RIDGEPATH CAPITAL MANAGEMENT LLC

Ridgepath Capital Management, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Ridgepath Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (865) 240- 4984 or by email at: sampressley7@gmail.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. Additional information about Ridgepath Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Ridgepath Capital Management, LLC’s CRD number is: 283343. 9202 S. Northshore, Suite 301 Knoxville, TN 37922 (865) 240-4984 spressley@ridgepathcapital.com https://www.ridgepathcapital.com Registration does not imply a certain level of skill or training. Version Date: 02/03/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Ridgepath Capital Management, LLC on 01/15/2025 are described below. Material changes relate to Ridgepath Capital Management, LLC’s policies, practices or conflicts of interests only. • Ridgepath Capital Management, LLC has updated its assets under management. (Item 4.E) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................................................................................... ii Item 3: Table of Contents ......................................................................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................................................................... 2 A. Description of the Advisory Firm................................................................................................................................................................... 2 B. Types of Advisory Services.............................................................................................................................................................................. 2 C. Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 3 D. Wrap Fee Programs .......................................................................................................................................................................................... 3 E. Assets Under Management .............................................................................................................................................................................. 3 Item 5: Fees and Compensation ................................................................................................................................................................................ 4 A. Fee Schedule ...................................................................................................................................................................................................... 4 B. Payment of Fees................................................................................................................................................................................................. 5 C. Client Responsibility For Third Party Fees .................................................................................................................................................... 5 D. Prepayment of Fees .......................................................................................................................................................................................... 5 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................................ 5 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................ 6 Item 7: Types of Clients ............................................................................................................................................................................................. 6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................................................... 6 A. Methods of Analysis and Investment Strategies .......................................................................................................................................... 6 B. Material Risks Involved.................................................................................................................................................................................... 7 C. Risks of Specific Securities Utilized ................................................................................................................................................................ 8 Item 9: Disciplinary Information ............................................................................................................................................................................ 10 A. Criminal or Civil Actions............................................................................................................................................................................... 10 B. Administrative Proceedings .......................................................................................................................................................................... 10 C. Self-regulatory Organization (SRO) Proceedings ....................................................................................................................................... 10 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................. 10 A. Registration as a Broker/Dealer or Broker/Dealer Representative ......................................................................................................... 10 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .......................... 10 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .................................................... 10 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .......................................... 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................... 11 A. Code of Ethics ................................................................................................................................................................................................. 11 B. Recommendations Involving Material Financial Interests ........................................................................................................................ 11 C. Investing Personal Money in the Same Securities as Clients .................................................................................................................... 11 D. Trading Securities At/Around the Same Time as Clients’ Securities ...................................................................................................... 11 iii  Item 12: Brokerage Practices.................................................................................................................................................................................... 12 A. Factors Used to Select Custodians and/or Broker/Dealers ...................................................................................................................... 12 1. Research and Other Soft-Dollar Benefits ................................................................................................................................................. 12 2. Brokerage for Client Referrals ................................................................................................................................................................... 12 3. Clients Directing Which Broker/Dealer/Custodian to Use ................................................................................................................. 13 B. Aggregating (Block) Trading for Multiple Client Accounts ...................................................................................................................... 13 Item 13: Review of Accounts ................................................................................................................................................................................... 13 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ....................................................................................... 13 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..................................................................................................... 13 C. Content and Frequency of Regular Reports Provided to Clients ............................................................................................................. 13 Item 14: Client Referrals and Other Compensation ............................................................................................................................................. 14 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ............... 14 B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................................................................ 15 Item 15: Custody ....................................................................................................................................................................................................... 15 Item 16: Investment Discretion ............................................................................................................................................................................... 15 Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................. 15 Item 18: Financial Information ................................................................................................................................................................................ 16 A. Balance Sheet ................................................................................................................................................................................................... 16 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................................ 16 C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................... 16 iv  Item 4: Advisory Business A. Description of the Advisory Firm Ridgepath Capital Management, LLC (hereinafter “RCML”) is a Limited Liability Company. The firm was formed in March 2016, and the principal owners are John Daniel Pressley and Samuel Nathan Pressley. B. Types of Advisory Services Portfolio Management Services RCML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RCML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring RCML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RCML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. RCML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RCML’s economic, investment or other financial interests. To meet its fiduciary obligations, RCML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RCML’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RCML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. 2  Selection of Other Advisers RCML may direct clients to third party investment advisers. Before selecting other advisers for clients, RCML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where RCML is recommending the adviser to clients. RCML may direct clients to Axxcess Wealth Management. Tax Preparation Services RCML offer tax preparation services based on the needs of the client. This service includes federal and state tax preparation and planning for individuals, trusts, estates, partnerships, and corporations. Services Limited to Specific Types of Investments RCML generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities or non-U.S. securities. RCML may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions RCML will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by RCML on behalf of the client. RCML may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RCML from properly servicing the client account, or if the restrictions would require RCML to deviate from its standard suite of services, RCML reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. RCML does not participate in any wrap fee programs. E. Assets Under Management RCML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 358,850,039.00 $ 0.00 December 2025 3  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $1,000,000 - $5,000,000 0.80% $5,000,001 - And Up 0.60% RCML uses the value of the account as of the last business day of the prior billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of RCML's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Selection of Other Advisers Fees RCML may direct clients to third-party investment advisers. RCML will be compensated via a fee share from the advisers to which it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. RCML may specifically direct clients to Axxcess Wealth Management (“Axxcess”). The annual fee schedule is as follows: Total Assets $1,000,000 – $5,000,000 $5,000,001 – and Up RCML’s Fee 0.80% 0.60% Axxcess’ Fee 0.05% 0.05% Total Fee 0.85% 0.65% Tax Preparation Service Fees Fees associated with this service are project costed based on the complexity of the tax return prepared. Consulting or planning fees are generally charged at $150 per hour. 4  B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Selection of Other Advisers Fees Fees are paid quarterly in advance. Fees for selection of Axxcess Wealth Management as third-party adviser are withdrawn by Axxcess Wealth Management directly from client accounts. RCML then receives its portion of the fees from Axxcess Wealth Management. RCML does not directly deduct the advisory fees. Payment of Tax Preparation Service Fees Payments are generally made by client in form or check in arrears. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by RCML. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees RCML collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither RCML nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. 5  Item 6: Performance-Based Fees and Side-By-Side Management RCML does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients RCML generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There is an account minimum of $1,000,000, which may be waived by RCML in its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis RCML’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Quantitative analysis or Technical analysis. Charting analysis involves the use of patterns in performance charts. RCML uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. 6  Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies RCML uses long term trading, short term trading or options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. 7  Investment Strategies RCML's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized RCML's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond 8  prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities- present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 9  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither RCML nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither RCML nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither RCML nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections RCML may direct clients to third-party investment advisers. RCML will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that RCML has an incentive to direct clients to the third-party investment advisers that 10  provide RCML with a larger fee split. RCML will always act in the best interests of the client, including when determining which third party investment adviser to recommend to clients. RCML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where RCML is recommending the adviser to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics RCML has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. RCML's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests RCML does not recommend that clients buy or sell any security in which a related person to RCML or RCML has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of RCML may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of RCML to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. RCML will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of RCML may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of RCML to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, RCML will never engage in 11  trading that operates to the client’s disadvantage if representatives of RCML buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on RCML’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and RCML may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in RCML's research efforts. RCML will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. RCML recommends clients use Charles Schwab & Co., Inc. Advisor Services, Elevation Securities, LLC, or Raymond James. 1. Research and Other Soft-Dollar Benefits While RCML has no formal soft dollars program in which soft dollars are used to pay for third party services, RCML may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). RCML may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and RCML does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. RCML benefits by not having to produce or pay for the research, products or services, and RCML will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that RCML’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals RCML receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 12  3. Clients Directing Which Broker/Dealer/Custodian to Use RCML will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If RCML buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, RCML would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. RCML would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for RCML's advisory services provided on an ongoing basis are reviewed at least quarterly by Samuel N Pressley, Managing and Founding Principal, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at RCML are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of RCML's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 13  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) RCML receives compensation from third-party advisers to which it directs clients. Charles Schwab & Co., Inc. Advisor Services provides RCML with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For RCML client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. information Charles Schwab & Co., Inc. Advisor Services also makes available to RCML other products and services that benefit RCML but may not benefit its clients’ accounts. These benefits may include national, regional or RCML specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of RCML by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist RCML in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of RCML’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of RCML’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to RCML other services intended to help RCML manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and 14  marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to RCML by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to RCML. RCML is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals RCML does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, RCML will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. RCML may also be deemed to have custody over the funds and securities of trust accounts for which it or its related persons serve as trustee. RCML may also be deemed to have custody over the funds and securities of trust accounts for which it or its related persons serve as trustee. Custody is also disclosed in Form ADV because RCML has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, RCML will follow the safeguards specified by the SEC rather than undergo an annual audit. Item 16: Investment Discretion RCML provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, RCML generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, RCML’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to RCML. Item 17: Voting Client Securities (Proxy Voting) RCML will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 15  Item 18: Financial Information A. Balance Sheet RCML neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients In light of the COVID-19 coronavirus and historic decline in market values, RCML has elected to participate in the CARES Act’s Paycheck Protection Program (“PPP”) to strengthen its balance sheet. RCML intends to use this loan predominantly to continue payroll for the firm and may ultimately seek loan forgiveness per the terms of the PPP. Due to this and other measures taken internally, RCML has been able to operate and continue serving its clients. C. Bankruptcy Petitions in Previous Ten Years RCML has not been the subject of a bankruptcy petition in the last ten years. 16