Richard G. Slater

Richard G. Slater Form ADV Part 2A – Disclosure Brochure Effective: June 30, 2026 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of the advisory firm, Richard G. Slater (“Slater” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (916) 835-4758. Slater is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information through Slater to assist you in determining whether to retain the Advisor. Additional information about Slater is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name (Richard G. Slater) or CRD# 112239. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Slater. For convenience, the Advisor has combined these documents into a single disclosure document. Slater believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Slater encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on January 23, 2026. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Slater. You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name (Richard G. Slater) or CRD# 112239. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (916) 835-4758. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 5 D. Wrap Fee Programs ....................................................................................................................................................... 5 E. Assets Under Management ............................................................................................................................................ 5 Item 5 – Fees and Compensation ......................................................................................................................... 5 A. Fees for Advisory Services ............................................................................................................................................. 6 B. Fee Billing ....................................................................................................................................................................... 6 C. Other Fees and Expenses .............................................................................................................................................. 6 D. Advance Payment of Fees and Termination .................................................................................................................. 7 E. Compensation for Sales of Securities ............................................................................................................................ 7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 7 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ....................................................................................................................................................... 8 B. Risk of Loss .................................................................................................................................................................... 8 Item 9 – Disciplinary Information ........................................................................................................................ 10 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10 A. Code of Ethics .............................................................................................................................................................. 10 B. Personal Trading with Material Interest ........................................................................................................................ 10 C. Personal Trading in Same Securities as Clients .......................................................................................................... 10 D. Personal Trading at Same Time as Client .................................................................................................................... 10 Item 12 – Brokerage Practices ............................................................................................................................ 11 A. Recommendation of Custodian[s] ................................................................................................................................ 11 B. Aggregating and Allocating Trades .............................................................................................................................. 11 Item 13 – Review of Accounts ............................................................................................................................. 11 A. Frequency of Reviews .................................................................................................................................................. 11 B. Causes for Reviews ...................................................................................................................................................... 12 C. Review Reports ............................................................................................................................................................ 12 Item 14 – Client Referrals and Other Compensation ........................................................................................ 12 A. Compensation Received by Slater ............................................................................................................................... 12 B. Compensation for Client Referrals ............................................................................................................................... 13 Item 15 – Custody ................................................................................................................................................ 13 Item 16 – Investment Discretion ......................................................................................................................... 13 Item 17 – Voting Client Securities ...................................................................................................................... 13 Item 18 – Financial Information .......................................................................................................................... 13 Form ADV Part 2B – Brochure Supplement ...................................................................................................... 14 Item 2 – Educational Background and Business Experience .......................................................................... 15 Item 3 – Disciplinary Information ........................................................................................................................ 15 Item 4 – Other Business Activities ..................................................................................................................... 15 Item 5 – Additional Compensation ..................................................................................................................... 15 Item 6 – Supervision ............................................................................................................................................ 15 Privacy Policy ....................................................................................................................................................... 16 Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 3  Item 4 – Advisory Services A. Firm Information Richard G. Slater (herein “Slater” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a sole proprietorship under the laws of the State of California. Slater was founded in July 1991, and is owned and operated by Richard G. Slater (hereinafter “Mr. Slater”). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by the Advisor and Mr. Slater. B. Advisory Services Offered Slater offers investment advisory services to individuals and high net worth individuals (each referred to as a “Client”). Investment advisory services generally include non-discretionary management of investment portfolios as well as comprehensive financial planning. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Slater’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Slater provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing non-discretionary investment management and consulting services. Slater works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Slater typically constructs portfolios with individual fixed income securities, but may also utilize exchange-traded funds (“ETFs”) as well as options to achieve the Client’s investment goals. The Advisor may also utilize other types of investments as necessary to meet the Client’s goals. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Slater’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Slater will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Slater evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. The Advisor may recommend employing cash positions as a possible hedge against market movement. Slater may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Slater accept or maintain custody of a Client’s funds or securities, except for the authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices and Item 15 – Custody. For implementation of investment recommendations, the Client shall approve each investment trade. Please see Item 16. Financial Planning Services Slater will provide financial planning either as part of its investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 4  Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Slater may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging Slater to provide investment management services, each Client is required to enter into an investment advisory agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Policy Statement – Slater, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Slater will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Slater will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Slater will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Slater does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Slater. E. Assets Under Management As of December 31, 2025, Slater manages $114,079,809 in Client assets, all of which are managed on a non- discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 5  A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees are based on the following tiered schedule: Assets Under Management Up to $100,000 $100,001 to $500,000 $500,001 to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $3,000,000 $3,000,001 to $10,000,000 $10,000,001 and over Annual Rate (%) 1.50% 1.20% 1.00% 0.75% 0.50% 0.40% negotiable The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may have a fee schedule that differs from the schedule above. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Slater will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Slater offers financial planning services on fixed fee basis. Fixed fees range up to $500 and are negotiable depending on the nature and complexity of each Client’s circumstances. An estimate for total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Slater at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Slater directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Additionally, the Advisor may invoice the Client directly. Financial Planning Services Financial planning fees may be invoiced up to a hundred percent (100%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Slater, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts, provided that the Client’s accounts meet the terms Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 6  and conditions of the Custodians brokerage requirements. However, the Custodian typically charge for mutual funds and other types of investments. The investment advisory fee charged by Slater is separate and distinct from these custody and securities execution fees. In addition, all fees paid to Slater for investment management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Slater, but would not receive the services provided by Slater which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Slater to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Slater is compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement with Slater, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s investment advisory agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Slater may require an advance deposit for financial planning services. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non- transferable without the Client’s prior consent. E. Compensation for Sales of Securities Slater does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Slater may offer a performance-based fee option to certain Clients. In such cases, Slater may receive a performance-based fee in addition to its investment advisory fees based upon any gains obtained in the accounts of “Qualified Clients” pursuant to the terms an investment advisory. Only Qualified Clients with either $1,400,000 under management with the Advisor or a net worth of $2,700,000 may be offered a performance-based fee option. The performance-based fee will be calculated at the close of the calendar quarter and deducted from Client accounts directly by the Custodian. The performance fee charged may be up to 2% of any gains in the Client account[s] for the quarter, subject to a high-water mark calculation. Only gains above the high-water mark shall be subject to the performance fee. The Advisor will receive the performance-based fee only to the extent that there are cumulative gains since the last performance fee calculation in the Client's account[s]. Performance fee may be negotiable at the discretion of the Advisor. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 7  Who is a “Qualified Client”? The Investment Advisers Act of 1940 (the “Advisers Act”), Rule 205-3(d)(1) defines a “Qualified Client” who is financially sophisticated and meets one or more of the following conditions: • Client is a natural person who, or a company that, immediately after entering into the contract has at least $1,400,000 under the management of the Advisor; • Client is a natural person who, or a company that, immediately prior to entering into the contract has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,700,000 at the time the contract is entered into. The receipt of a performance-based fee by certain Clients results in a potential conflict of interest, where the Advisor has the potential for higher compensation from a Client. Qualified Clients that are charged a performance fee may be offered a lower investment advisory fee. Slater does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Slater offers investment advisory services to individuals and high net worth individuals. Slater generally does not impose a minimum account size for establishing a relationship. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Slater primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Slater are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Slater generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Slater will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Slater may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Slater will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 8  indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Stocks Risks Stocks provide investors with an opportunity for capital appreciation and growth. The stocks of smaller companies tend to have the greatest potential for growth, but also the highest levels of risk or volatility. Larger company stocks have more moderate potential for both return and risk. Stocks have a variety of risks, including specific risk which is related to individual company developments, industry/sector risk, which is a function of broader economic factors affecting a company’s business, and market/systematic risk, which affects all stocks in a market and is the result of general investor sentiment and growth of the broader economy. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Leveraged and Inverse ETFs Leveraged and Inverse ETFs are not suitable for all investors and should be utilized only by sophisticated investors who understand leverage risk, consequences of seeking daily leveraged investment results and intend to actively monitor and manage their investments. Leverage ETFs are not designed to track the underlying index over periods longer than one trading day. The use of leverage increases the level of investment risk. Leverage will magnify gains or losses on those investments. Inverse ETFs lose value when the underlying investments rise Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 9  in value. The investments have the risk of not meeting their stated daily investment objectives over a long-term period. The Advisor does not actively include these investments in Client portfolios. Certain Client may have legacy positions in these investments. The Advisor will work closely with the Client to determine whether to retain these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving the Advisor or Mr. Slater. Slater values the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider in which the Client engages. Information about the Advisor’s firm can be found on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name (Richard G. Slater) or CRD# 112239. Item 10 – Other Financial Industry Activities and Affiliations The sole business of the Advisor and Mr. Slater is to provide investment management services to its Clients. Neither Slater nor Mr. Slater are involved in other business endeavors. Slater does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Slater has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to the Advisor and Mr. Slater as its sole Advisory Person. The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Slater owes a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Slater to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (916) 835-4758. B. Personal Trading with Material Interest The Advisor and/or Mr. Slater may purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. The Advisor and/or Mr. Slater do not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. The Advisor and/or Mr. Slater do not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients The Advisor and/or Mr. Slater may purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information D. Personal Trading at Same Time as Client While the Advisor and/or Mr. Slater may purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are executed after trades in Client accounts have been entered. At no Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 10  time will the Advisor or Mr. Slater transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Slater does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the “Custodian”) to safeguard Client assets and authorize Slater to direct trades to the Custodian as agreed upon in the investment management agreement. Further, Slater does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by- trade basis. Where Slater does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Slater. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Slater may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation and/or the location of the Custodian’s offices. Slater will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Slater maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. For additional information, please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Slater does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, Slater may receive certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Slater does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Slater will place trades within the established account[s] at the Custodian. Further, all Client accounts are traded within their respective account[s], unless specifically authorized in writing by the Client. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Slater will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The Advisor does not aggregate Client trades when making purchases or sales for Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Mr. Slater (Owner and Chief Compliance Officer). Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 11  B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Slater if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance on an as needed basis. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Slater Slater is a fee-only advisory firm, who, in all circumstances, is compensated solely by the Client. Slater does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Participation in Institutional Advisor Platform Slater has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Slater. As a registered investment advisor participating on the Schwab Advisor Services platform, Slater receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from the Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Slater that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Slater believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 12  B. Compensation for Client Referrals Slater does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion Slater does not accept investment discretion over Client accounts. Slater will present all investment decisions to Clients for approval prior to executing any trades. Item 17 – Voting Client Securities Slater does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Slater, nor Mr. Slater have any adverse financial situations that would reasonably impair the ability of Slater to meet all obligations to its Clients. Neither Slater, nor Mr. Slater have been subject to a bankruptcy or financial compromise. Slater is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 13  Form ADV Part 2B – Brochure Supplement for Richard G. Slater Owner and Chief Compliance Officer Effective: June 30, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Richard G. Slater (CRD# 1525400) in addition to the information contained in the Advisor’s Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Slater Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (916) 835-4758. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 14  Item 2 – Educational Background and Business Experience Richard G. Slater is the Owner and Chief Compliance Officer of the Advisor. Mr. Slater, born in 1956, is dedicated to advising Clients of the Advisor. Mr. Slater attended the University of New Mexico in 1974 and Linfield College in 1975. In addition, Mr. Slater earned a Bachelor of Arts from Sacramento State University in 1985. Additional information regarding Mr. Slater’s employment history is included below. Employment History: Owner and Chief Compliance Officer, Richard G. Slater Broker, Merrill Lynch 07/1991 to Present 1986 to 1991 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Slater. Mr. Slater has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Slater. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Slater. Item 4 – Other Business Activities Mr. Slater is dedicated to the investment advisory activities of Slater’s Clients. Mr. Slater does not have any other business activities. Item 5 – Additional Compensation Mr. Slater is dedicated to the investment advisory activities of Slater’s Clients. Mr. Slater does not receive any additional forms of compensation. Item 6 – Supervision Mr. Slater serves as the Owner and Chief Compliance Officer of Slater. Mr. Slater can be reached at (916) 835- 4758. The Advisor has implemented a Code of Ethics an internal compliance document that guides adherence to fiduciary obligations to Clients of Slater. Further, Slater is subject to regulatory oversight by various agencies. These agencies require registration by Slater. As a registered entity, Slater is subject to examinations by regulators, which may be announced or unannounced. Slater is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 15  Privacy Policy Effective Date: June 30, 2026 Our Commitment to You Richard G. Slater (“Slater” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Slater (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Slater does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectlively implement its services. In the section below, we list some reasons we may share your personal information. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 16  Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes Slater does not disclose, and does not intend to disclose, personal information with non-afffiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Slater or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Slater does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (916) 835-4758. Richard G. Slater 901 51st Street, Sacramento, CA 95819 Phone: (916) 835-4758 http://theatobapproach.com Page 17