the accounts held at Interactive Brokers. The first payment for our asset Inc. or the aggregate value of the accounts held at Interactive Brokers. The first payment for our asset management program will be due after assets are placed with the custodian and will be assessed at the management program will be due after assets are placed with the custodian and will be assessed at the beginning of the first full month the assets are placed with the custodian. Our firm bills on cash unless beginning of the first full month the assets are placed with the custodian. Our firm bills on cash unless otherwise noted in writing. Subsequent payments are due and will be assessed on the first day of each otherwise noted in writing. Subsequent payments are due and will be assessed on the first day of each quarter based on the starting month. quarter based on the starting month. Fees are negotiable and will be deducted from your managed account. In rare cases, we will agree to Fees are negotiable and will be deducted from your managed account. In rare cases, we will agree to direct bill clients. As part of this process, you understand and acknowledge the following: direct bill clients. As part of this process, you understand and acknowledge the following: a) Your independent custodian sends statements at least quarterly to you showing the market a) Your independent custodian sends statements at least quarterly to you showing the market values for each security included in the Assets and all disbursements in your account including values for each security included in the Assets and all disbursements in your account including the amount of the advisory fees paid to us; the amount of the advisory fees paid to us; b) You provide authorization permitting us to be directly paid by these terms. We send our b) You provide authorization permitting us to be directly paid by these terms. We send our invoice directly to the custodian; invoice directly to the custodian; ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 5 Page 5 RHS Financial, LLC RHS Financial, LLC  c) c) If we send a copy of our invoice to you, a legend urging you to compare information provided If we send a copy of our invoice to you, a legend urging you to compare information provided in our statement with those from the qualified custodian will be included. in our statement with those from the qualified custodian will be included. Fees for our subadvisory services will be negotiable per financial adviser that utilizes this service but will Fees for our subadvisory services will be negotiable per financial adviser that utilizes this service but will range between 10bps and 45bps. This service will have no minimum investment amount, with fees bided range between 10bps and 45bps. This service will have no minimum investment amount, with fees billed quarterly in advance on a pro-rate annualized basis. quarterly in advance on a pro-rate annualized basis. Client authorizes the custodian holding client funds and securities to deduct RHS Financial advisory fees Client authorizes the custodian holding client funds and securities to deduct RHS Financial advisory fees direct from the client account in accordance with statements prepared and submitted to the custodian by direct from the client account in accordance with statements prepared and submitted to the custodian by RHS Financial. The custodian will provide periodic account statements to the client. Such statements will RHS Financial. The custodian will provide periodic account statements to the client. Such statements will reflect all fee withdrawals by RHS Financial. Our firm suggests that clients periodically check the accuracy reflect all fee withdrawals by RHS Financial. Our firm suggests that clients periodically check the accuracy of fee calculations, but it is ultimately the responsibility of RHS Financial to properly calculate the fees we of fee calculations, but it is ultimately the responsibility of RHS Financial to properly calculate the fees we charge. The custodian will not determine whether the fee is properly calculated. charge. The custodian will not determine whether the fee is properly calculated. Clients will incur transaction charges for trades executed in their accounts. These transaction fees are Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our firm's advisory fees and will be disclosed by the chosen custodian. Charles Schwab & separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. ("Schwab") does not charge transaction fees for U.S. listed equities and exchange traded funds. Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay charges imposed directly by a mutual fund, index fund, or exchange traded fund, Clients may also pay charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund's prospectus (i.e., fund management fees, initial or deferred sales which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses). Our firm does not receive a portion of these fees. retirement plan fees, and other fund expenses). Our firm does not receive a portion of these fees. Fees are not collected for services to be performed more than six months in advance. Fees are not collected for services to be performed more than six months in advance. For our asset management program, services will continue until either party terminates the Agreement For our asset management program, services will continue until either party terminates the Agreement with written notice. with written notice. If termination occurs prior to the end of a calendar quarter, a pro-rata refund of unearned fees will be If termination occurs prior to the end of a calendar quarter, a pro-rata refund of unearned fees will be made to the client. Management fees shall not be prorated for each capital contribution or withdrawal made to the client. Management fees shall not be prorated for each capital contribution or withdrawal made during applicable calendar quarter. made during applicable calendar quarter. For Financial Plans and Consultations, the client may terminate the Agreement at any time and a refund For Financial Plans and Consultations, the client may terminate the Agreement at any time and a refund of the unearned fees will be made based on the flat fee charged and the actual term and scope of the of the unearned fees will be made based on the flat fee charged and the actual term and scope of the engagement. The Agreement for Financial Plans and Consultations terminates upon delivery of the plan engagement. The Agreement for Financial Plans and Consultations terminates upon delivery of the plan or services. At this time no refunds will be made. or services. At this time no refunds will be made. The Advisory Agreement contains a pre-dispute arbitration clause. Client understands that the agreement The Advisory Agreement contains a pre-dispute arbitration clause. Client understands that the agreement to arbitrate does not constitute a waiver of the right to seek a judicial forum where such a waiver would to arbitrate does not constitute a waiver of the right to seek a judicial forum where such a waiver would be void under the federal securities laws. Arbitration is final and binding on the parties. be void under the federal securities laws. Arbitration is final and binding on the parties. Item 6: Performance-Based Fees & Side-By-Side Management Item 6: Performance-Based Fees & Side-By-Side Management RHS Financial does not charge performance-based fees, which are based on capital gains in the client RHS Financial does not charge performance-based fees, which are based on capital gains in the client account. account. ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 6 Page 6 RHS Financial, LLC RHS Financial, LLC  Item 7: Types of Clients & Account Requirements RHS Financial provides advisory services to individuals, charitable organizations, other ERISA accounts, RHS Financial provides advisory services to individuals, charitable organizations, other ERISA accounts, trusts, estates, and business entities. trusts, estates, and business entities. Generally, the minimum account size is $500,000, subject to a minimum annual fee of at least $2,500 Generally, the minimum account size is $500,000, subject to a minimum annual fee of at least $2,500 annually. The minimum fee would increase the maximum percentage rate paid on smaller accounts to annually. The minimum fee would increase the maximum percentage rate paid on smaller accounts to more than 1% annualized as shown on the standard fee schedule. However, in no case would the fee more than 1% annualized as shown on the standard fee schedule. However, in no case would the fee exceed 2% per year. Multiple accounts from the same client may be aggregated into a "household" to exceed 2% per year. Multiple accounts from the same client may be aggregated into a “household” to meet the account minimum stated above. Our firm can waive or discount minimum fees and account meet the account minimum stated above. Our firm can waive or discount minimum fees and account requirements at its sole discretion. requirements at its sole discretion. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Investing in securities involves the risk of loss that client should be prepared to bear. Analysis utilized by Investing in securities involves the risk of loss that client should be prepared to bear. Analysis utilized by RHS Financial includes charting, fundamental, technical, and cyclical. RHS Financial uses asset allocation RHS Financial includes charting, fundamental, technical, and cyclical. RHS Financial uses asset allocation strategies for portfolio management strategy. strategies for portfolio management strategy. By its nature, financial planning looks to the long-term. After the client's short-term cash needs and By its nature, financial planning looks to the long-term. After the client's short-term cash needs and emergency fund is evaluated, investment strategies are designed to help the client achieve his or her emergency fund is evaluated, investment strategies are designed to help the client achieve his or her financial goals. Casualty insurance (e.g. homeowner's, auto, liability, etc.) is reviewed only at the client's financial goals. Casualty insurance (e.g. homeowner's, auto, liability, etc.) is reviewed only at the client's request, and would be provided by an outside casualty firm. request, and would be provided by an outside casualty firm. While there is risk in all investments, some carry a greater degree of risk or higher costs. There is no While there is risk in all investments, some carry a greater degree of risk or higher costs. There is no guarantee that the investment strategy selected for the client will result in the client's goals being rnet, guarantee that the investment strategy selected for the client will result in the client’s goals being met, nor is there any guarantee of profit or protection from loss. For those investments sold by prospectus, nor is there any guarantee of profit or protection from loss. For those investments sold by prospectus, clients should read the prospectus in full. clients should read the prospectus in full. RHS Financial is disclosingthose risks and opportunities for our investment strategy or for particulartypes RHS Financial is disclosing those risks and opportunities for our investment strategy or for particular types of securities used. of securities used.  Debt securities are subject to interest rate risk. • Debt securities are subject to interest rate risk.  Stock investments, individual securities and Mutual Funds. • Stock investments, individual securities and Mutual Funds.  High yield securities are corporate debt securities rated below investment grade... • High yield securities are corporate debt securities rated below investment grade...  By timing the buys and sells, we endeavor to control the risks. Timing the markets has its own set • By timing the buys and sells, we endeavor to control the risks. Timing the markets has its own set of risks and can have both positive and negative effects on performance. of risks and can have both positive and negative effects on performance.  There are tax consequences for short-term trading wherein capital gains are taxed as ordinary • There are tax consequences for short-term trading wherein capital gains are taxed as ordinary income. income.  Our investment style is a diversified approach based on asset allocation, however, as there is risks • Our investment style is a diversified approach based on asset allocation, however, as there is risks in all investments it is impossible to diversify away market risk. in all investments it is impossible to diversify away market risk.  Auction Rate Securities are floating rate debt securities (long-term variable-rate corporate or • Auction Rate Securities are floating rate debt securities (long-term variable-rate corporate or municipal bonds) tied to short-term interest rates. ARS have a long-term nominal maturity with municipal bonds) tied to short-term interest rates. ARS have a long-term nominal maturity with interest rates reset through an auction process ("Dutch auction") interest rates reset through an auction process (“Dutch auction”)  Structured products are a basket of investments that combine the upside potential of equity with • Structured products area basket of investments that combine the upside potential of equity with the downside protections of fixed income. Structured products are complex and difficult for the the downside protections of fixed income. Structured products are complex and difficult for the average investor to understand. Structured products are used to hedge and speculate and also average investor to understand. Structured products are used to hedge and speculate and also pose a risk to principal. pose a risk to principal. ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 7 Page 7 RHS Financial, LLC RHS Financial, LLC  Item 9: Disciplinary Information Item 9: Disciplinary Information An investment advisor must disclose material facts about any legal or disciplinary event that is material An investment advisor must disclose material facts about any legal or disciplinary event that is material to a client's evaluation of the advisory business or of the integrity of its management personnel. RHS to a client’s evaluation of the advisory business or of the integrity of its management personnel. RHS Financial does not have any disclosure items. Financial does not have any disclosure items. Item 10: Other Financial Industry Activities & Affiliations Item 10: Other Financial Industry Activities & Affiliations Our firm is not registered, nor does it have an application pending to register, as a broker-dealer, Our firm is not registered, nor does it have an application pending to register, as a broker-dealer, registered representative of a broker dealer, investment company or pooled investment vehicle, other registered representative of a broker dealer, investment company or pooled investment vehicle, other investment adviser or financial planner, futures commission merchant, commodity pool operator, investment adviser or financial planner, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or a sponsor or firm, insurance company or agency, pension consultant, real estate broker or dealer or a sponsor or syndicator of limited partnership, or an associated person of the foregoing entities. syndicator of limited partnership, or an associated person of the foregoing entities. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Code of Ethics Code of Ethics RHS Financial maintains a Code of Ethics. The Code of Ethics sets forth standards of conduct expected of RHS Financial maintains a Code of Ethics. The Code of Ethics sets forth standards of conduct expected of advisory personnel; requires compliance with federal securities laws; and, addresses conflicts that arise advisory personnel; requires compliance with federal securities laws; and, addresses conflicts that arise from personal trading by advisory personnel. The Code of Ethics includes provisions relating to the from personal trading by advisory personnel. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised entertainment items, and personal securities trading procedures, among other things. All supervised persons at RHS Financial must acknowledge the terms of the Code of Ethics annually, or as amended. persons at RHS Financial must acknowledge the terms of the Code of Ethics annually, or as amended. Clients may request a copy of the Code of Ethics. Clients may request a copy of the Code of Ethics. Participation or Interest in Client Transactions Participation or Interest in Client Transactions Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. our firm or a related person has a material financial interest without prior disclosure to the client. Personal Trading Personal Trading At times RHS Financial and/or its IA Reps may take positions in the same securities as clients, and we will At times RHS Financial and/or its IA Reps may take positions in the same securities as clients, and we will try to avoid conflicts with clients. The firm and its IA Reps will generally be "last in" and "last out" for the try to avoid conflicts with clients. The firm and its IA Reps will generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades. We will not violate our fiduciary trading day when trading occurs in close proximity to client trades. We will not violate our fiduciary responsibilities to our clients. Scalping (trading shortly ahead of clients) is prohibited. Should a conflict responsibilities to our clients. Scalping (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading. would not be disclosed at the time of trading. ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 8 Page 8 RHS Financial, LLC RHS Financial, LLC  Item 12: Brokerage Practices Item 12: Brokerage Practices Selection or Recommendation of Broker/Dealers Selection or Recommendation of Broker/Dealers Custodian & Brokers Used Custodian & Brokers Used Our firm does not maintain custody of client assets (although our firm may be deemed to have custody of Our firm does not maintain custody of client assets (although our firm may be deemed to have custody of client assets if give the authority to withdraw assets from client accounts. See Item 15 Custody, below). client assets if give the authority to withdraw assets from client accounts. See Item 15 Custody, below). Client assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Custodians will hold client assets in a brokerage account and buy and sell securities when instructed. bank. Custodians will hold client assets in a brokerage account and buy and sell securities when instructed. Two Custodians provide institutional brokerage services to our firm and to our clients: Two Custodians provide institutional brokerage services to our firm and to our clients:  The Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Charles Schwab”), a FINRA- The Schwab Advisor Services division of Charles Schwab & Co. Inc. ("Charles Schwab"), a FINRA- • registered broker-dealer, member SIPC; or registered broker-dealer, member SIPC; or  The institutional services of Interactive Brokers LLC, a division of Interactive Brokers Group, Inc. The institutional services of Interactive Brokers LLC, a division of Interactive Brokers Group, Inc. • ("Interactive Brokers") member FINRA/SIPC. (“Interactive Brokers”) member FINRA/SIPC. Our firm is independently owned and operated and is not affiliated with Charles Schwab or Interactive Our firm is independently owned and operated and is not affiliated with Charles Schwab or Interactive Brokers (herein "Custodians"). Clients may decide to open an account with one of the Custodians by Brokers (herein “Custodians”). Clients may decide to open an account with one of the Custodians by entering into an account agreement directly with them. Our firm does not open the account. entering into an account agreement directly with them. Our firm does not open the account. Even though the account is maintained by the Custodians, our firm can still use other brokers to execute Even though the account is maintained by the Custodians, our firm can still use other brokers to execute trades, as described in the next paragraph. trades, as described in the next paragraph. How Brokers/Custodians Are Selected How Brokers/Custodians Are Selected Our firm seeks to recommend a custodian/broker who will hold client assets and execute transactions on Our firm seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. terms that are overall most advantageous when compared to other available providers and their services. A wide range of factors are considered, including, but not limited to: A wide range of factors are considered, including, but not limited to:  •  •  •  • reputation, financial strength and stability of the provider reputation, financial strength and stability of the provider competitiveness of the price of t services (commission rates, margin interest rates, other fees, competitiveness of the price of t services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate combination of transaction execution services along with asset etc.) and willingness to negotiate combination of transaction execution services along with asset custody services (generally without a separate fee for custody) custody services (generally without a separate fee for custody) capability to execute, clear and settle trades (buy and sell securities for client accounts) capability to execute, clear and settle trades (buy and sell securities for client accounts) capability to facilitate transfers and payments to and from accounts (wire transfers, check capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) requests, bill payment, etc.)  breadth of investment products made available (stocks, bonds, mutual funds, exchange traded breadth of investment products made available (stocks, bonds, mutual funds, exchange traded • funds (ETFs), etc.) funds (ETFs), etc.)  availability of investment research and tools that assist in making investment decisions quality of • availability of investment research and tools that assist in making investment decisions quality of services services  prior service to our firm and our other clients • prior service to our firm and our other clients  availability of other products and services that benefit our firm, as discussed below (see “Products • availability of other products and services that benefit our firm, as discussed below (see "Products & Services Available from The Custodians") & Services Available from The Custodians”) Products & Services Available from the Custodians Products & Services Available from the Custodians ADV Part 2A – Firm Brochure ADV Pa rt 2A - Firm Brochure Page 9 Page 9 RHS Financial, LLC RHS Financial, LLC  Schwab Advisor Services and the institutional services of Interactive Brokers LLC are the Custodians’ Schwab Advisor Services and the institutional services of Interactive Brokers LLC are the Custodians' businesses serving independent investment advisory firms like our firm. They provide our firm and clients businesses serving independent investment advisory firms like our firm. They provide our firm and clients with access to its institutional brokerage – trading, custody, reporting and related services – many of with access to its institutional brokerage — trading, custody, reporting and related services — many of which are not typically available to either custodian’s retail customers. The Custodians also make available which are not typically available to either custodian's retail customers. The Custodians also make available various support services. Some of those services help manages or administer our client accounts while various support services. Some of those services help manages or administer our client accounts while others help manage and grow our business. Custodians’ support services are generally available on an others help manage and grow our business. Custodians' support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge to our firm. The availability of unsolicited basis (our firm does not have to request them) and at no charge to our firm. The availability of the Custodians products and services are not based on the provision of particular investment advice, such the Custodians products and services are not based on the provision of particular investment advice, such as purchasing particular securities for clients. Here is a more detailed description of the Custodians’ as purchasing particular securities for clients. Here is a more detailed description of the Custodians' support services: support services: Services that Benefit Clients Services that Benefit Clients The Custodians’ institutional brokerage services include access to a broad range of investment products, The Custodians' institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available execution of securities transactions, and custody of client assets. The investment products available through these programs include some to which our firm might not otherwise have access or that would through these programs include some to which our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. The Custodians’ services require a significantly higher minimum initial investment by firm clients. The Custodians' services described in this paragraph generally benefit clients and their accounts. described in this paragraph generally benefit clients and their accounts. Services that May Not Directly Benefit Clients Services that May Not Directly Benefit Clients The Custodians also make available other products and services that benefit our firm but may not directly The Custodians also make available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both proprietary to each custodian and that of third client accounts. They include investment research, both proprietary to each custodian and that of third parties. This research may be used to service all or some substantial number of client accounts, including parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained by either of the Custodians. In addition to investment research, the Custodians accounts not maintained by either of the Custodians. In addition to investment research, the Custodians also make available software and other technology that: also make available software and other technology that:  provides access to client account data (such as duplicate trade confirmations and account provides access to client account data (such as duplicate trade confirmations and account • statements); statements);  facilitates trade execution and allocate aggregated trade orders for multiple client accounts; facilitates trade execution and allocate aggregated trade orders for multiple client accounts; •  provides pricing and other market data; provides pricing and other market data; •  facilitates payment of our fees from our clients’ accounts; and • facilitates payment of our fees from our clients' accounts; and  assists with back-office functions, recordkeeping and client reporting. assists with back-office functions, recordkeeping and client reporting. • Services that Generally Benefit Only Our Firm Services that Generally Benefit Only Our Firm The Custodians also offer other services intended to help manage and further develop our business The Custodians also offer other services intended to help manage and further develop our business enterprise. These services include: enterprise. These services include:  educational conferences and events educational conferences and events •  technology, compliance, legal, and business consulting; technology, compliance, legal, and business consulting; •  publications and conferences on practice management and business succession; and publications and conferences on practice management and business succession; and •  access to employee benefits providers, human capital consultants and insurance providers. • access to employee benefits providers, human capital consultants and insurance providers. The Custodians may provide some of these services. In other cases, the Custodians will arrange for third- The Custodians may provide some of these services. In other cases, the Custodians will arrange for third- party vendors to provide the services to our firm. The Custodians may also discount or waive fees for some party vendors to provide the services to our firm. The Custodians may also discount or waive fees for some ADV Part 2A – Firm Brochure ADV Part 2A - Firm Brochure Page 10 Page 10 RHS Financial, LLC RHS Financial, LLC  of these services or pay all or a part of a third party’s fees. The Custodians may also provide our firm with of these services or pay all or a part of a third party's fees. The Custodians may also provide our firm with other benefits, such as occasional business entertainment for our personnel. other benefits, such as occasional business entertainment for our personnel. Irrespective of direct or indirect benefits to our clients through the Custodians, our firm strives to enhance Irrespective of direct or indirect benefits to our clients through the Custodians, our firm strives to enhance the client experience, help clients reach their goals and put client interests before that of our firm and the client experience, help clients reach their goals and put client interests before that of our firm and associated persons. associated persons. Our Interest in The Custodians’ Services. Our Interest in The Custodians' Services. The availability of these services from the Custodians benefits our firm because our firm does not have to The availability of these services from the Custodians benefits our firm because our firm does not have to produce or purchase them. Our firm does not have to pay for these services, and they are not contingent produce or purchase them. Our firm does not have to pay for these services, and they are not contingent upon committing any specific amount of business to the Custodians in trading commissions or assets in upon committing any specific amount of business to the Custodians in trading commissions or assets in custody. custody. In light of our arrangements with the Custodians, a conflict of interest exists as our firm may have incentive In light of our arrangements with the Custodians, a conflict of interest exists as our firm may have incentive to require that clients maintain their accounts with the Custodians based on our interest in receiving the to require that clients maintain their accounts with the Custodians based on our interest in receiving the Custodians’ services that benefit our firm rather than based on client interest in receiving the best value Custodians' services that benefit our firm rather than based on client interest in receiving the best value in custody services and the most favorable execution of transactions. As part of our fiduciary duty to our in custody services and the most favorable execution of transactions. As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should be aware, clients, our firm will endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of the Custodians as a custodial conflict of interest and may indirectly influence our firm's choice of the Custodians as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend the Custodians and has determined that the recommendation is in the best interest of our firm’s clients the Custodians and has determined that the recommendation is in the best interest of our firm's clients and satisfies our fiduciary obligations, including our duty to seek best execution. and satisfies our fiduciary obligations, including our duty to seek best execution. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including the value of research provided, execution capability, commission rates, and dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Our not necessarily obtain the lowest possible commission rates for specific client account transactions. Our firm believes that the selection of the Charles Schwab or Interactive Brokers as a custodian and broker is firm believes that the selection of the Charles Schwab or Interactive Brokers as a custodian and broker is often in the best interest of our clients. This is primarily supported by the scope, quality and price of both often in the best interest of our clients. This is primarily supported by the scope, quality and price of both custodians’ suite of services, and not solely the Custodians’ services that only benefit our firm. custodians' suite of services, and not solely the Custodians' services that only benefit our firm. Custody & Brokerage Costs Custody & Brokerage Costs The Custodians generally do not charge separately for custodial services but are compensated by charging The Custodians generally do not charge separately for custodial services but are compensated by charging commissions or other fees to clients on trades that are executed or that settle into the Custodians’ commissions or other fees to clients on trades that are executed or that settle into the Custodians' account. For some accounts, the Custodians may charge client accounts a percentage of the dollar number account. For some accounts, the Custodians may charge client accounts a percentage of the dollar number of assets in the account in lieu of commissions. The Custodians’ commission rates and/or asset-based fees of assets in the account in lieu of commissions. The Custodians' commission rates and/or asset-based fees applicable to client accounts were negotiated based on our firm’s commitment to maintain a minimum applicable to client accounts were negotiated based on our firm's commitment to maintain a minimum threshold of assets statement equity in accounts at the Custodians. This commitment benefits clients threshold of assets statement equity in accounts at the Custodians. This commitment benefits clients because the overall commission rates and/or asset-based fees paid are lower than they would be if our because the overall commission rates and/or asset-based fees paid are lower than they would be if our firm had not made the commitment. In addition to commissions or asset-based fees, the Custodians firm had not made the commitment. In addition to commissions or asset-based fees, the Custodians charge a flat dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has charge a flat dollar amount as a "prime broker" or "trade away" fee for each trade that our firm has executed by a different broker-dealer but where the securities bought or the funds from the securities executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into one of the Custodians’ accounts. These fees are in addition to the sold are deposited (settled) into one of the Custodians' accounts. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, in order to commissions or other compensation paid to the executing broker-dealer. Because of this, in order to ADV Part 2A – Firm Brochure ADV Part 2A - Firm Brochure Page 11 Page 11 RHS Financial, LLC RHS Financial, LLC  minimize client trading costs, our firm has one of the Custodians execute most trades for our clients’ minimize client trading costs, our firm has one of the Custodians execute most trades for our clients' accounts. accou nts. Client Brokerage Commissions Client Brokerage Commissions The Custodians do not make client brokerage commissions generated by client transactions available for The Custodians do not make client brokerage commissions generated by client transactions available for our firm’s use. our firm's use. Client Transactions in Return for Soft Dollars Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Our firm does not receive brokerage for client referrals. Directed Brokerage Directed Brokerage Our firm and firm’s representatives have no discretional authority to direct order execution among Our firm and firm's representatives have no discretional authority to direct order execution among custodians or broker dealers; execution details include but are not limited to commission rates, time custodians or broker dealers; execution details include but are not limited to commission rates, time constraints, and volume considerations. constraints, and volume considerations. Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Our Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Our firm often recommends use of Charles Schwab or Interactive Brokers. firm often recommends use of Charles Schwab or Interactive Brokers. Client-Directed Brokerage Client-Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. may receive less favorable prices. Aggregation of Purchase or Sale Aggregation of Purchase or Sale Our firm provides investment management services for various clients. At times, portfolio transactions Our firm provides investment management services for various clients. At times, portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm., Although concurrent authorizations could potentially be advantageous or accounts served by our firm., Although concurrent authorizations could potentially be advantageous or disadvantageous to any one or more particular accounts, they are executed only when our firm believes disadvantageous to any one or more particular accounts, they are executed only when our firm believes that doing so is best interests of the represented accounts. When concurrent authorizations occur, the that doing so is best interests of the represented accounts. When concurrent authorizations occur, the objective is to allocate executions in a manner which is deemed equitable to accounts involved. Our firm objective is to allocate executions in a manner which is deemed equitable to accounts involved. Our firm attempts to allocate trade executions in the most equitable manner possible, using price averaging, attempts to allocate trade executions in the most equitable manner possible, using price averaging, proration, and consistent non-arbitrary methods of allocation. proration, and consistent non-arbitrary methods of allocation. ADV Part 2A – Firm Brochure ADV Part 2A - Firm Brochure Page 12 Page 12 RHS Financial, LLC RHS Financial, LLC  Item 13: Review of Accounts or Financial Plans Item 13: Review of Accounts or Financial Plans Our asset management program accounts are reviewed at a minimum of once per quarter. Market Our asset management program accounts are reviewed at a minimum of once per quarter. Market conditions that might cause a wide variance in the specified asset allocation, or other factors could cause conditions that might cause a wide variance in the specified asset allocation, or other factors could cause a more frequent review. a more frequent review. The financial plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients The financial plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients engage us on an annual basis to update the financial plan. engage us on an annual basis to update the financial plan. All clients receive standard account statements from investment sponsors and brokerage firms. Our asset All clients receive standard account statements from investment sponsors and brokerage firms. Our asset management program clients receive a written quarterly performance report from RHS Financial. management program clients receive a written quarterly performance report from RHS Financial. Financial Plans and Consultations clients do not receive reviews of their written plans unless they take Financial Plans and Consultations clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post-financial updated reports regarding their financial plans unless they separately engage our firm for a post-financial plan meeting or update to their initial written financial plan. plan meeting or update to their initial written financial plan. Item 14: Client Referrals & Other Compensation Item 14: Client Referrals & Other Compensation Schwab & Interactive Brokers Schwab & Interactive Brokers Our firm receives economic benefit from the Custodians in the form of the support products and services Our firm receives economic benefit from the Custodians in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain made available to our firm and other independent investment advisors that have their clients maintain accounts with the Custodians. These products and services, how they benefit out firm, and the related accounts with the Custodians. These products and services, how they benefit out firm, and the related conflicts of interest are described above (see Item 12 — Brokerage Practices). The availability of the conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of the Custodians' products and services are not based on our firm giving particular investment advice, such as Custodians’ products and services are not based on our firm giving particular investment advice, such as buying particular securities for our clients. buying particular securities for our clients. Referral Fees Received Referral Fees Received In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm may provide cash or In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm may provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed dearly and prominently to referred prospective clients at the time of each information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm's relationship with such unaffiliated person. the referral resulting from our firm’s relationship with such unaffiliated person. ADV Part 2A – Firm Brochure ADV Part 2A— Firm Brochure Page 13 Page 13 RHS Financial, LLC RHS Financial, LLC  In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm's solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. responsibility. Item 15: Custody Item 15: Custody Our firm does not maintain physical custody of client assets (which are maintained by a qualified Our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), however we are deemed to have custody of certain client assets if given custodian, as discussed above), however we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as described below under "Third Party Money the authority to withdraw assets from client accounts, as described below under “Third Party Money Movement." All our clients receive account statements directly from their qualified custodian(s) at least Movement.” All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. If our quarterly upon opening of an account. We urge our clients to carefully review these statements. If our firm decides to send its own account statements to clients, such statements will include a legend that firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those recommends the client compare the account statements received from the qualified custodian with those received from our firm. received from our firm. Third Party Money Movement: Third Party Money Movement: The SEC issued a no-action letter ("Letter") with respect to the Rule 206(4)-2 ("Custody Rule") under the The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 ("Advisers Act"). The letter provided guidance on the Custody Rule as Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction ("SLOA") is deemed to have custody. As such, our firm has adopted the standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: following safeguards in conjunction with our custodians:  The client provides an instruction to the qualified custodian, in writing, that includes the client’s The client provides an instruction to the qualified custodian, in writing, that includes the client's • signature, the third party's name, and either the third party's address or the third party's account signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. number at a custodian to which the transfer should be directed.  The client authorizes the investment adviser, in writing, either on the qualified custodian’s form • The client authorizes the investment adviser, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to or separately, to direct transfers to the third party either on a specified schedule or from time to time. time.  The client’s qualified custodian performs appropriate verification of the instruction, such as a • The client's qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization and provides a transfer of signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. funds notice to the client promptly after each transfer.  The client can terminate or change the instruction to the client’s qualified custodian. • The client can terminate or change the instruction to the client's qualified custodian.  The investment adviser has no authority or ability to designate or change the identity of the third The investment adviser has no authority or ability to designate or change the identity of the third • party, the address, or any other information about the third party contained in the client's party, the address, or any other information about the third party contained in the client’s instruction. instruction.  The investment adviser maintains records showing that the third party is not a related party of The investment adviser maintains records showing that the third party is not a related party of • the investment adviser or located at the same address as the investment adviser. the investment adviser or located at the same address as the investment adviser.  The client’s qualified custodian sends the client, in writing, an initial notice confirming the The client's qualified custodian sends the client, in writing, an initial notice confirming the • instruction and an annual notice reconfirming the instruction. instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Item 16: Investment Discretion RHS Financial maintains full discretion under a limited power of attorney as to the securities and amount RHS Financial maintains full discretion under a limited power of attorney as to the securities and amount of securities. In all cases, however, such discretion is to be exercised in a manner consistent with the of securities. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. stated investment objectives for the particular client account. ADV Part 2A – Firm Brochure ADV Part 2A — Firm Brochure Page 14 Page 14 RHS Financial, LLC RHS Financial, LLC  RHS Financial will not have authority to withdraw funds or to take custody of client funds or securities, RHS Financial will not have authority to withdraw funds or to take custody of client funds or securities, other than under the terms of the Fee Payment Authorization clause in the Agreement with the client. other than under the terms of the Fee Payment Authorization clause in the Agreement with the client. RHS Financial does have the ability to discount brokerage commissions. RHS Financial does have the ability to discount brokerage commissions. Item 17: Voting Client Securities Item 17: Voting Client Securities RHS Financial does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive RHS Financial does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Questions about proxies may be made via the contact proxy materials directly from the custodian. Questions about proxies may be made via the contact information on the cover page. information on the cover page. Item 18: Financial Information Item 18: Financial Information An investment advisor must provide financial information if a threshold of fee prepayments is met; there An investment advisor must provide financial information if a threshold of fee prepayments is met; there is a financial condition likely to impair the ability to meet contractual commitments; or, a bankruptcy is a financial condition likely to impair the ability to meet contractual commitments; or, a bankruptcy within the past ten years. RHS Financial does not have any disclosure items in this section. within the past ten years. RHS Financial does not have any disclosure items in this section. ADV Part 2A – Firm Brochure ADV Part 2A- Finn Brochure Page 15 Page 15 RHS Financial, LLC RHS Financial, LLC 

Item 1: Cover Page Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement Part 2B of Form ADV: Brochure Supplement March 23, 2026 March 23, 2026 Colby Davis Grotem Colby Davis Grotem Nom FINANCIAL INVEST WITH PURPOSE' RHS Financial, LLC RHS Financial, LLC 4171 24th Street, Ste 101 4171 24th Street, Ste 101 San Francisco, CA 94114 San Francisco, CA 94114 www.rhsfinancial.com www.rhsfinancial.com Firm Contact: Firm Contact: Risley Sams Risley Sams Chief Compliance Officer Chief Compliance Officer This brochure supplement provides information about Colby Davis that supplements our brochure. You This brochure supplement provides information about Colby Davis that supplements our brochure. You should have received a copy of that brochure. Please contact Risley Sams if you did not receive RHS should have received a copy of that brochure. Please contact Risley Sams if you did not receive RHS Financial, LLC's brochure or if you have any questions about the contents of this supplement. Additional Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Colby Davis is available on the SEC's website at www.adviserinfo.sec.gov by searching information about Colby Davis is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #6452013. CRD #6452013. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2 /14/2024 Page 1 Page 1 RHS Financial, LLC RHS Financial, LLC  Item 2: Educational Background & Business Experience Item 2: Educational Background & Business Experience Colby Davis Grotem Colby Davis Grotem Year of Birth:1985 Year of Birth: 1985 Educational Background: Educational Background:  2009: University of Washington; Bachelor of Arts in Economics • 2009: University of Washington; Bachelor of Arts in Economics  2007: Highline Community College; A.A. 2007: Highline Community College; A.A. • Business Background: Business Background: RHS Financial, LLC; Portfolio Manager & Investment Adviser RHS Financial, LLC; Portfolio Manager & Investment Adviser  04/2015 – Present • 04/2015 —Present Representative Representative  08/2012 – 04/2015 08/2012 -04/2015 •  01/2012 – 08/2012 • 01/2012 -08/2012 RHS Financial, LLC; Investment Analyst RHS Financial, LLC; Investment Analyst Clean Power Finance; Analyst Clean Power Finance; Analyst Exams, Licenses & Other Professional Designations: Exams, Licenses & Other Professional Designations:  2019: Series 3 Exam 2019: Series 3 Exam •  2016: Chartered Financial Analyst, CFA® • 2016: Chartered Financial Analyst, CFA®  2015: Series 65 Exam 2015: Series 65 Exam • Chartered Financial Analyst, CFA® Chartered Financial Analyst, CFA® The CFA® charter is a globally respected, graduate-level investment credential established in 1962 and The CFA® charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA® Institute — the largest global association of investment professionals. To earn the CFA® awarded by CFA® Institute — the largest global association of investment professionals. To earn the CFA® charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA® Institute as members; and 4) commit to abide qualified professional investment experience; 3) join CFA® Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA® Institute Code of Ethics and Standards of by, and annually reaffirm, their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. The CFA® Program curriculum is updated every year by experts from around the Professional Conduct. The CFA® Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflectthe dynamic and complex nature of the profession. To learn more and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA® charter, visit www.CFAinstitute.org. about the CFA® charter, visit www.CFAinstitute.org. Item 3: Disciplinary Information Item 3: Disciplinary Information There are no legal or disciplinary events material to the evaluation of Colby Davis. There are no legal or disciplinary events material to the evaluation of Colby Davis. Item 4: Other Business Activities Item 4: Other Business Activities Mr. Davis does not have any outside business activities to report. Mr. Davis does not have any outside business activities to report. Item 5: Additional Compensation Item 5: Additional Compensation Colby Davis does not receive any other economic benefit for providing advisory services in addition to Colby Davis does not receive any other economic benefit for providing advisory services in addition to advisory fees. advisory fees. Item 6: Supervision Item 6: Supervision Risley Sams, Managing Member and Chief Compliance Officer of RHS Financial, LLC, supervises and Risley Sams, Managing Member and Chief Compliance Officer of RHS Financial, LLC, supervises and monitors Colby Davis' activities on a regular basis to ensure compliance with our firm's Code of Ethics. monitors Colby Davis’ activities on a regular basis to ensure compliance with our firm’s Code of Ethics. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2 /14/2 024 Page 2 Page 2 RHS Financial, LLC RHS Financial, LLC  Please contact Risley Sams if you have any questions about Colby Davis’ brochure supplement at (415) Please contact Risley Sams if you have any questions about Colby Davis' brochure supplement at (415) 495-2900. 495-2900. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2/14/2024 Page 3 Page 3 RHS Financial, LLC RHS Financial, LLC 

Item 1: Cover Page Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement Part 2B of Form ADV: Brochure Supplement March 23, 2026 March 23, 2026 Risley Sams Risley Sams Nom FINANCIAL INVEST WITH PURPOSE' RHS Financial, LLC RHS Financial, LLC 4171 24th Street, Ste 101 4171 24th Street, Ste 101 San Francisco, CA 94114 San Francisco, CA 94114 www.rhsfinancial.com www.rhsfinancial.com Firm Contact: Firm Contact: Risley Sams Risley Sams Chief Compliance Officer Chief Compliance Officer This brochure supplement provides information about Risley Sams that supplements our brochure. You This brochure supplement provides information about Risley Sams that supplements our brochure. You should have received a copy of that brochure. Please contact Risley Sams if you did not receive RHS should have received a copy of that brochure. Please contact Risley Sams if you did not receive RHS Financial, LLC's brochure or if you have any questions about the contents of this supplement. Additional Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Risley Sams is available on the SEC's website at www.adviserinfo.sec.gov by searching information about Risley Sams is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #4572447. CRD #4572447. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2 /14/2024 Page 1 Page 1 RHS Financial, LLC RHS Financial, LLC  Item 2: Educational Background & Business Experience Item 2: Educational Background & Business Experience Risley Sams, CFP®, CPWA® M.B.A. Risley Sams, CFP®, CPWA® M.B.A. Year of Birth: 1969 Year of Birth: 1969 Educational Background: Educational Background:  2007: College of Financial Planning; CFP ® 2007 • 2007: College of Financial Planning; CFP ® 2007  2002: Purdue University; Krannert School of Business; MBA 2002: Purdue University; Krannert School of Business; MBA •  1993: California State University, Chico; B.S. Business Administration, Minor in Music • 1993: California State University, Chico; B.S. Business Administration, Minor in Music Business Background: Business Background:  2009 – Present • 2009 — Present  2008 – 2009 • 2008 -2009  2007 – 2008 2007 -2008 •  2002 – 2007 2002 -2007 • RHS Financial, LLC; RHS Financial, LLC; Managing Member and Chief Compliance Officer Managing Member and Chief Compliance Officer Merrill Lynch; Senior Financial Advisor Merrill Lynch; Senior Financial Advisor Bear Stearns; Vice President Bear Stearns; Vice President Smith Barney; Financial Advisor Smith Barney; Financial Advisor Exams, Licenses & Other Professional Designations: Exams, Licenses & Other Professional Designations:  2018: Certified Private Wealth Advisor, CPWA® • 2018: Certified Private Wealth Advisor, CPWA®  2007: CERTIFIED FINANCIAL PLANNER™, CFP® • 2007: CERTIFIED FINANCIAL PLANNER-, CFP''  2006: Series 31 Exam • 2006: Series 31 Exam  2002: Series 7, 63 and 66 2002: Series 7, 63 and 66 • Certified Private Wealth Advisor, CPWA® Certified Private Wealth Advisor, CPWA® The CPWA® designation signifies that an individual has met initial and on-going experience, ethical, The CPWA® designation signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for the professional designation, which is centered on private education, and examination requirements for the professional designation, which is centered on private wealth management topics and strategies for high-net-worth clients. The designation is administered wealth management topics and strategies for high-net-worth clients. The designation is administered through Investment Management Consultants Association ("IMCA"). Prerequisites for the CPWA® through Investment Management Consultants Association (“IMCA”). Prerequisites for the CPWA® designation are a Bachelor's degree from an accredited college or university or one of the following designation are a Bachelor’s degree from an accredited college or university or one of the following designations or licenses: LIMA®, CIMC®, CFA®, CFP®, ChFC®, or CPA license; have an acceptable regulatory designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC®, or CPA license; have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements and five years of professional history as evidenced by FINRA Form U-4 or other regulatory requirements and five years of professional client-centered experience in financial services or a related industry. CPWA® designees have completed a client-centered experience in financial services or a related industry. CPWA® designees have completed a rigorous educational process that includes self-study requirements, an in-class education component, and rigorous educational process that includes self-study requirements, an in-class education component, and successful completion of a comprehensive examination. CPWA® designees are required to adhere to successful completion of a comprehensive examination. CPWA® designees are required to adhere to IMCA's Code of Professional Responsibility and Rules and Guidelines for Use of the Marks. CPWA® IMCA’s Code of Professional Responsibility and Rules and Guidelines for Use of the Marks. CPWA® designees must report 40 hours of continuing education credits, including two ethics hours, every 2 years designees must report 40 hours of continuing education credits, including two ethics hours, every 2 years to maintain the certification. to maintain the certification. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks The CERTIFIED FINANCIAL PLANNER'", CFP° and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by (collectively, the "CFP' marks") are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Certified Financial Planner Board of Standards, Inc. ("CFP Board"). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial The CFP° certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries planners to hold CFP' certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2 /14/2 024 Page 2 Page 2 RHS Financial, LLC RHS Financial, LLC  and (3) ethical requirements that govern professional engagements with clients. Currently, more than and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United States. 62,000 individuals have obtained CFP' certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following To attain the right to use the CFP marks, an individual must satisfactorily fulfill the following requirements: requirements:  Education – Complete an advanced college-level course of study addressing the financial planning • Education —Complete an advanced college-level course of study addressingthe financial planning subject areas that CFP Board's studies have determined as necessary for the competent and subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor's Degree from a professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board's financial planning subject areas include insurance planning and risk university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; planning, and estate planning;  Examination – Pass the comprehensive CFP® Certification Examination. The examination, • Examination — Pass the comprehensive CFP° Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one's ability to correctly diagnose financial planning issues and apply one's designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; knowledge of financial planning to real world circumstances;  Experience – Complete at least three years of full-time financial planning-related experience (or • Experience — Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and the equivalent, measured as 2,000 hours per year); and  Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents • Ethics —Agree to be bound by CFP Board's Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. outlining the ethical and practice standards for CFP' professionals. Individuals who become certified must complete the following ongoing education and ethics Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: requirements in order to maintain the right to continue to use the CFP' marks:  Continuing Education – Complete 30 hours of continuing education hours every two years, • Continuing Education — Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; Conduct, to maintain competence and keep up with developments in the financial planning field; and and  Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The • Ethics — Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a Standards prominently require that CFP' professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services fiduciary standard of care. This means CFP' professionals must provide financial planning services in the best interests of their clients. in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP CFP' professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® Board's enforcement process, which could result in suspension or permanent revocation of their CFP certification. certification. Item 3: Disciplinary Information Item 3: Disciplinary Information There are no legal or disciplinary events material to the evaluation of Risley Sams. There are no legal or disciplinary events material to the evaluation of Risley Sams. Item 4: Other Business Activities Item 4: Other Business Activities Mr. Sams does not have any outside business activities to report. Mr. Sams does not have any outside business activities to report. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2 /14/2 024 Page 3 Page 3 RHS Financial, LLC RHS Financial, LLC  Item 5: Additional Compensation Item 5: Additional Compensation Risley Sams does not receive any other economic benefit for providing advisory services in addition to Risley Sams does not receive any other economic benefit for providing advisory services in addition to advisory fees. advisory fees. Item 6: Supervision Item 6: Supervision Risley Sams, Managing Member and Chief Compliance Officer of RHS Financial, LLC, and as such has no Risley Sams, Managing Member and Chief Compliance Officer of RHS Financial, LLC, and as such has no internal supervision placed over him. He is, however, bound by our firm's Code of Ethics. internal supervision placed over him. He is, however, bound by our firm’s Code of Ethics. ADV Part 2B – Brochure Supplement 2/14/2024 ADV Part 2B - Brochure Supplement 2/14/2024 Page 4 Page 4 RHS Financial, LLC RHS Financial, LLC