Riverstone Asset Management, LLC

Item 1 – Cover Page Riverstone Asset Management, LLC 2100 Gardiner Lane, Suite 207 Louisville, KY 40205 502-882-5580 June 23, 2026 This Brochure provides information about the qualifications and business practices of Riverstone Asset Management, LLC (“RAM’ or the “Firm”). If you have any questions about the contents of this Brochure, please contact us at 502-882-5580. 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. RAM is a registered investment adviser with the Securities and Exchange Commission. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about RAM is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for RAM is 161087. i  Item 2 – Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since the last annual update and provide clients with a summary of such changes. Our current Brochure has been updated as follows: • We have updated Item 1 Cover Page to indicate our registration with the Securities and Exchange Commission • We have updated Item 16 Investment Discretion to better describe our practices relating to trading authority. • We have removed Item 19-Requirements for State-Registered Advisers as Riverstone Asset Management is transitioning to registration with the Securities and Exchange Commission. • Updates have been made throughout the Brochure to adjust the use of the word “May” We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Jennifer Ringstaff, Chief Compliance Officer at 502-882-5580. (Brochure Date: 06/23/2026) (Last Annual Updating Amendment: 03/27/2026) ii  Item 3 – Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 – Table of Contents ........................................................................................................................... iii Item 4 – Advisory Business ........................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................. 3 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 5 Item 7 – Types of Clients ............................................................................................................................... 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 6 Item 9 – Disciplinary Information ................................................................................................................. 8 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 8 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .................................. 9 Item 12 – Brokerage Practices .................................................................................................................... 10 Item 13 – Review of Accounts..................................................................................................................... 11 Item 14 – Client Referrals and Other Compensation .................................................................................. 12 Item 15 – Custody ....................................................................................................................................... 13 Item 16 – Investment Discretion ................................................................................................................ 14 Item 17 – Voting Client Securities ............................................................................................................... 14 Item 18 – Financial Information .................................................................................................................. 14 Brochure Supplement (provided to clients) iii  Item 4 – Advisory Business RAM is owned by Louis T. Roth & Co. PLLC and has been providing investment advisory services since May 2012. As of December 31, 2025, RAM had $103,037,541 in discretionary assets under management, $0 in nondiscretionary assets under management, and $5,468,711 in assets under advisement. Investment Management Services: RAM manages investment portfolios for individuals (including high net worth individuals), qualified retirement plans, trusts, charitable organizations and small businesses. RAM will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. Investment and portfolio allocation software will as appropriate be used to evaluate alternative portfolio designs. RAM evaluates the client's existing investments with respect to the client's investment policy statement. The Firm works with new clients to develop a plan to transition from the client's existing portfolio to the desired portfolio. RAM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular progress meetings with the client regarding their account and other wealth management issues, as necessary. RAM will typically create a portfolio of no-load mutual funds, and will as appropriate use model portfolios if the models match the client's investment policy. RAM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The Firm primarily recommends portfolios consisting of no-load mutual funds offered by Dimensional Fund Advisors ("DFA"). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. RAM will as appropriate also utilize other passively managed mutual funds or exchange traded funds, including funds offered by Vanguard and Bridgeway. Client portfolios in certain instances will also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). RAM manages mutual fund and equity portfolios on a discretionary basis according to the investment policy selected by the client. A client may impose any reasonable restrictions on 1 RAM’s discretionary authority, including restrictions on the types of securities in which  RAM will as appropriate invest client’s assets and on specific securities, which the client may believe to be appropriate. RAM will as appropriate also recommend to advisory clients fixed income portfolios, which consist of managed accounts of laddered individual bond portfolios. The Firm will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. RAM will prepare a separate Fixed Income Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, RAM will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client's Fixed Income Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain the Firm’s consent prior to the sale of any client securities. RAM is available to answer clients' inquiries regarding their accounts and periodically review with clients the performance of their accounts at the clients’ request. The Firm will review with the client, no less than annually, each client's investment policy and risk profile, and discuss the re-balancing of each client's accounts to the extent appropriate. RAM will provide to the fixed income securities manager any updated client financial information or account restrictions necessary for the fixed income securities manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, RAM will as appropriate consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: For certain retirement plans, RAM also works in coordination and support with Focus Partners Advisor Solutions (f.k.a. Buckingham Strategic Partners). Retirement plan clients will engage both RAM and Focus Partners Advisor Solutions. Focus Partners Advisor Solutions will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made 2  available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. RAM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Item 5 – Fees and Compensation In certain circumstances, all fees, account minimums and their applications to family or other circumstances may be negotiable. Individual accounts for immediate family members (such as husband, wife and dependent children) are aggregated, and the fee is charged based on the total value of all family members’ accounts. RAM has contracted with Focus Partners Advisor Solutions for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. RAM has also contracted with Focus Partners Advisor Solutions for sub-advisory services with respect to clients’ fixed income accounts. RAM pays a fee for Focus Partners Advisor Solutions based on management fees paid to the Firm on accounts which use Focus Partners Advisor Solutions. The fee paid by RAM to Focus Partners Advisor Solutions consists of a portion of the fee paid by clients to RAM and varies based on the total client assets participating in Focus Partners Advisor Solutions through RAM. These fees are not separately charged to advisory clients. The fee charged by RAM to its clients includes all sub-advisory fees charged by Focus Partners Advisor Solutions. The specific manner in which fees are charged by RAM is established in a client’s written agreement with the Firm. Generally, Investment Management and Employee Benefit Plan clients will be invoiced in advance at the beginning of each calendar quarter based upon the value (market value based on independent third party sources or fair market value in the absence of market value; client account balances on which RAM calculates fees may vary from account custodial statements based on independent valuations and other accounting variances, including mechanisms for including accrued interest in account statements) of the client’s account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted or will not be billed until the next quarter. 3 For Investment Management and Employee Benefit Plan clients, RAM will request authority from the client to receive quarterly payments directly from the client's account held by an independent custodian. Clients may provide written limited authorization to  RAM or its designated service provider, Focus Partners Advisor Solutions, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit RAM’s fee and remit such fee to the Firm. A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days’ written notice. Upon termination of any account at any time after the required 30-day notice, any prepaid, unearned fees will be promptly refunded. RAM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients in certain circumstances will incur certain charges imposed by custodians, brokers, third party investments and other third parties such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds (ETFs) also charge internal management fees, which are disclosed in a fund’s prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to RAM for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. The services provided by RAM are designed, among other things, to assist the client in determining which mutual fund, ETF or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by RAM to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Such charges, fees and commissions are exclusive of and in addition to RAM’s fee, and the Firm shall not receive any portion of these commissions, fees and costs. Advisory Fees Fees may be negotiable based on family relations or individual circumstances including account size and the level and scope of the services requested. Employee and individual accounts for immediate family members (such as husband, wife and dependent children) are aggregated, and the fee is charged based on the total value of all family members’ accounts. Investment Management Services: 4 The annual fee for Investment Management Services will be charged as a percentage of assets under management, according to the schedule below:  Assets Under Management Annual Fee (%) On the first $500,000 On the next $500,000 On the next $1 million On the next $1 million On the next $2 million On all amounts thereafter 1.00% 0.90% 0.70% 0.50% 0.40% 0.35% Employee Benefit Retirement Plan Services: The annual fee for plan services will be charged as a percentage of assets within the plan. Total Fee Assets Under Management RAM’s Annual Fee Focus Partners Advisor Solutions’ Annual Fee 0.20% 0.15% 0.70% 0.45% 0.90% 0.60% 0.08% 0.25% 0.33% 0.05% 0.15% 0.20% On the first $1,000,000 On the next $4,000,000 On the next $5,000,000 On all amounts above $10,000,000 Item 6 – Performance-Based Fees and Side-By-Side Management RAM does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Item 7 – Types of Clients RAM offers services to individuals (including high net worth individuals), pension and profit-sharing plans, qualified retirement plans, trust, estates or charitable organizations or business entities. 5  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy RAM's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. RAM's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. RAM recommends diversified portfolios, principally through the use of passively managed, asset class mutual funds. The Firm selects or recommends to clients’ portfolios of securities, principally broadly-traded open end mutual funds or conservative fixed income securities to implement this investment strategy. Although all investments involve risk, RAM's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate, for particular clients the investment directly in conservative fixed income securities to represent the fixed income class. RAM's investment philosophy is designed for investors who desire a buy and hold strategy. The frequent trading of securities increases brokerage and other transaction costs that the Firm's strategy seeks to minimize. In the implementation of investment plans, RAM therefore primarily uses mutual funds and, as appropriate, portfolios of conservative fixed income securities. RAM will as appropriate also utilize Exchange Traded Funds (ETFs) to represent a market sector. Clients will as appropriate hold or retain other types of assets as well, and the Firm will as appropriate offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. RAM's strategies do not utilize securities that we believe would be classified as having any unusual risks, and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. RAM receives supporting research from Focus Partners Advisor Solutions and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). The Firm utilizes DFA mutual funds in client portfolios. DFA mutual funds follow a passive asset class investment philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to RAM. 6  Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, RAM relies on an analysis of the client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, RAM will as appropriate use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other methods used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • • • • The risk that expected future cash flows will not match those used in the analysis The risk that future rates of return will fall short of the estimates used in the simulation The risk that inflation will exceed the estimates used in the simulation For taxable clients, the risk that tax rates will be higher than was assumed in the analysis Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by RAM will as appropriate include funds invested in domestic and international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities. Equity securities will as appropriate include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. 7 Among the riskiest mutual funds used in RAM’s investment strategies are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities, or TIPS) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds.  Certain funds utilized by RAM will as appropriate contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. More information about the risks of any particular market sector can be reviewed in representative prospectuses for funds managing assets within each applicable sector. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of RAM or the integrity of RAM’s management. The Firm has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Affiliated Accounting Firm RAM is wholly owned by Louis T. Roth & Co., PLLC, an accounting firm. RAM personnel may also be Partners or employees of Louis T. Roth & Co., PLLC. Louis T. Roth & Co., PLLC may recommend RAM to accounting clients in need of advisory services. RAM may recommend Louis T. Roth & Co., PLLC to advisory clients in need of accounting or tax services. Accounting and tax services provided by Louis T. Roth & Co., PLLC are separate and distinct from the advisory services of RAM, and are provided for separate and typical compensation. No RAM client is obligated to use Louis T. Roth & Co., PLLC for any accounting services. Focus Partners Advisor Solutions 8 As described in Item 4, RAM will as appropriate exercise discretionary authority provided by a client to select an independent third-party investment manager for the management of portfolios of individual fixed income securities. RAM selects Focus Partners Advisor Solutions for such fixed income management. The Firm also contracts with Focus Partners Advisor Solutions for back office services and assistance with portfolio modeling. RAM has a fiduciary duty to select qualified and appropriate managers in the client’s best interest, and believes that Focus Partners Advisor Solutions effectively provides both the back office services that assist with its overall investment advisory practice and fixed income portfolio management services. The management of RAM continuously makes this assessment. While the Firm has a contract with Focus Partners Advisor Solutions governing a time  period for back office services, RAM has no such fixed commitment to the selection of Focus Partners Advisor Solutions for fixed income management services and will as appropriate select another investment manager for clients upon reasonable notice to Focus Partners Advisor Solutions. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading RAM has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. RAM's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth the Firm's practice of supervising the personal securities transactions of employees with access to client information. Individuals associated with RAM may buy or sell securities for their personal accounts identical or different than those recommended to clients. It is the expressed policy of the Firm that no person employed by the firm shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on investment decisions of advisory clients. To supervise compliance with its Code of Ethics, RAM requires that anyone associated with this advisory practice with access to advisory recommendations provide annual securities holding reports and quarterly transaction reports to the firm's Chief Compliance Officer. The Firm also requires such access persons to receive approval from the Chief Compliance Officer or a Principal prior to investing in any IPOs or private placements (limited offerings). RAM's Code of Ethics further includes the firm's policy prohibiting the use of material non- public information and protecting the confidentiality of client information. The Firm requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to discipline. RAM will provide a complete copy of its Code of Ethics to any client or prospective client upon request by contacting Jennifer Ringstaff, Chief Compliance Officer at 502-882-5580 9 It is RAM’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. RAM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction in certain circumstances will also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction  where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions in certain circumstances arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices RAM arranges for the execution of securities transactions with the assistance of Focus Partners Advisor Solutions. Through Focus Partners Advisor Solutions, RAM participates in the Schwab Advisor Services (SAS) program offered to independent investment advisers by Charles Schwab & Company, Inc. and the Fidelity Institutional Wealth Services (FIWS) program sponsored by Fidelity Brokerage Services LLC ('Fidelity'). Schwab and Fidelity are unaffiliated SEC-registered broker dealers and FINRA member broker dealers. Each offers to independent investment advisers, services, which include custody of securities, trade execution, clearance and settlement of transactions. The Schwab and Fidelity brokerage programs will generally be recommended to advisory clients for the execution of mutual fund and equity securities transactions. RAM regularly reviews these programs to ensure that its recommendations are consistent with its fiduciary duty. These trading platforms are essential to RAM’s service arrangements and capabilities, and the Firm may not accept clients who direct the use of other brokers. As part of these programs, RAM receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). As RAM will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid in these situations, clients must direct RAM as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that the Firm will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. RAM will not exercise authority to arrange client transactions in fixed income securities. Clients will provide this authority to a fixed income manager retained by RAM on each client’s behalf by designating the portfolio manager with trading authority over each client’s brokerage account. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of the portfolio manager. SAS and FIWS do not generally charge clients a custody fee and are compensated by 10 account holders through commissions or other transaction related fees for securities trades  that are executed through the broker or that settle into the clients’ accounts at the brokers. Trading client accounts through other brokers may result in fees (including mark-ups and mark-downs) being charged by the custodial broker or a custodian and an additional broker. The authority of the fixed income portfolio manager includes the ability to trade client fixed income assets through other brokers. RAM generally does not aggregate any client transactions in mutual fund or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which RAM arranges transactions. Focus Partners Advisor Solutions, in the management of fixed income portfolios, will aggregate certain transactions among client accounts that it manages, in which case a RAM client’s orders may be aggregated with an order for another client of Focus Partners Advisor Solutions who is not a RAM client. See Focus Partners Advisor Solutions Form ADV Part 2. RAM does not have any arrangements to compensate any broker dealer for client referrals. When trading client accounts, errors may periodically occur. RAM does not maintain any client trade error gains. The Firm makes client whole with respect to any trade error losses incurred by client and caused by RAM. Employee Benefit Retirement Plan Services: RAM does not arrange for the execution of securities transactions for participant directed plans utilizing Employee Benefit Retirement Plan Services. Transactions are executed directly through employee plan participation. Item 13 – Review of Accounts Reviews: Investment Management Services: Account assets are supervised on an ongoing basis, and formally reviewed no less than annually by Jennifer Ringstaff of RAM. The review process contains each of the following elements: 11 a. b. c. d. assessing client goals and objectives; evaluating the employed strategy(ies); monitoring the portfolio(s); and addressing the need to rebalance.  Additional account reviews may be triggered by any of the following events: a. b. c. d. a specific client request; a change in client goals and objectives; an imbalance in a portfolio asset allocation; and market/economic conditions. For fixed income portfolios, certain account review responsibilities are delegated to a third-party investment manager as described above in Item 4. Employee Benefit Retirement Plan Services: Retirement plan assets are reviewed no less than annually, and according to the standards and situations described above for investment management accounts. Reports: Investment Management Services and Employee Benefit Retirement Plan Services: All clients, other than those utilizing Employee Benefit Retirement Plan Services through a Retirement Plan Services Provider (RPSP), will receive quarterly performance reports, prepared by Focus Partners Advisor Solutions and reviewed by RAM. These quarterly reports summarize the client's account, asset allocation, portfolio performance, current positions, and current market value. Clients will also receive statements from account custodians. Clients utilizing Employee Benefit Retirement Plan Services will receive reporting services through their respective RPSPs. Plan sponsors are provided with quarterly information and annual performance reviews from a RPSP. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan. Item 14 – Client Referrals and Other Compensation Client Referrals RAM does not compensate, either directly or indirectly, any person (defined as a natural person or a company) for client referrals. Other Compensation 12  As indicated under the disclosure for Item 12, SAS provides RAM with access to services which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. products These services benefit RAM but may not benefit its clients' accounts. Many of the and services assist the Firm in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of RAM's fees from its clients’ accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally will as appropriate be used to service all or a substantial number of RAM's accounts. SAS also makes available to RAM other services intended to help the Firm manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. RAM does not, however, enter into any commitments with SAS for transaction levels in exchange for any services or products from SAS. While as a fiduciary, RAM endeavors to act in its clients’ best interests. The Firm's requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to RAM of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by SAS, which may create a potential conflict of interest. RAM also receives software from DFA, which the Firm utilizes in forming asset allocation strategies and producing performance reports. DFA also provides continuing education for RAM personnel. These services are designed to assist the Firm plan and design its services for business growth. Item 15 – Custody RAM does not have custody of client funds and securities. Investment Management and Employee Benefit Retirement Plan Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. RAM urges you to carefully review such statements and compare such official custodial records to the account statements that we provide to you, as appropriate. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 13  Item 16 – Investment Discretion RAM accepts discretionary authority to manage securities on your behalf when you sign the Wealth Advisory Agreement – Discretionary, which includes which securities and the amounts of securities are bought or sold on your behalf. For fixed income securities, this authority will include the discretion to retain a third-party money manager for fixed income accounts. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, RAM observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to RAM in writing. Item 17 – Voting Client Securities Proxy Voting: As a matter of firm policy and practice, RAM does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in clients’ investment portfolios. However, the Firm will as appropriate provide advice to clients regarding the clients’ voting of proxies. Class Actions, Bankruptcies and Other Legal Proceedings: Clients should note that RAM will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held or were previously held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct RAM to transmit copies of class action notices to the client or a third party. Upon such direction, the Firm will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information 14 Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about RAM’s financial condition. The Firm has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.