RMR WEALTH BUILDERS, INC.

ITEM 1: COVER PAGE ____________________________________________________________________________________________________ RMR WEALTH BUILDERS, INC. Form ADV Part 2A - Firm Brochure (CRD # 169005 / SEC # 801-80404) 111 Grove Street, Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 https://www.rmrwealth.com http://www.rmrwealthbuilders.com https://www.facebook.com/rmrwealth/ https://www.linkedin.com/company/rmr-wealth-builders-inc-/ https://www.linkedin.com/showcase/rmr-wealth-workforce-solutions-retirement/posts January 1, 2026 This Form ADV Part 2A Disclosure brochure (“brochure”) provides information about the qualifications and business practices of RMR Wealth Builders, Inc., an investment advisory firm registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this brochure's contents, please contact us at T: 201.836.2460 or compliance@rmrwealth.com. The information in this brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Registration does not imply any level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide information to determine whether to retain their services. This brochure is on file with the appropriate regulatory authorities, as federal and state regulations require. Additional information about RMR Wealth Builders, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in RMR Wealth Builders, Inc. or CRD # 169005. Results will provide you with all firm disclosure brochures.) 1  ITEM 2: MATERIAL CHANGES ____________________________________________________________________________________________________ In this item, RMR Wealth Builders, Inc. ("RMR" or "the Adviser") is required to summarize only those material changes made to this brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 31, 2025, we have made changes to the following brochure sections: Item 4: Advisory Business Assets Under Management As of December 31, 2025, RMR’s assets under continuous management total $2,885,624,988. The following represents client assets under management by account type: Account Type Assets Under Management “AUM” Discretionary Non-Discretionary Total $ 2,375,902,942 $ 509,722,046 $ 2,885,624,988 Please note that the provided amount includes assets that RMR manages as a sub-adviser, namely the PeakShares RMR Prime Equity ETF (“PRMR”), totaling $50,748,670. Digital Asset Management Services In September 2025, this section was updated to reflect that Digital Assets management services accounts are offered through Fidelity Digital Assets®, Fidelity Investments®’ Digital Asset platform, and are custodied with Fidelity Digital Asset Services, LLC. Portfolio Management Services In September 2025, this section was updated to reflect that Digital Asset management services clients will also maintain their assets with Fidelity Digital Assets®, Fidelity Investments®’ Digital Asset platform, and that these assets will be custodied with Fidelity Digital Asset Services, LLC. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred qualified custodians and custodial practices.) Registered Investment Company Sub-Advisory Services PeakShares, LLC RMR entered into a sub‑advisory relationship with PeakShares, LLC in December 2025 to provide discretionary portfolio management services to the PeakShares RMR Prime Equity ETF (“PRMR”), a registered investment company under the Investment Company Act of 1940, pursuant to a sub‑advisory agreement and related expense‑sharing and equity arrangements. These arrangements result in the provision of a new advisory service line and additional compensation and economic interests that present potential conflicts of interest, as further described in this brochure. (See Items 4, 5, 10, and 14 for additional information.) In this section, additional disclosures were added to help clients better understand the onboarding process for each advisory service. Item 5: Fees & Compensation Item 5 was updated to clarify fee structures, billing practices, and administrative fees. Portfolio Management Services Fees Additional disclosures were added to RMR’s portfolio management services fee structure and related billing practices to clarify the use of a single, flat, asset‑based advisory fee applied to managed accounts, the billing frequency and proration methodology, and the documentation of final fee terms in each client’s executed Investment Management Agreement (“Advisory Agreement” or “Agreement”). The section was further updated to reflect that RMR transitioned 2  from a tiered/blended fee schedule to a single flat‑rate advisory fee, which constitutes a material change to our fee methodology. Digital Asset Management Services Fees This item was updated to add information regarding our Digital Asset management services billing practices, including advisory fee calculation, advance billing, and the application of third‑party custodial and transaction‑related costs charged by Fidelity Digital Assets® or other third parties for Digital Asset custody, transaction execution, and related services, which are in addition to RMR’s advisory fees. Registered Investment Company Sub-Advisory Services Fees RMR added registered investment company sub‑advisory services as a new advisory service and provided further disclosures on this service option for consideration, including the way we are compensated at the fund level under sub‑advisory arrangements rather than directly by advisory clients. (See Item 5: Fees & Compensation for a complete description of advisory fees, billing practices, and additional costs associated with RMR’s advisory service offerings.) Item 7: Types of Clients In this section, we disclosed that RMR also provides advisory and sub‑advisory services to registered investment companies under the Investment Company Act of 1940, including exchange‑traded funds (“ETFs”). Item 8: Methods of Analysis, Investment Strategies, Types of Investments & Risk of Investment Loss This item was updated to clarify that Digital Asset custody is maintained with Fidelity Digital Asset Services, LLC, and to note that investment strategies implemented for registered investment companies are subject to the fund’s stated objectives, policies, and restrictions, which may differ from strategies used for advisory clients. Item 10: Other Financial Industry Activities & Affiliations This item was updated to disclose RMR’s registered investment company sub-advisory services relationship with PeakShares, LLC, including the existence of a non‑controlling economic interest, and to describe the related potential conflicts of interest. Item 12: Brokerage Practices This Item was updated to reflect Fidelity Digital Assets® as a platform solution for Digital Asset management services and to clarify brokerage practices applicable to registered investment companies advised by RMR. Full Brochure Availability At any time, we may amend this document to reflect changes in RMR’s business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary due to material changes, we will provide clients, either by electronic means or in hard copy, with a new brochure or a summary of material changes from the previously supplied document, with an offer to deliver a full brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "RMR Wealth Builders, Inc.” or CRD # 169005. The SEC's website also provides information about any RMR-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may also obtain a copy of this brochure free of charge by contacting us directly at T: 201.836.2460 or via email @ compliance@rmrwealth.com. 3  ITEM 3: TABLE OF CONTENTS ____________________________________________________________________________________________________ Item 1: Cover Page ................................................................................................................................................. 1 Item 2: Material Changes ........................................................................................................................................ 2 Item 3: Table of Contents ........................................................................................................................................ 4 Item 4: Advisory Business ....................................................................................................................................... 5 Item 5: Fees & Compensation ............................................................................................................................... 18 Item 6: Performance-Based Fees & Side-By-Side Management .......................................................................... 28 Item 7: Types of Clients ........................................................................................................................................ 29 Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss ................. 29 Item 9: Disciplinary Information ............................................................................................................................. 45 Item 10: Other Financial Industry Activities & Affiliations ...................................................................................... 45 Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading ............................... 48 Item 12: Brokerage Practices ................................................................................................................................ 49 Item 13: Reviews of Accounts ............................................................................................................................... 54 Item 14: Client Referrals & Other Compensation .................................................................................................. 57 Item 15: Custody ................................................................................................................................................... 58 Item 16: Investment Discretion .............................................................................................................................. 60 Item 17: Voting Client Securities ........................................................................................................................... 61 Item 18: Financial Information ............................................................................................................................... 62 Item 19: Requirement for State Registered Advisers ............................................................................................ 63 Item 20: Additional Information ............................................................................................................................. 63 4  ITEM 4: ADVISORY BUSINESS ____________________________________________________________________________________________________ Overview RMR Wealth Builders, Inc. (hereafter “RMR” or the “Adviser”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”), as amended. Founded in 1986 and incorporated in the State of New Jersey, the Adviser’s principal place of business is located at 111 Grove Street, Suite 203, Montclair, New Jersey. The Adviser maintains additional offices in AZ, CA, CT, FL, IL, MA, NY, PA, RI, and WY. For over 36 years, RMR, through its founding partners, has embraced the discipline and practice of aligning fiduciary standards and professional principles. The equal owners of the privately owned company are Ryan P. DeGrau (Chief Executive Officer), Douglas R. Roth (Co-Chairman), Joseph J. Russo (Co-Chairman), and Edward A. Majitenyi (President), who undertake all of the Adviser's significant strategic and administrative decisions. Their combined industry experience exceeds 100 years. (Please refer to each Principal’s Form ADV Part 2B brochure Supplement for additional details on their formal education and business background.) RMR acts as a fiduciary to its advisory clients, as defined under applicable federal and state securities laws. As a fiduciary, the Adviser owes clients a duty of loyalty and care and is required to act in good faith and in their best interests. In fulfilling these obligations, RMR seeks to identify, disclose, and address potential conflicts of interest and endeavors to avoid situations in which one client’s interests are placed ahead of another’s. As used in this brochure, the terms “we,” “our,” or “us” refer to RMR Wealth Builders, Inc. The terms “you,” “your,” and “client” refer to any client or prospective client of the firm. The term “Associated Persons” (or “Associates”) refers collectively to RMR’s Supervised Persons, as that term is defined under the Advisers Act, including the firm’s officers and directors (each a “Control Person”), employees, and investment professionals—namely, the firm’s Investment Advisor Representatives (“IARs”)—who, whether as employees or independent contractors, are subject to RMR’s supervision and control and are authorized to provide investment advice or advisory services on behalf of the Adviser. RMR’s investment advisory services are designed to help clients pursue their financial goals. Our IARs play a central role in establishing, maintaining, and managing each client relationship. Clients are introduced to RMR through these experienced IARs, and each advisory relationship is managed by one or more IARs registered with the firm. These investment professionals serve as the primary point of contact between RMR and its clients. IARs are required under applicable laws, rules, and firm policies to obtain appropriate licenses and complete required training to recommend specific investment products and services. Clients should be aware that an IAR may or may not be able to recommend certain services, investments, or models depending on the licenses held, training completed, or other regulatory limitations. Additionally, IARs may conduct advisory business and respond to client inquiries only in the state(s) in which they are properly registered or otherwise exempt from registration. (For additional information regarding the IARs providing advisory services, clients should refer to their investment professional’s Form ADV Part 2B brochure Supplement. This separate disclosure document is required to be delivered to clients before or at the inception of the advisory relationship, together with this Form ADV 2A brochure. Clients who did not receive these documents should contact their IAR or RMR’s Chief Compliance Officer at T: 201. 836.2460 or via email @ compliance@rmrwealth.com to request copies of these important disclosures.) RMR supports and maintains an open environment where its Associates and IARs have access to the technology, tools, products, and support we believe are necessary to achieve our goal of providing diverse, high-quality client services. Together with our preferred qualified custodian(s), we aim to deliver a white-glove approach to the resources, support, operations, technology, compliance, guidance, oversight, business development, investment selection, and platform access we make available to our Investment Professionals and clients. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred qualified custodians and custodial practices.) Non-Exclusive Relationship RMR's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Accordingly, since investment strategies and advice are tailored to each client's specific financial situation, the advice we provide to one client may differ from or conflict 5  with that for the same security or investment for another client. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations At the client's request, RMR may recommend the services of independent third‑party professionals for implementation or related purposes. Such professionals may include, but are not limited to, attorneys, accountants, insurance agents, or other specialists. These professionals are engaged directly by the client on an as‑needed basis, and clients are under no obligation to engage any recommended professional. Clients who elect to engage a recommended professional will enter into a separate agreement directly with the selected provider, governing the scope of services, fees, and other contractual terms. Unless otherwise disclosed, RMR is not a party to any such arrangement, does not share in any fees earned by the referred professional, and does not have the authority to accept clients on behalf of, or otherwise bind, any such professional. Each referred professional retains the sole discretion to accept or decline any client referral, for any reason or no reason. In selecting a third‑party professional, clients are responsible for reviewing and understanding the provider’s separate agreement, including all applicable fees and charges. Clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation made by RMR. RMR is not responsible for the acts, omissions, or services provided by any third‑party professional engaged by a client. Clients must resolve any disputes arising from their engagement of a recommended professional directly with the engaged provider. Client Responsibilities RMR’s advisory services depend on information provided by clients. The Adviser cannot adequately perform its contractual obligations or fulfill its fiduciary duties unless clients provide accurate, complete, and timely information regarding their financial circumstances, investment objectives, and needs. Clients are responsible for promptly providing requested information or documentation, notifying us of material changes, and otherwise fulfilling their obligations under their written contract. Regardless of whether a client has granted discretionary authority or retains final decision‑making authority, it is the client’s responsibility to ensure that their IAR has all information reasonably necessary to make appropriate recommendations and/or manage the account in the client’s best interest. Clients are responsible for promptly notifying RMR, in writing, of any material changes in circumstances, including changes to information previously provided that may affect account management, or if any prior disclosures become inaccurate. RMR and its IARs will generally rely on the accuracy of information furnished by the client or on the client’s behalf, without independent verification, and are not required to verify information received from clients or from other professionals, such as accountants or attorneys. Clients (or their successors or authorized representatives) must also promptly notify RMR, in writing, of any event that may affect the validity of the contract or RMR’s authority thereunder, including the dissolution, merger, termination, or bankruptcy of a client that is not a natural person. RMR reserves the right to decline or terminate an advisory engagement if a client willfully withholds, conceals, or refuses to provide information that RMR determines is material to the advisory services provided. Description of Advisory Services RMR is an investment management and financial planning firm; it does not sell advisory securities on a commission basis. RMR’s investment professionals emphasize personal client contact and interaction in providing individually tailored investment advice and advisory services, which include the following personalized asset‑allocation investment programs (“Program Services” or “Programs”) and other advisory services as described throughout this brochure: 6   Portfolio Management Services1 Traditional Portfolio Management Services Program - IAR Client Investment Portfolio Non-Wrap Fee Program (hereafter “CIP Program”) o - Wrap Fee Portfolio Management Services Programs IAR Client Investment Portfolio Wrap Fee Program (hereafter “CIP Wrap Fee Program”) o o Third-Party Manager Wrap Fee Program (hereafter “TPM Wrap Fee Program,” with RMR as investment adviser and the third-party manager as sub-adviser)  Annuity Management Services  Digital Asset Management Services  Financial Planning & Consulting Services - Single Engagement - Ongoing Planning Engagement  Retirement Plan Services  Registered Investment Company Sub-Advisory Services  Pontera Services  Educational Seminars & Workshops Services Establishing an Advisory Relationship RMR begins each advisory relationship with a suitability discovery process to evaluate the client’s financial circumstances, investment objectives, time horizon, and risk tolerance. This information is used to determine the appropriateness of the selected advisory service and to establish goals consistent with it. The Advisory Agreement RMR provides all investment advisory services pursuant to a single, comprehensive Investment Management Agreement (the “Advisory Agreement” or “Agreement”), which serves as the foundational contract and framework governing each client’s advisory relationship with the firm. The Advisory Agreement documents the client’s selected Program or services, the scope of services provided, and the duties and responsibilities of both parties. It reflects the client's responsibilities, any written restrictions imposed by the client, the limitations on the services, and the brokerage and custody arrangements applicable to the account. The Agreement describes advisory fee billing practices—including the fee formula, billing frequency, any exclusions, proration methods, and termination procedures—as well as the manner in which any prepaid fees are returned in accordance with regulatory requirements. The Agreement also records the client’s chosen investment authorization (discretionary or non‑discretionary) for RMR—and, where applicable, any independent third‑party manager (“TPM”), to exercise trading authority consistent with Item 16: Investment Discretion, and incorporates regulatory disclosures required under the Advisers Act, including the firm’s fiduciary obligations, conflicts of interest, trading practices, and RMR’s policies regarding proxy voting and class action matters. The Agreement also reflects the custodial arrangements applicable to each account. RMR does not maintain physical custody of client funds or securities, except for its limited authority to deduct advisory fees from client accounts, as disclosed herein. Independent, unaffiliated qualified custodians hold client assets. Clients receive the applicable custodial agreements and related account‑opening documentation in advance, either directly from the custodian or through the Advisory Agreement. (Refer to Item 12: Brokerage Practices and Item 15: Custody for additional information.) This single Agreement governs all advisory relationships offered by RMR and serves as the primary legal document for each client’s account. The client’s executed Agreement (and any applicable supplemental agreements) documents the decided terms of the advisory relationship. 1 Portfolio Management Services are offered to prospective and existing advisory clients with the option to make investment management services and transaction/commission costs available via a convenient single "wrap fee,” in conjunction with RMR as Wrap Fee Program Manager and Sponsor for the CIP and TPM Wrap Fee Programs. (Refer to RMR’s Form ADV Part 2A Appendix 1 - Wrap Fee Program brochure for further details.) 7  Certain service arrangements, including those involving TPMs, may require the client to enter into a separate agreement directly with the applicable TPM (and, where applicable, the TPM’s designated custodian) to grant the independent manager discretionary trading authority or to satisfy the manager’s operational or custodial requirements. Such agreements are distinct from the client’s Advisory Agreement with RMR. Any such agreements will be provided to clients in advance of engagement and are required only when mandated by a specific TPM Advisory services will commence only after the applicable Agreement(s) and documents have been fully executed. IARs may provide only those services and assess only those fees expressly authorized under the executed Agreement and consistent with the client’s stated objectives, limitations, and restrictions. Clients may engage RMR for additional services by executing the applicable supplemental or separate Agreement(s). Any amendments to an existing Agreement will be made in accordance with the amendment provisions set forth therein. (Refer to Item 5: Fees & Compensation for additional details.) Investment Policy Statement Following the completion of the discovery process, the suitability profile, and the execution of the client’s Agreement, when requested and appropriate in connection with the client’s investment management program, RMR may also prepare an Investment Policy Statement (“IPS”). The IPS reflects the client’s approved investment parameters and provides a framework for constructing a diversified portfolio aligned with the client’s long‑term objectives and risk considerations. The IPS is a guideline only; it is not a contract, does not amend the Advisory Agreement, and does not guarantee performance or outcomes. Clients remain responsible for reviewing and approving their IPS. The client’s IAR will then use the information obtained through this discovery process to recommend the portfolio management service that it believes is in the client’s best interest. Portfolio Management Services Advisory Services Programs As part of its portfolio management services, RMR utilizes several advisory services programs (“Programs”) and billing/management structures to assist in the construction and ongoing management of client investment accounts, where appropriate. After evaluating a client’s information—including investment objectives, risk tolerance, financial circumstances, the amount of assets to be managed, and, where applicable, the client’s IPS—clients are assigned to an appropriate risk profile and corresponding portfolio Program and strategy. RMR’s portfolio management services are designed to accommodate varying investment objectives and risk profiles while remaining consistent with each client’s overall financial circumstances, as documented in the Advisory Agreement. When constructing or customizing a client’s investment portfolio, an IAR may recommend one or more of RMR’s advisory Programs based on the client's individual circumstances. In such cases, the IAR may adjust asset allocations, investment selections, and holdings to align the selected Program with the client’s stated investment objectives, written restrictions, and other instructions. Clients may engage RMR through one of the following portfolio management programs, each of which may utilize model portfolios that we manage and/or sponsor as part of the investment management process: 1. CIP Program - CIP Non‑Wrap Fee Program - CIP Wrap Fee Program 2. TPM Wrap Fee Program Clients will indicate their selected advisory services Program and applicable billing or management arrangement directly within the Advisory Agreement. A more detailed description of each Program and the related advisory services follows: 8  CIP Program Under RMR’s CIP Program, IARs manage client portfolios—using model portfolio construction where appropriate—in accordance with each client’s stated investment objectives, risk tolerance, financial circumstances, and any reasonable investment restrictions agreed upon with the client. Program services are generally provided on a discretionary basis, subject to the terms of the client’s Advisory Agreement and, where applicable, their IPS. In this capacity, RMR supervises and directs investments in the client’s account consistent with the client’s objectives, limitations, and restrictions, and in accordance with its fiduciary obligations under the Advisers Act. Clients participating in the CIP Program may elect one of the following billing arrangements, as specified in their written Agreement. The scope of advisory services provided under the CIP Program does not change based on the selected billing option: CIP Non‑Wrap Fee Program - Clients who prefer a traditional advisory fee arrangement may participate in the CIP Program under a non‑wrap fee billing structure. Under this option, RMR charges an asset‑based advisory fee for portfolio management services, and transaction‑related charges (such as brokerage commissions and other custodial transaction costs) are assessed separately by the client’s qualified custodian. This arrangement is commonly referred to as a “non‑wrap fee” program. CIP Wrap Fee Program - Clients may alternatively elect to participate in the CIP Program under a wrap‑fee billing structure. Under this option, clients pay a single, asset‑based “wrap fee” or “Program fee” that covers RMR’s investment advisory services and certain transaction and execution costs charged by the custodian. Participation in a wrap‑fee arrangement may result in higher or lower overall costs than a non‑wrap fee arrangement, depending on factors such as trading activity, account size, and the services selected. (Note: Additional information regarding RMR’s wrap‑fee arrangements, including services, fees, expenses, and conflicts of interest, is provided in RMR’s Wrap Fee Program brochure (Form ADV Part 2A, Appendix 1), which is furnished to clients before or at the time of entering into a wrap‑fee agreement.) TPM Wrap Fee Program In addition to managing client portfolios directly through the CIP Program, RMR offers clients the option to engage independent third‑party portfolio managers (“TPMs”) to manage their accounts on a discretionary basis. Clients who elect this service participate in RMR’s TPM Wrap Fee Program. All TPM accounts are offered exclusively on a wrap‑fee basis. The wrap fee generally includes RMR’s advisory services, the TPM’s portfolio management fee, and applicable transaction‑execution costs. Portfolio management responsibility for TPM‑managed accounts rests with the selected TPM; RMR does not manage the underlying investments in TPM accounts. Instead, RMR’s role is generally limited to selecting, recommending, monitoring, and replacing TPMs, as appropriate. RMR conducts due diligence on TPMs before making them available to clients and maintains written agreements with approved TPMs to facilitate their participation in the program and support overall program administration. Certain TPMs may require clients to enter into additional, manager‑specific agreements to authorize discretionary management or to satisfy operational or custodial requirements. Minimum account sizes for TPMs generally range from $25,000 to $1,000,000, depending on the specific manager. A conflict of interest exists because RMR has a financial incentive to recommend wrap‑fee arrangements, including both RMR’s CIP Wrap Fee Program and the TPM Wrap Fee Program, over non‑wrap fee arrangements. In wrap‑fee accounts, RMR may pay certain transaction costs, thereby reducing the incentive to trade. In addition, TPMs are compensated through existing business arrangements with RMR. RMR seeks to address these conflicts through its fiduciary obligations, suitability and cost‑effectiveness analyses, ongoing monitoring of client accounts and TPM performance, and full and fair disclosure. Clients are encouraged to review RMR’s Wrap Fee Program brochure (Form ADV Part 2A, Appendix 1), which is provided to them before or at the time of entering into a Wrap Fee Program Agreement and is available upon request, for a detailed discussion of wrap‑fee services, fees, expenses, and related conflicts of interest. (Note: RMR’s advisory fees and billing 9  practices are described in greater detail in Item 5: Fees and Compensation and in the client’s executed Agreement. Clients should refer to these documents for complete information regarding the scope of services and applicable fees.) Annuity Management Services RMR offers annuity management services for a flat advisory fee not to exceed the guidelines reflected within the Adviser’s Disclosure brochure and IRS Private Letter Ruling Number 202104001. To participate in this service, following our customary interview, discussion and analysis process, clients will execute RMR’s “Annuity Management Services Agreement” to appoint RMR as Adviser and their appropriately licensed IAR to review, recommend and service their annuity contracts, including but not limited to Fixed, Variable, and Indexed annuities, and effect investment transactions believed to meet fiduciary, best interest, and impartial conduct standards for the annuity contract assets. RMR shall have the right to amend the provisions of the Annuity Management Services Agreement by modifying, rescinding, or adding a new provision upon thirty (30) days' written notice to the client. The client may amend the Agreement only with RMR’s express written consent. With this service, clients will authorize and appoint RMR and its IAR as attorneys and agents-in-fact for their annuity contract assets and grant full discretionary authority to buy, sell, or otherwise effect investment transactions for the assets in their name and annuity contract. Clients will authorize RMR to instruct the Insurance Company product provider holding each of their annuity contracts of focus to liquidate investments and mail or wire specific monies to the client’s address of record, or another pre- designated bank account, according to the client’s written instructions. At the Insurance Company product provider’s request, clients may also be required to execute additional documentation to grant this discretionary authority to RMR and their Investment Professional. For annuity contracts recommended or serviced that are subject to security buy, sell, or hold recommendations, investment allocations will be selected based on the available investments specified in the annuity contract issued by the Insurance Company. RMR will not maintain custody of any of the assets associated with the client’s annuities; the client, at all times, will retain complete ownership rights to all assets held in their Insurance Company annuity contract. However, clients should be aware that recommendations regarding annuity sub-account holdings of securities subject to RMR and IARs can involve potential conflicts of interest and may require the pre-approval of any broker-dealer with which RMR and its IAR are licensed or affiliated in any capacity. It is the client’s responsibility to have received, read, and understand all additional and other applicable fees and charges separately disclosed by the Insurance Company, any insurance-related entity, or unrelated third-party entities that provide services and receive compensation arising from or related to the annuity contracts recommended by RMR, which fee schedules and charges are provided directly to the client by the Insurance Company before or upon delivery of the Annuity Contract and are in addition to, separate, and distinct from RMR’s advisory Fees. (For example, the client may incur other charges imposed by the Insurance Company, including, but not limited to, mortality and expense (“M&E”) fees, annuity contract rider charges, and other expenses disclosed in the client’s Annuity Contract.) Digital Asset Management Services Digital Assets, a new technology that generally refers to assets issued and/or transferred using distributed ledger or blockchain technology (including virtual/cryptocurrencies, “coins,” and “tokens”), are recommended to clients, as appropriate, through RMR’s Digital Asset management services option. Clients wishing to participate in this service will execute RMR’s standard Advisory Agreement and a separate, additional contract, the “Digital Assets Management Agreement,” to authorize the activity, designating RMR as the investment adviser and their IAR. Due to the volatile nature of the Digital Assets market, clients are required to grant full discretionary authority under the Agreements to RMR and their IAR to execute transactions deemed in their best interest. The authorization will also allow RMR to assist them with account registration, provide access to the Adviser’s Portfolio recommendations to construct and manage a 10  customized Digital Assets investment portfolio, and execute transactions, as necessary, to strive to achieve the client’s investment objectives while observing any noted account restrictions. Additionally, it is essential to note that while the Digital Assets market is open 24/7, 365 days a year, RMR will be available to execute transactions between 9:30 a.m. and 4:30 p.m. Eastern time. Digital Assets accounts offered by RMR may incur additional charges, expenses, and miscellaneous fees in addition to the client's Annual Advisory and Administrative Fees. It is the client’s responsibility to have received, read, and understood all documents, including any additional fees and charges disclosed by their account custodian, which are separate and distinct from the RMR’s Advisory and Administrative Fees. (See Item 5: Fees & Compensation and Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Financial Planning & Consultation Services RMR offers financial planning and consulting services tailored to each client’s needs. These services vary based on the scope and depth of the planning areas addressed, the complexity of the analysis performed, the recommendations developed, and the nature of any written materials, reports, or presentations provided. In providing these advisory services, RMR may make assumptions regarding interest rates, inflation rates, and the performance of financial markets and the broader economy, and may rely, in part, on historical data and past trends. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Service scope, as determined between the client and IAR, is available via the following personalized options: 1. Single Engagement 2. Ongoing Planning Engagement A more detailed description of each service option follows: Single Engagement – Single Engagements for financial planning and consulting services are available to clients as either a Comprehensive Financial Plan or an à la carte menu of Financial Planning services offered by RMR. The à la carte menu of services available includes, but is not limited to, cash flow analysis, college planning, insurance and needs analysis review, investment review, tax planning, and estate planning. A Comprehensive Financial Plan will include, but not be limited to, each planning service offered on the à la carte menu by RMR. Clients also have the option to build their service package from the à la carte menu. The fee for providing services under a Single Engagement is based on the cost of the selected services from the available menu. RMR charges a flat fee for a Comprehensive Financial Plan. Ongoing Planning Engagement - Beyond a single engagement, we offer our clients the option of an Ongoing Planning Engagement. RMR has set a minimum asset on the platform threshold of $250,000, including ongoing planning services, which is negotiable. We also offer ongoing planning services for $1,500 annually or $150/month. Fees for continuing planning are negotiable. To participate in any of the financial planning or consulting options described above, clients will enter into a Financial Planning & Consulting Agreement that sets forth the terms and conditions of the engagement, including termination provisions, the scope of services to be provided, and the applicable fees. Fees are disclosed and agreed to before commencement of services, and the final fee structure is documented in the executed Financial Planning & Consulting Agreement. Depending on the scope of the engagement and the complexity of the planning or advice to be provided, financial planning and consulting services may take approximately one week to six months to complete. If services are not completed within six months, any unearned fees will be prorated and refunded to the client in accordance with the terms of the executed Financial Planning & Consulting Agreement. Financial plans are based on the client’s financial circumstances at the time the plan is presented and rely on financial information disclosed by the client to RMR at the time the agreement is executed. Because financial planning is a discovery process, circumstances may arise in which the client was unaware of certain financial exposures, obligations, or other relevant considerations at the outset of the engagement. If material information differs substantially from what was initially disclosed, 11  RMR will provide the client with a revised scope of services and fee for review and acceptance. The client must approve any increase in fees or modification of scope in advance, in writing, before additional work is performed. Additional reviews may be conducted at the client’s request, and written updates to the financial plan may be provided in connection with such reviews. Any subsequent or ongoing financial planning services require the execution of a new Financial Planning & Consulting Agreement. Updates to financial plans may be subject to additional fees, which the client must approve in writing prior to the commencement of further services. (See Item 5: Fees & Compensation for additional information.) As with all advisory services provided by RMR, clients are expected to promptly notify RMR in writing of any material changes in assets, liabilities, net worth, or planning objectives that RMR would not otherwise know. clients, or their successors, must also promptly notify RMR in writing of (1) the dissolution, termination, merger, or bankruptcy of the client if the client is not a natural person, and (2) the occurrence of any other event that may affect the validity of the executed agreement or RMR’s authority thereunder. RMR reserves the right to terminate financial planning and consulting engagement if, in its judgment, a client has willfully concealed or refused to provide material information necessary and appropriate for RMR to provide financial planning or consulting services. Clients should refer to their Financial Planning & Consulting Agreement for complete details regarding termination and related provisions. Financial planning and consulting services may be provided on a standalone basis. Entering into a Financial Planning & Consulting Agreement does not constitute - and does not require - the execution of a separate Advisory Agreement for investment advisory services, nor does it obligate the client to purchase any investment, insurance, or other financial products or services from RMR, any RMR IAR, or any third party. When providing financial planning or consulting services, neither RMR nor the client’s IAR will have discretionary investment authority. These services do not include the implementation or ongoing monitoring of recommendations provided to the client unless separately agreed to in writing. Written financial plans generally do not include analyses or recommendations regarding liability risk management, tax planning strategies, or tax preparation services. If such services are needed, clients are responsible for engaging appropriate third-party professionals. Clients are not obligated to act upon any recommendation provided through RMR’s financial planning or consulting services. If clients choose to implement recommendations, they may do so by executing transactions through any brokerage firm or service provider of their choosing. Retirement Plan Services As part of its portfolio management services, RMR also offers retirement plan services, including various levels of advisory and consulting services, investment due diligence, education, and other investment advisory services, provided to clients with employee benefit plans or other retirement accounts for a fee, as described herein. These services are designed to assist Plan sponsors in meeting their management and fiduciary obligations to Plan Participants under the Employee Retirement Income Security Act (“ERISA”). Under this service option, clients can participate in the following services: 1. Plan Fiduciary Education Services 2. Participant Education Services 3. Service Provider Search Support 4. Plan Design Support Services 5. Plan Operation Support 6. 7. Investment Adviser Services - 3(21) (i.e., IPS, investment selection, performance monitoring, reporting, and additional services as specified from time to time within the client’s Agreement.) Investment Manager - 3(38) (Investment Selection, performance monitoring and reporting, and additional services, if any, as specified from time to time within the client’s Agreement.) For retirement plan services, client assets remain held with the retirement plan’s custodian or trustee, as designated by the plan sponsor or Responsible Plan Fiduciary. RMR does not take custody of plan assets and provides advisory or fiduciary services 12  in accordance with ERISA and the applicable plan documents. Custodial relationships are disclosed to clients in advance. (Additional information regarding RMR’s brokerage practices and custodial arrangements is provided in Item 12: Brokerage Practices and Item 15: Custody.) RMR is considered a fiduciary under ERISA and regulations under the Internal Revenue Code of 1986. In this capacity, our status is that of an investment advisor registered under the Investment Advisers Act of 1940 and a fiduciary under ERISA Part 4, Title 1. In performing these services, RMR acts either as a non-discretionary fiduciary of the Plan, as defined in Section 3(21) of ERISA, or as a discretionary fiduciary of the Plan, as defined in Section 3(38) of ERISA. RMR is not subject to any disqualification under Section 411 of ERISA. In connection with such accounts and pursuant to adopted regulations of the U.S. Department of Labor (“DOL”), we are required to provide the plan’s Responsible Plan Fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) and clients with a written statement of the services we provide to the Plan, the compensation we receive, any conflicts of interests present, our status as an ERISA fiduciary, and the following notice: “When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, and the laws governing retirement accounts. How we are compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: 1. Meet a professional standard of care when making investment recommendations (give prudent advice). 2. Never put our financial interests ahead of yours when making recommendations (give loyal advice). 3. Avoid misleading statements about conflicts of interest, fees, and investments. 4. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. 5. Charge no more than is reasonable for our services. 6. Give you basic information about conflicts of interest. RMR benefits financially from the rollover of a client’s assets from a retirement account to an account that we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Our policy as a fiduciary is to recommend a client rollover of retirement assets only if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our firm.” Clients are not contractually or otherwise obligated to complete a rollover. If they elect to complete a rollover, they are not obligated to have their retirement assets managed by RMR. If a client or a prospective client receives a recommendation to leave their plan assets with their old employer, RMR will receive no compensation. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, RMR will have discretionary account Plan Fiduciaries who evidence their authority to retain our advisory services and to appoint us as an "Investment Manager" within the meaning of Section 3(38) of ERISA for those Plan assets that comprise the client's account. The Plan Fiduciary will confirm that RMR's Agreement services are consistent with Plan documents and furnish true and complete copies of all Plan governing documents. The Plan Fiduciary will provide us with a copy of all relevant documents requested, confirm, and agree that their selected advisory program is consistent with those documents, and will notify us, promptly in writing, of any changes to any of the Plan's investment policies, guidelines, restrictions, or other related documents regarding Plan investments. If the assets in the account constitute only a part of the Plan’s assets, the Plan Fiduciary will provide us with documentation of all Plan investment guidelines or policies that affect the account. Under ERISA requirements, the client will acknowledge that RMR has no responsibility for the overall diversification of the Plan's investments and no duty, accountability, or liability for any Plan asset that is not under RMR’s advisement. 13  The compliance of any recommendation or investment RMRs’ IARs with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. RMR is not responsible or liable for Plan administration or the performance of any other duties not expressly outlined in the Agreement. Further, the client must obtain and maintain, at their own expense, any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, and agents concerning RMR’s Agreement. Plan fiduciaries will promptly provide appropriate documents evidencing such coverage upon request. If ERISA or other applicable law requires bonding for the account's assets, RMR will ensure bonding is in place to satisfy the obligation to cover RMR and all Associates whose inclusion is expected by law. ERISA & Retirement Plans Special Disclosures In this brochure’s Section 5: Fees & Expenses, RMR has disclosed potential conflicts of interest, including receiving additional compensation from third parties (e.g., 12b-1 fees) for marketing, recordkeeping, or other services related to certain investments. RMR has adopted policies and procedures designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. (For example, RMR has taken several steps to address the potential conflict of interest of IARs, who receive compensation for services provided to ERISA Plans. First, an IAR negotiates the compensation with ERISA Plan sponsors or participants (“ERISA clients”), and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate.) As a covered service provider to ERISA plans, RMR will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). RMR does not allow IARs to provide advice or manage ERISA client assets if RMR believes there are conflicts of interest that it considers prohibited by ERISA. Thus, RMR’s practice is to disclose (1) direct compensation received from ERISA clients, (2) indirect compensation received from third parties, and (3) transaction-based compensation (i.e., commissions) or other similar compensation shared with related parties servicing ERISA plans. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending an ERISA client’s advisory service Agreement. RMR also provides participant and fiduciary education, vendor selection, reporting, and technology services support, and other non-investment-related assistance for ERISA, retirement, and other qualified account clients. Retirement Account Rollover Considerations Individual participants in corporate Plans advised by RMR who are retiring or changing jobs can request that RMR provide additional educational information on tax-free transfer options and the benefits of keeping assets in the Plan as long as they remain eligible. RMR will not solicit Plan Participants to retire or change jobs. For Plan Participants who decide to leave the Plan of their own accord due to retirement or a change in employer, we can be separately engaged to provide recommendations on the advisability of taking retirement Plan distributions. Any Plan Participant services that include discussions about individual distributions or how to invest distribution proceeds will be performed separately with the Plan Participant. In determining whether to make a retirement account rollover to RMR, Plan Participants and clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company Plans. Further, current employees can sometimes move assets from their company Plan before retiring or changing jobs. RMR will consider various factors before recommending retirement plan rollovers, including the investment options available in the Plan versus others available, the rollover options available, each individual's age, personal circumstances, investment options, Plan fees and expenses versus those of alternative account types, services, conflicts of interest, penalties, protections from creditors and legal judgments, required minimum distributions and employer stock tax consequences, the services and responsiveness of the Plan's Investment Professionals versus those of RMR, and employer stock tax consequences (if any), among others. 14  To the extent the following options are available, clients should carefully consider the costs and benefits of the following: Leaving the funds in the employer's/former employer's Plan.   Moving the funds to a new employer's retirement Plan.  Cashing out and taking a taxable distribution from the Plan.  Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for RMR to manage are encouraged to speak with their CPA or tax attorney before taking any action or making any changes. The following is also offered for your consideration before making a change: 1. Determine whether the investment options in your employer's retirement Plan address your needs or whether you might wish to consider other investment types: - - Employer retirement Plans generally have a more limited investment menu than IRAs. Employer retirement Plans may offer unique investment options, such as employer securities or previously closed funds, that are unavailable to the public. 2. Consider Plan fees & expenses - your current Plan may have lower fees than RMR’s. - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement Plan and how the share class costs compare with those available in an IRA. - You should understand the various products and services you might use with an IRA provider, along with their potential costs. 3. RMR’s strategy may involve greater risk than your Plan's option(s). 4. Your current Plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; this may vary by state. - Generally, federal law protects assets in qualified Plans from creditors. Since 2005, IRA assets have been largely protected from creditors in bankruptcy proceedings. However, there can be some exceptions to the usual rules, so consult an attorney about protecting retirement Plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your Plan, you may be able to liquidate those shares at a lower capital gains tax rate. 9. 10. Your Plan may allow you to hire RMR as the manager and keep the assets in the Plan name. Registered Investment Company Sub-Advisory Services RMR provides discretionary investment management services as a sub‑adviser to registered investment companies, including exchange‑traded funds (“ETFs”). Registered investment company sub-advisory services are provided pursuant to separate sub‑advisory agreements entered into with a fund’s primary investment adviser. They are governed by the fund’s prospectus and other governing documents, subject to oversight by the fund’s board of trustees. In this capacity, RMR manages all or a designated portion of a fund’s investment portfolio in accordance with the fund’s stated investment objectives, policies, and restrictions, and in compliance with the Investment Company Act of 1940 and related regulations. RMR’s role includes day‑to‑day portfolio management as specified in the applicable sub‑advisory agreement. Under this advisory service, fund assets are held by the fund’s independent custodian or in fund investor custodial accounts. Individual investors do not maintain custodial accounts with RMR, and RMR does not hold fund shareholders' assets in custody. Custody arrangements are disclosed in the applicable fund prospectus and other regulatory filings provided to investors. (See Item 10: Other Financial Industry Activities & Affiliations for potential conflicts of interest associated with RMR’s registered 15  investment company sub‑advisory relationships, including compensation arrangements and ownership interests. Additional information regarding RMR’s brokerage practices and custodial arrangements is provided in Item 12: Brokerage Practices and Item 15: Custody.) Pontera-Related Advisory Services RMR offers Pontera‑related advisory services to individual plan participants who independently engage RMR for investment advisory services with respect to certain employer‑sponsored retirement accounts and similar accounts, including, but not limited to, 401(k) plans, health savings accounts (“HSAs”), and other assets not maintained under RMR’s custody. Through the Pontera platform, RMR and its IARs are able, with client authorization, to obtain limited functional access to a client’s account to provide advisory services, including making investment recommendations and implementing discretionary allocation changes, solely among the investment options made available under the applicable plan. RMR does not have custody of client assets. Client accounts remain held with the plan’s recordkeeper or custodian. Custodial relationships are disclosed to clients in advance. (Additional information regarding RMR’s brokerage practices and custodial arrangements is provided in Item 12: Brokerage Practices and Item 15: Custody. Fee information applicable to Pontera‑related advisory services is disclosed in Item 5: Fees & Compensation.) RMR and its IARs are not affiliated with Pontera, and RMR does not receive compensation from Pontera in connection with its use of the platform. Clients who elect to receive Pontera‑related advisory services will establish their connection to the Pontera platform via a link provided directly to them. Once authorized, RMR and its IARs will have access to account information necessary to provide advisory services, including account allocations and available investment options. Accounts using the Pontera platform are reviewed at least annually, and available investment options are evaluated with each review to determine whether changes to account allocations are appropriate. This service is separate and distinct from RMR’s retirement plan services, pursuant to which RMR may act as an adviser or fiduciary to employer‑sponsored retirement plans. Under Pontera‑related advisory services, RMR provides investment advice directly to individual plan participants who engage the firm independently and does not provide advisory services to plan participants of retirement plans for which RMR or its IARs serve as the plan’s adviser of record. Educational Seminars & Workshops RMR provides investment education seminars and workshops, and may speak at community events and conferences on various investment‑related topics on an “as‑announced” basis for groups seeking general education on investments and other personal finance matters. Seminar and workshop content varies depending on the audience and is purely educational, and does not involve the sale of any investment products. Information presented during these events is general in nature, is not tailored to any individual’s circumstances, and does not constitute personalized investment advice. RMR and its IARs do not provide personalized investment advice, recommendations, or portfolio management services during such events. Investment advice will be provided only pursuant to a separate advisory engagement, and only after the attendee’s individual financial information, investment objectives, and circumstances are obtained and evaluated. Any materials distributed in connection with educational seminars or workshops are provided for informational and educational purposes only and should not be construed as accounting, investment, legal, tax, or other professional advice. Attendees are under no obligation to schedule a consultation, engage RMR for advisory services, purchase any services, or become clients of the firm as a result of attending such events. Client Tailored Services & Imposed Restrictions Client Tailored Services RMR offers a consistent suite of advisory services to its clients. However, depending on a client’s individual circumstances, investment holdings, or service needs, certain clients may engage RMR for limited or modified services. In such cases, advisory fees may be reduced or adjusted at RMR’s discretion and are documented in the client’s written advisory agreement. (For additional information regarding advisory fees, see Item 5: Fees & Compensation.) 16  Client‑Imposed Restrictions Clients who engage RMR for discretionary portfolio management services may, at any time, impose reasonable restrictions on RMR’s discretionary authority. Such restrictions may include limitations on investing in specific securities, asset classes, or security types based on a client’s preferences, values, beliefs, or other considerations. All client‑imposed restrictions must be submitted to RMR in writing, and any amendments or modifications to such restrictions must also be provided in writing. RMR will make reasonable efforts to comply with client‑imposed investment guidelines and limitations in accordance with standard industry practices. clients should understand that imposing investment restrictions may affect account management and performance and may result in variations - positive or negative - relative to similarly managed accounts or applicable investment program composites that do not have such restrictions. Certain investment structures, strategies, or limitations may also constrain the ability to pursue or achieve specific investment outcomes. Upon receipt of a client’s written restriction request, RMR will review the request, evaluate its feasibility, discuss the potential impact with the client, and confirm the client’s acknowledgment and understanding of the possible consequences. If client‑imposed restrictions materially impair effective account management or require substantial deviations from RMR’s advisory recommendations, RMR reserves the right to decline or terminate the advisory relationship. In no event, and regardless of the advisory service provided, will RMR be obligated to implement any investment strategy or enter into any transaction that RMR reasonably believes would violate applicable federal or state laws or regulations. Clients participating in TPM programs may impose investment restrictions in accordance with the terms of the applicable referred manager’s governing agreement and program documents. Types of Investments RMR’s investment advisory and management services are designed to accommodate a wide range of investment objectives and strategies. Depending on a client’s financial circumstances, risk tolerance, investment objectives, and the advisory services selected, RMR may recommend or utilize the following types of investments, which are listed in alphabetical order for convenience, and are not intended to be all‑inclusive: annuities (fixed, indexed, and variable), business development companies (“BDCs”), certificates of deposit, commercial paper, derivatives, Digital Assets, equities, exchange‑traded funds (“ETFs”), exchange‑traded notes (“ETNs”), fixed‑income securities, hedge funds, insurance products, limited liability companies, limited partnerships (including real estate, oil, and gas interests), mutual funds (load and no‑load), non‑U.S. securities, options, private placements, real estate investment trusts (“REITs”), bonds (including treasury inflation‑protected and inflation‑linked securities), unit investment trusts, and warrants, as appropriate. Investment recommendations are made based on suitability considerations, client‑imposed restrictions, applicable laws and regulations, and the specific terms of the client’s advisory agreement. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) RMR typically avoids market timing but will increase cash holdings when necessary. When recommending investments in mutual funds, it is RMR’s policy to consider the available share classes and to select the share class deemed most appropriate based on the facts and circumstances of the client and the investment. Factors considered may include, among others, minimum investment requirements, trading restrictions, internal expense structures, transaction charges, availability, and other relevant considerations. Institutional share class mutual funds typically have lower internal expenses than other share classes and, in most cases, do not include ongoing 12b‑1 fees, which can result in a lower overall expense ratio. Accordingly, when available and appropriate, selecting lower‑cost share classes may be in a client’s best interest. However, the availability and suitability of any particular share class will depend on account‑specific factors, custodial platforms, and other considerations. Although RMR generally provides advice on the investment products described herein, the Adviser reserves the right to recommend or utilize other investment products or strategies deemed suitable based on a client’s individual financial circumstances, objectives, and needs, including the use of additional securities to achieve portfolio diversification when appropriate. (For further information, see Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) 17  Conflicts of Interest Clients should be aware that the specific advisory program selected and the manner in which fees are charged will affect the compensation received by RMR and its IARs. Accordingly, the compensation received by RMR and/or its IARs under a particular advisory program may be greater than the compensation that would have been received had the client participated in a different advisory program or paid separately for investment advice, brokerage, or other related services. Because RMR offers multiple advisory programs and services with varying fee structures and features, a conflict of interest arises in which RMR and its IARs have a financial incentive to recommend one program or service over another. Factors that may affect the overall cost of an advisory program, as compared to the cost of purchasing similar services separately, include, but are not limited to: the type and size of the account; the historical and anticipated frequency, size, and complexity of transactions; and the scope and nature of supplemental advisory, administrative, and client-related services provided. Clients are under no obligation to implement any recommendation made by RMR or an IAR, nor are they required to purchase any additional products or services offered by RMR or through any third party. If a client elects to act upon a recommendation, the client is not obligated to execute transactions through RMR or through any recommended broker-dealer or other service provider. As noted previously, clients are free to place securities transactions or engage other services with any broker-dealer or provider of their choosing. RMR does not represent that the advisory programs, investments, products, or services it recommends or makes available are offered at the lowest possible cost. Clients may be able to obtain the same or similar advisory services, investment products, or other services at a lower price from other advisers, brokers, or financial service providers. RMR seeks to mitigate conflicts of interest through its fiduciary obligations, written supervisory and compliance policies and procedures, and its Code of Ethics (the “Code”). Additional information regarding these policies and procedures, including how personal trading and other conflicts are addressed, is outlined in the Code. A copy of RMR’s Code of Ethics is available to clients and prospective clients to review, upon request, free of charge. If you have questions regarding the content of this brochure or any Advisory Agreement, disclosure document, account statement, or other material provided by RMR, or if you do not understand any explanation offered, please contact your IAR directly or our Compliance Department at T: 201.836.2460 or via email @ compliance@rmrwealth.com for assistance. Assets Under Management As of December 31, 2025, RMR’s assets under continuous management total $ 2,885,624,988. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $ 2,375,902,942 $ 509,722,046 $ 2,885,624,988 Please note that the RAUM provided includes the assets that RMR manages as the sub-adviser, which is the PRMR ETF, totaling $50,748,670. (Refer to Registered Investment Company Sub-Advisory Services within this section for additional information.) ITEM 5: FEES & COMPENSATION ____________________________________________________________________________________________________ Advisory Services Fees & Compensation RMR’s advisory clients generally pay an asset‑based advisory fee, calculated in accordance with the fee schedules described herein and, where applicable, as further detailed in RMR’s Form ADV Part 2A, Appendix 1 – Wrap Fee Program brochure, for clients who elect to participate in RMR’s TPM Wrap Fee Program. Annual asset‑based advisory fees are assessed periodically and generally charged in advance or arrears, as disclosed in the applicable Advisory Agreement and the relevant Form ADV disclosure documents. 18  Under the Adviser’s Act and the related "Brochure Rule," investment advisors must provide written disclosure statements to their clients. A copy of RMR's Form ADV Part 2A brochure, Form ADV 2A - Appendix 1 Wrap Fee Program brochure, and Form ADV Part 3 (the "Client Relationship Summary" or "Form CRS”) disclosure brochures, as applicable for the type of account opened, and the Part 2B Brochure Supplement for the IAR assigned to the client’s account will be provided to clients before or upon execution of an RMR Advisory Agreement. Unless a client has received these important disclosure documents at least 48 hours before signing their Advisory Agreement, clients may terminate their Agreement with RMR within five (5) business days of Agreement execution without incurring any advisory fees. (Note: In accordance with Rule 203(m)‑1 and related guidance under the Investment Advisers Act, advisers providing solely impersonal investment advice for which a client pays less than $500 in advisory fees per year may be exempt from certain brochure delivery requirements.) Fee Negotiation Availability Under certain circumstances, RMR’s advisory fees are negotiable, up to the maximum annual rates disclosed herein, subject to applicable limitations and RMR approval. Advisory fees may vary based on factors such as account size, services provided, and other relevant considerations. In its sole discretion, RMR may charge reduced advisory fees or waive or reduce minimum fees based on specific factors, which may include, but are not limited to, the nature and duration of a pre‑existing client relationship, the total number of related accounts, the inception date of the advisory relationship, total assets under management with RMR, anticipated additional assets or future contributions, the composition and complexity of the account, the client’s anticipated future earning capacity, and client negotiations. At RMR’s discretion, certain related accounts—such as those held by members of a client’s immediate family or other affiliated accounts—may be aggregated for fee‑billing purposes, with advisory fees assessed based on the total combined assets under management. Because advisory fees are negotiable, some clients may pay higher or lower fees than others receiving similar advisory services. In addition, clients may pay more or less in advisory fees than they would have paid if they had engaged another investment adviser for comparable services, and lower fees for similar services may be available from other advisers. The specific advisory fee arrangements applicable to each client are outlined in the client’s written Advisory Agreement. Clients remain solely responsible for any tax liabilities arising from transactions executed in their accounts. RMR does not provide tax advice unless otherwise specifically agreed to in writing. Regardless of the availability of fee negotiation, RMR will not accept prepayment of advisory fees more than six (6) months in advance or for an amount exceeding $1,200. Legacy Fees Since RMR began providing investment management services, it has utilized various advisory fee schedules, including certain legacy fee arrangements, that may differ from those currently described herein. From time to time, RMR may implement new advisory fee schedules. Such fee schedule changes generally apply only to new clients entering into Advisory Agreements after the effective date of the latest schedule. The advisory fees charged to existing clients are typically not affected by the adoption of new advisory fee schedules, unless otherwise mutually agreed in writing. As a result, some existing clients may pay advisory fees that differ from those described in this brochure, including fees that may be higher or lower than those currently offered for comparable advisory services. The following sections describe how RMR is compensated for each of its advisory services, as applicable. Advisory Services Fees RMR’s advisory fees are calculated on assets under management or as otherwise described herein, billed in accordance with the client’s executed Advisory Agreement, and reflected through BlackDiamond, RMR’s portfolio reporting and account monitoring platform. Advisory fees are generally calculated based on the total market value of the account's assets, including assets purchased on margin. This creates a potential conflict of interest, as it can incentivize RMR to recommend or maintain margin borrowing because it increases the asset base used to calculate advisory fees. 19  Annual Account Administration Fee Effective April 1, 2024, RMR increased its annual Administrative Fee for accounts billed directly from $52 to $80. This Administrative Fee applies to both non‑wrap‑fee and wrap‑fee investment advisory programs. The Administrative Fee is prorated daily and charged quarterly, based on the number of days in the quarter divided by 365, as further described in the client’s Advisory Agreement. The fee is assessed to RMR fee‑based program clients in accordance with the terms of their executed Advisory Agreement. Regardless of the amount of assets under management, clients subject to the Administrative Fee receive access to and use of the BlackDiamond Wealth Platform, an online trading and reporting system. Through BlackDiamond, clients are provided with a secure, direct login to view portfolio information, review holdings, access account summaries and reports, and obtain educational and training materials. Clients may access this information independently or with the assistance of a dedicated Service Team Member, and the platform also supports ongoing client communications and tools to help clients monitor their investments. Portfolio Management Services Fees RMR’s portfolio management services fees are charged as a single, flat percentage of the total account value. The fee is calculated by applying a fixed annual rate to the entire account value as of the end of the last billing period. This simplified fee structure means the same percentage rate is applied uniformly across the entire account balance. Annual Advisory Fee Schedule Assets Under Management (“AUM”) All Maximum Annual Fee 2.65% *Lower fees for comparable services can sometimes be available from other sources. The annual account management fee is billed quarterly, based on the number of days in the quarter divided by 365, multiplied by the applicable AUM fee. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are negotiable based on account value and account type, but will not exceed the maximum Annual Fee indicated above. The final fee schedule is documented in the client’s executed Agreement. Additional funds and/or securities deposited during a calendar quarter will be billed on a pro‑rata basis, as stated in the client Agreement. Clients who withdraw funds from a managed account during a billing period are not generally entitled to a pro‑rata refund unless they terminate their client Agreement or the Agreement provides otherwise. RMR reserves the right to change its standard Annual Advisory Fee Schedule upon providing clients with at least thirty (30) days’ advance written notice, as required by applicable law. The advisory management fees applicable to each of RMR’s portfolio management services Programs are described below. CIP Program Fees The fees for RMR’s CIP Program services are as follows: CIP Non‑Wrap Fee Program - Clients who select RMR’s traditional portfolio management services under the CIP Non‑Wrap Fee Program will pay an ongoing asset‑based advisory fee calculated in accordance with the Annual Advisory Fee Schedule above. The following also applies:  The maximum annual advisory fee charged under the CIP Non‑Wrap Fee Program is 2.65%.  Transaction costs, brokerage charges, and custodial fees are assessed separately and are not included in the advisory fee.  Fees are billed quarterly, as specified in the client’s executed Agreement. 20  CIP Wrap Fee Program - Clients who elect to receive portfolio management services through RMR’s sponsored CIP Wrap Fee Program will pay a single, bundled asset‑based wrap fee that includes RMR’s advisory services and most transaction‑related brokerage costs. The following also applies:  Fees are calculated as a percentage of assets under management, based on the Annual Advisory Fee Schedule above.  The maximum annual advisory fee charged under the CIP Wrap Fee Program is 2.65%  Fees are billed quarterly, in advance, in accordance with the client’s executed Program Agreement.  RMR acts as the Wrap Fee Program Sponsor and receives advisory compensation under this Program. (For complete details regarding services provided, applicable fees, potential conflicts of interest, and material risks associated with the CIP Wrap Fee Program, clients should refer to RMR’s Form ADV Part 2A – Appendix 1 (Wrap Fee Program brochure) and the applicable Wrap Fee Program Agreement.) TPM Wrap Fee Program Fees In some cases, RMR will recommend or retain third‑party investment managers to manage a portion or all of a client’s assets. Clients participating in RMR’s TPM Wrap Fee Program receive portfolio management services from an independent TPM, with RMR providing advisory oversight, due diligence, and Program administration. Clients will pay a single wrap fee, calculated as a percentage of assets managed within the TPM Wrap Fee Program, in accordance with RMR’s Form ADV Part 2A – Appendix 1 (Wrap Fee Program brochure). The wrap fee is allocated between RMR and the referred TPM pursuant to contractual arrangements. Depending on the applicable agreement, a portion of the client's advisory fee paid to RMR may be shared with such TPMs. TPM Program fees may be structured in one of the following ways and are disclosed in each client’s Agreement:  A split of management fees between RMR and the TPM.  A fixed flat percentage fee, applied to total account assets.  A tiered fee schedule applying different rates to different asset levels.  A linear fee schedule, in which a breakpoint percentage fee is applied to total account assets. The portion of the fee received by RMR is disclosed in RMR’s Form ADV disclosure documents, the client’s Agreement and Fee Disclosure Statement, and the referred TPM’s Form ADV disclosure brochure and separate manager agreement. Under the Wrap Fee Programs, clients are generally billed quarterly, in advance, based on the specific program selected. RMR receives a portion of the overall wrap fee for the advisory, administrative, and oversight services it provides, as more fully described in RMR’s Form ADV Part 2A – Appendix 1 (Wrap Fee Program brochure), the applicable Wrap Fee Program Agreement(s), the client’s RMR Advisory Agreement, and, where applicable, any referred manager’s contract. The following also applies:  Fees for the initial billing period are calculated on a pro‑rata basis at account inception, consistent with the client’s Agreement.  Advisory fees are calculated and reflected through BlackDiamond and debited from the client’s custodial account pursuant to the client’s authorization.  RMR generally remits the TPM’s portion of the fee; however, in certain cases, the TPM may debit the client’s account directly. As a result, clients can see two line items reflecting the allocation of a single wrap fee rather than duplicative fees. Fees are paid to referred TPMs in accordance with the applicable Agreement provisions.  Payment in full is expected in accordance with the applicable Agreement.  With respect to the TPM Wrap Fee Program, RMR’s advisory fee represents the maximum fee RMR may receive and will not exceed applicable regulatory limits. Referred TPMs may charge fees that differ from, and are in addition to, those reflected in RMR’s Annual Advisory Fee Schedule. TPMs typically reserve the right, at their sole discretion, to reduce or waive their fees. In addition, certain investment vehicles used within portfolio model(s) may impose internal fees and expenses, such as fund‑level management fees, which are separate 21  from and in addition to the Wrap Fee Program fee. Fee‑sharing arrangements create a potential conflict of interest, as RMR and its IARs may have a financial incentive to select or recommend managers with whom they have such arrangements. Where applicable, these arrangements and their associated compensation are disclosed to clients in advance. Further, because these services are provided for a single bundled fee, Wrap Fee Program fees are typically higher than traditional non‑wrap advisory fees, particularly for clients who engage in limited trading activity. Clients participating in portfolio management services will receive either a written statement or an electronic notice from their qualified custodian (or, where applicable, the TPM custodian’s secure online platform) detailing all account activity, including advisory fee payments. Clients are encouraged to review all account statements promptly upon receipt to verify accuracy. (See Item 13: Reviews of Accounts for additional information.) Annuity Management Services Fees RMR’s annuity management services fees are billed in arrears, as disclosed herein and described in greater detail in Appendix A to the client’s executed Annuity Management Services Agreement. Clients will authorize these fees pursuant to Appendix A of the Agreement. RMR works with multiple annuity providers. As a result, fee calculation methods and payment mechanics may vary depending on the annuity provider applicable to a client’s account. All such calculation methods and payment options are fully described in Appendix A of the client’s Annuity Management Services Agreement. Further, because annuity management fees are negotiable, clients with accounts of similar size or composition may be charged different management fees. Clients will acknowledge their responsibility to review and verify the accuracy of all fee calculations. If a client identifies a discrepancy in any fee calculated under the Agreement, the client is responsible for promptly notifying RMR and the Insurance Company in writing. If an annuity contract does not maintain sufficient available cash to satisfy a fee payment when due, RMR may sell securities within the annuity contract, without prior notice to the client, to generate sufficient funds to pay such fees. If an Annuity Management Services Agreement is terminated during a billing period, the client will not be charged a prorated fee for services provided during the billing period in which the Agreement terminates. In addition to the annuity management services fees described herein and in Appendix A, clients may incur additional charges imposed by the Insurance Company, including, but not limited to, mortality and expense (“M&E”) fees, annuity rider charges, and other expenses disclosed in the client’s annuity contract. Digital Asset Management Services Fees Digital Asset management services clients will pay a negotiated annual advisory fee based on their investment account’s assets under management, as reported by their qualified custodian on the last day of the previous calendar quarter. The fee is billed quarterly based on the number of days in the quarter divided by 365 multiplied by the AUM fee, debited quarterly in advance, and paid to RMR directly from the client’s custodial account listed in the Digital Assets Management Agreement upon the client’s written permission. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Additional funds and/or securities deposits during a particular calendar quarter will be billed on a pro rata basis, as stated in the client Agreement. Clients who withdraw funds from a managed account during a billing period are generally not entitled to a pro rata refund unless they terminate their client Agreement or it is otherwise stated in the client Agreement. With this service, clients will also incur fees from Fidelity Digital Assets® for transaction execution and custodial services provided for their Digital Assets. Additional fees may include costs and expenses incurred with Fidelity Digital Assets® or other third parties, including, but not limited to, electronic fund fees, exchange fees, intermediary fees, network fees, transaction fees, and wire transfer charges. These fees are separate and distinct from, and in addition to, RMR’s Digital Asset management services fees. If the client’s Fidelity Digital Assets® account does not hold sufficient funds to pay the applicable fees, clients will authorize 22  RMR to enter into transactions on their behalf for the sale of Digital Assets to generate sufficient currency (USD) to promptly remit the fees incurred and due on their account, as stated in the Digital Assets Management Agreement. Financial Planning & Consulting Services Fees Clients may engage RMR for financial planning and consulting services through either a Single Engagement or an Ongoing Planning Engagement. The applicable fees and terms are outlined below. Single Engagement - Single engagement financial planning and consulting services are available on either a comprehensive or à la carte basis: Comprehensive Services - Clients may engage RMR for a Comprehensive Financial Plan, which includes, but is not limited to, each of the financial planning services offered on RMR’s à la carte menu. The fee for a Comprehensive Financial Plan is charged as a flat fee. Build-Your-Own (À La Carte ) Services - Clients may elect to purchase individual financial planning services à la carte. Each selected planning service is charged as a flat fee, based on the specific services selected. Ongoing Planning Engagement - Ongoing planning and consulting services are available to clients who engage RMR for Investment Management Services, beyond a single planning engagement. RMR has established a minimum platform asset threshold of $250,000, which includes ongoing planning services. This minimum is negotiable, at RMR’s discretion. Ongoing planning services may also be provided for $1,500 annually, or $150 per month. Fees for ongoing planning services are negotiable. The following also applies:  A retainer of up to 50% of the total fee is required upon execution of the Financial Planning & Consulting Agreement for both Single Engagement and Ongoing Planning engagements, unless otherwise negotiated.  The remaining balance is due within thirty (30) days of project completion and/or delivery of the financial plan.  If the agreement is terminated before project completion, any unearned fees will be refunded on a prorated basis. Additional reviews may be conducted upon the client's request. Written updates to the financial plan may be provided in connection with such reviews. Clients who do not fall under the Ongoing Planning Engagement described above and who seek additional financial planning services will be required to execute a new Financial Planning & Consulting Agreement and pay fees in accordance with RMR’s then‑current fee schedule, which must be approved in writing by the client before any work commences. Retirement Plan Services Fees RMR retirement plan services are available on a client account, assets under management basis, as a flat, one-time, or ongoing fee, or at an hourly rate for one-time projects or ongoing work. The scope of services, fees, and terms are negotiated on a case-by-case basis with each client and varies depending on the size, complexity, and needs. Ranges, in general, are as follows:  AUM fees are charged according to RMR’s standard Annual Advisory Fee Schedule and as indicated in the client’s executed advisory Agreement.  Flat, one-time, and ongoing fees are determined based on the client’s scope of work.  Hourly fees will not exceed $500/hr. Fees outside the above range are subject to RMR's review and approval. Upon termination, clients will receive a pro-rated refund of any prepaid advisory fees that the Adviser has not yet earned. 23  Registered Investment Company Sub Advisory Fees General Sub‑Advisory Compensation & Expense Arrangements RMR provides sub‑advisory services to registered investment companies pursuant to written sub‑advisory agreements with the funds’ primary investment advisers. When providing registered investment company sub-advisory services, RMR is compensated by the primary adviser and does not receive advisory fees directly from the fund or its shareholders. Sub‑advisory compensation is generally derived from a portion of the management fees the fund pays to the primary adviser. Depending on the engagement, RMR’s compensation arrangements may also include the sharing of certain fund‑related expenses and net advisory revenues, as specified in the applicable agreements. Expense‑sharing arrangements may relate to costs associated with the launch and ongoing operation of a fund, including legal, regulatory, compliance, marketing, distribution, administration, and other operational expenses. Following the deduction of applicable expenses, any net advisory revenue may be allocated between RMR and the primary adviser in accordance with the terms of the governing agreements. These compensation arrangements are not based on the fund's investment performance. Compensation and expense arrangements for sub‑advised registered investment companies may vary by fund, the services provided, and contractual terms, and are disclosed as required by applicable law and regulation. PeakShares RMR Prime Equity ETF – Additional Arrangements RMR serves as sub‑adviser to the PeakShares RMR Prime Equity ETF pursuant to a sub‑advisory agreement with PeakShares LLC, the fund’s primary investment adviser. In addition to the general sub‑advisory compensation and expense‑sharing arrangements described above, RMR holds a non‑controlling equity ownership interest in PeakShares LLC. This equity interest is determined pursuant to a contractual formula based on assets under management attributable to RMR’s sub‑advisory services. It is subject to contractual limitations, including caps and dilution provisions. RMR’s equity ownership interest is not tied to the fund's investment performance. RMR does not hold ownership interest in the primary adviser of any other sub‑advised registered investment company unless expressly disclosed. The compensation, expense‑sharing, and, where applicable, equity-ownership arrangements described above create potential conflicts of interest, as RMR has a financial incentive to increase the assets managed through the funds it sub‑advises. RMR addresses these conflicts through its fiduciary obligations, written policies and procedures reasonably designed to ensure services are provided in the best interests of clients and fund shareholders, and the disclosures contained in this brochure and other required regulatory filings. Pontera Services Fees RMR’s Pontera services fees are asset-based, charged as a flat percentage of the client account's total assets. Fees are calculated based on the number of days in the client's calendar quarter for services provided. The fee charged to the client for the initial period is prorated daily and charged in advance based on the number of days remaining in the billing cycle after the billing start date. For all future periods, the fee will be prorated daily and charged quarterly, in advance, based on the number of days in the billing period, using the client’s account balance at the end of the prior billing period. Pontera charges RMR a percentage fee based on the total assets managed using Pontera’s platform. The initial fee charged by Pontera to RMR is prorated daily and charged in arrears at the end of the billing period. As a result, RMR reserves the right to adjust the initial fee to cover the fee Pontera charges us for the initial billing period. Educational Seminars & Workshop Services Fees Fees for educational seminars and workshops are negotiable. Fees & Fee Billing Clients have two options to pay their RMR advisory fees: either via (1) direct debit or (2) billed, and will select their chosen method by indicating their preference in the Agreement they execute with RMR. As authorized by the client, RMR or its administrative agent typically requests that, for discretionary accounts, the qualified custodian debit account management fees from the client’s account automatically. For non-discretionary accounts, the client 24  will be contacted to provide consent. Clients may also be billed for fees by writing a check directly to RMR or its administrative agent for the fee amount. For all advisory services, full payment of fees is expected promptly upon presentation of the invoice. The exact process for fee payment is as follows: Directly Debited Fees - For directly debited fees, clients will authorize RMR in writing to deduct advisory fees due from their custodial account and provide the custodian with authorization to deduct such fees and instructions to remit them directly to RMR.   For this type of fee payment, when fees are due, RMR will provide the qualified custodian with an advisory fee calculation based on the terms of the client's Agreement and direct the qualified custodian to remit the client a statement of the activity to the client's address of record - or another authorized address, as otherwise designated in writing by the client, reflecting the fee amounts paid to RMR for the quarter in question. If paid directly, the qualified custodian will deduct the client's advisory fees due, as instructed by RMR, at the end of each calendar quarter, regardless of the portfolio's market performance during the quarter just ended. The account management fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings, according to the discretionary authority granted by the client to RMR, IAR, and the referred third-party manager, as applicable for the type of account established. When authorized by the client to debit advisory fees from client accounts, RMR is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct the fees. RMR urges clients to compare their custodial account statements with any periodic portfolio report or date they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us may vary based on accounting procedures, reporting dates, or valuation methodologies. If a client is not receiving statements directly from their custodian, in addition to advising their IAR promptly, RMR also recommends contacting their custodian directly. Billed Fees - Clients who wish to be directly billed by RMR for their advisory services fees will authorize this payment in writing on their advisory services contract and request that RMR invoice them directly quarterly for any fees due. Clients will then make their fee payments to RMR by separate check or credit card, and under no circumstances will any RMR advisory fees be deducted from amounts held in their custodial account(s). Other Fees & Expenses Except as otherwise expressly disclosed, all programs offered by RMR may incur additional charges, expenses, and miscellaneous fees that may be charged by third parties in connection with a client’s account and investment activities that are separate and distinct from the Adviser’s Administrative and AUM Fees. For clients participating in RMR’s Wrap Fee Program, certain securities execution transaction costs and commissions are included in the asset‑based management fee as described in the applicable Wrap Fee Program Agreement, subject to the scope and limitations of the particular program. For non‑wrap accounts, or where not otherwise included, clients may incur additional costs and expenses charged by broker‑dealers, custodians, product sponsors, or other third parties. Such additional fees and expenses may include, but are not limited to, administrative and account maintenance fees, annual custody and safekeeping fees, brokerage commissions and transaction charges, debit or credit interest, margin interest, default charges, direct investment costs (including those related to limited partnerships and limited liability companies), margin and trade extensions, mailing or delivery charges, money market fees, physical reorganization costs, renege assessments, legal processing fees, returned check or stop‑payment fees, transfer or wiring fees, transfer and sub‑transfer agent fees, distributor fees, and other miscellaneous charges customarily assessed in connection with the purchase, holding, or sale of securities or investment products. Additional fees or expenses may also be imposed by product sponsors, including mutual funds, exchange‑traded funds, insurance companies, real estate sponsors, oil and gas programs, or other direct investment providers, as disclosed in the applicable prospectus or offering documents, as well as by the client’s broker‑dealer or qualified custodian. RMR does not share in or receive any portion of these additional fees or expenses, except as otherwise expressly disclosed in this brochure or in a client’s advisory agreement. 25  Margin Interest If a client purchases securities on margin, the client will incur interest charges imposed by the applicable broker‑dealer or qualified custodian on amounts borrowed to finance such purchases. The interest rate, calculation methodology, and associated risks are described in the margin agreement executed between the client and the broker‑dealer or custodian. Securities Transaction & Execution Fees Clients may also incur securities execution transaction fees charged by clearing broker‑dealers and passed through by the introducing broker‑dealer or custodian in connection with the purchase and sale of securities. Each broker‑dealer or qualified custodian provides its clients with a schedule of applicable transaction charges by security type and will notify clients of any changes to such fee schedules. Further, any mutual fund share classes that pay asset‑based sales charges or service fees (such as 12b‑1 fees) and that are received by RMR will be credited back to the client’s account. Additional information regarding fees and expenses assessed by mutual funds is available in the applicable fund prospectuses. Revenue Sharing & Other Considerations RMR makes available and may recommend a broad range of investment products and mutual funds. Certain product sponsors maintain marketing, educational, or distribution support arrangements intended to facilitate awareness of their investment offerings. As a result of such arrangements, RMR’s IARs may attend educational meetings, seminars, due diligence presentations, or conferences covering general industry topics, regulatory developments, or product‑specific information. Clients should be aware that different investment products may charge different commissions or internal expenses; however, RMR’s IARs do not receive a higher or lower commission percentage based on the selection of particular products. Nonetheless, receiving educational or promotional support from product sponsors presents a potential conflict of interest, as it could influence the focus or selection of the products recommended. Clients are under no obligation to purchase securities or insurance products through RMR or any person affiliated with RMR. Clients may buy recommended products through unaffiliated brokers or agents. Before transferring securities into an advisory account, clients are encouraged to consider and discuss with their investment adviser representative, tax professional, and other investment professionals, as appropriate:  Whether any commissions were previously paid or will continue to be owed under a deferred compensation arrangement.  Whether the client wishes to have the security managed in an advisory account, subject to an ongoing advisory fee.  Whether the client prefers to hold the security in an unmanaged brokerage account, not subject to an advisory fee. Clients are encouraged to review RMR’s Advisory Agreement, the agreements of any TPMs, and all applicable prospectuses, offering documents, and disclosures to understand the fees, costs, expenses, commissions, and other charges associated with their accounts and investments. Clients are encouraged to contact their IAR, tax professional, or other investment professionals with any questions. (Additional information regarding brokerage practices is provided in Item 12: Brokerage Practices.) Account Additions, Withdrawals, Terminations & Assignments RMR provides multiple advisory services, each governed by a separate written agreement and subject to distinct fee structures and operational requirements. As a result, the provisions applicable to account additions, withdrawals, terminations, and assignments vary by service. The Advisory Services Matrix: Account Additions, Withdrawals, Terminations & Assignments table that follows summarizes how these matters are generally handled across RMR’s service offerings. However, in all cases, the executed Advisory Agreement— and any applicable third‑party or platform agreements—controls in the event of any inconsistency. 26  Advisory Services Matrix: Account Additions, Withdrawals, Terminations & Assignments Additions Withdrawals Terminations Assignments* Advisory Service  The client may terminate by written notice, without penalty, within five (5) business days after the Agreement's execution.  Thereafter, either party may terminate on at least 30 days’ written notice, effective on receipt.  Clients may make additions to their RMR accounts in cash or securities at any time.  Unearned, prepaid fees are  Additions of over $10,000 refunded pro rata.  No RMR client  If billed in arrears, fees are  Clients may withdraw in cash or securities at any time, subject to customary settlement procedures.  An outgoing account Agreement may be assigned without the client’s prior consent. will incur additional prorated fees based on the number of days remaining in the billing period.  Transactions not  RMR may liquidate transfer fee may apply when transferring to another firm. Portfolio Management Services transferred securities or decline to accept specific securities.  If liquidation occurs, the resulting in a change of actual control or management under the Advisers Act are not considered assignments.  Withdrawals from a client account of over $10,000 will result in a prorated refund based on the number of days remaining in the billing period. client may incur transaction fees, mutual-fund-level charges (e.g., CDSCs), and tax ramifications. prorated through the termination date using the portfolio-value basis described (i.e., the prior full billing quarter adjusted for days elapsed).  For natural person clients, the Agreement terminates upon RMR’s receipt of written notice of death; disability or incompetency does not automatically terminate the Agreement.  An authorized representative may terminate the Agreement by written notice.  After termination, the Adviser is not entitled to any additional fees and has no obligation to continue acting on the account.  The annuity contract governs withdrawals, surrenders, or loans.  The insurance carrier may No assignment without the client’s prior consent. Annuity Management Services Additional contributions or contract value increases are subject to the annuity contract terms and the carrier's rules. impose surrender charges, taxes, or penalties.  The Agreement may be terminated per its terms.  Advisory fees cease as of the termination date, but carrier- imposed charges may continue. Fees are billed in arrears; if the Agreement is terminated mid-billing period, the client will not pay a prorated fee for that partial period.  RMR may amend the annuity services fee schedule (Appendix A) with 30 days’ prior written notice. No assignment without the client’s prior consent. Digital Asset Management Services Contributions or transfers follow platform/custodian procedures, timing, and limits. The client may terminate pursuant to the agreement; fees are prorated through the termination date, subject to platform timing. Withdrawals are subject to platform liquidity, processing times, and third- party network/ transaction fees. 27  Additions Withdrawals Terminations Assignments* Advisory Service Not applicable. Not applicable once the scope is defined. No assignment without the client’s prior consent. Financial Planning – Single Engagement Engagement ends upon delivery of the agreed-upon services or earlier, per the agreement; fees may be refundable if services are not completed.  Either party may terminate upon written notice. No assignment without the client’s prior consent. Additional planning services may be added by mutual agreement and may result in a revised fee arrangement. Financial Planning – Ongoing Planning Engagements Withdrawals of “planning-only” fees are not applicable; planning does not involve custody of client assets.  Fees are prorated through the termination date based on the billing cycle.  Termination occurs upon Retirement Plan Services No assignment without the client’s prior consent. Plan sponsors/participants make additions per plan documents and ERISA. disengagement by the plan sponsor or fiduciary in accordance with ERISA and plan documents. Plan documents and applicable law govern distributions; RMR does not control participant withdrawals.  Fees are prorated at the plan level through termination. Not applicable to sub-advisory services. Not applicable to RMR’s sub-advisory relationships; fund cash flows are governed by fund operations. Termination is governed by sub- advisory agreements, fund board approval, and law; retail termination rights do not apply. Registered Investment Company Sub-Advisory Services Assignments governed by the Investment Company Act of 1940 and fund-level agreements; not a retail client Agreement.  The client may revoke access or terminate.  Advisory fees are prorated Pontera Services through termination. No assignment without the client’s prior consent. Client-directed contributions and/or transfers are subject to the held-away plan’s rules and the Pontera platform. The client initiates distributions through the plan custodian; RMR has no custody or control.  Plan assets remain subject to Plan rules.  The contract continues until  The executed RMR the client or the TPM terminates by written notice.  The TPM is responsible for  The executed RMR Advisory Agreement and the applicable TPM Program Agreement govern withdrawals.  No assignment of RMR’s Agreement may be made without the client’s prior consent.  Operational timing,  TPM Program  Third-Party Manager Services Advisory Agreement and the applicable TPM Program Agreement govern additions and withdrawals.  TPM/platform rules and minimums apply. agreements may include their own assignment provisions. processing procedures, and limitations are subject to the TPM and custodian platform. refunding unearned fees per its contract. If the total account value (or aggregated value) falls below the TPM minimum, the TPM may terminate the Program Agreement. *Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Investment Advisers Act of 1940, as amended, shall not be considered an assignment. Clients should review all applicable advisory agreements, third‑party agreements, plan documents, prospectuses, and disclosure materials to fully understand how additions, withdrawals, and terminations operate for their specific service. ITEM 6: PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT ____________________________________________________________________________________________________ Performance-based fees are fees based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees alongside those that are not. RMR does not accept performance-based fees or participate in side-by-side management. (See Item 5: Fees & Compensation for additional information.) 28  ITEM 7: TYPES OF CLIENTS ____________________________________________________________________________________________________ Types of Clients RMR primarily provides investment advisory services to individuals, high-net-worth individuals, partnerships, trusts, corporations, retirement/pension and profit-sharing plans, charitable organizations, and other institutions and business entities. RMR also provides advisory and sub-advisory services to registered investment companies, including exchange-traded funds. Minimum Account Size There is no account minimum for RMR’s services, and there are no ongoing contribution requirements for client accounts. However, this practice is highly recommended for continued savings, asset allocation, and tax efficiency. Clients participating in RMR’sTPM Wrap Fee Program services will be subject to the independent TPM’s account minimums (typically between $25,000 and $1,000,000), as disclosed in each TPM’s agreement. In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they execute with their referred third- party manager. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, TYPE OF INVESTMENTS & RISK OF INVESTMENT LOSS ____________________________________________________________________________________________________ Methods of Analysis RMR provides customized investment recommendations and portfolio investment advice based on, but not limited to, each client's distinct circumstances, investment objectives, and needs, as stated by the client during consultations. The information clients supply will serve as the basis for a strategic asset allocation plan designed to help the client strive to meet their expressed personal short- and long-term financial goals and objectives, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s economic objectives. In all cases, the client’s IAR will rely upon the accuracy of data furnished by the client or on their behalf without further investigation - RMR is not required to confirm the information obtained from clients or their other professional advisors. As RMR’s IARs have the independence to take the approach they believe is most appropriate when analyzing investment products and strategies for clients, there is a potential conflict: IARs may provide different clients with dissimilar advice regarding the same securities. Several sources of information are used in the investment analysis process. These sources include, but are not limited to:  Financial publications.  Research materials prepared by others.  Corporate rating services.  SEC filings (such as annual reports, prospectuses, 10-ks, etc.).  Company press releases. RMR does not favor one specific method of analysis over another and, therefore, does not have one “significant strategy” for client investments. Instead, several standard approaches will generally be used individually or collectively when advising clients, which approaches may include one or more of the following methods of analysis or investment strategies: Cyclical Analysis - A technical analysis involving evaluating recurring price patterns and trends. With this type of analysis, economic/business cycles may be unpredictable, fluctuating between long-term expansions and contractions, and their lengths may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty of predicting economic trends and, consequently, the changing value of securities affected by these trends. Fundamental Analysis - A security evaluation method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what 29  sort of position to take with that security (underpriced = buy, overpriced = sell or short). This security analysis method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, using fundamental analysis may not yield favorable returns. Quantitative Analysis - an analysis technique that seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research. By assigning numerical values to variables, quantitative analysts aim to model reality mathematically. Some believe it can also be used to predict real-world events, such as changes in share prices. Technical Analysis (“Charting”) - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that a stock's performance, rather than the company's, is more closely tied to its future price. Some risks of this type of analysis include biased opinions or indicators that, while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. Our investment strategies and advice will vary depending on each client's financial situation. Therefore, clients must notify us immediately of any material changes to their financial circumstances, including, for example, changes in their current or expected income level, tax circumstances, or employment status. While RMR’s IARs may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. Additionally, when balancing portfolios, IARs will consider only the account’s managed assets, not other investments the client may hold elsewhere. Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation, as we determine investments and allocations based on their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in their best interest objective. Client restrictions and guidelines will also affect the composition of their portfolio. In addition to the “Risks of Loss & Other Types of Risks” provided for review herein, the following are other items that can also be considered when determining investment strategies and practices: Asset Allocation - This investment strategy aims to balance risk and reward by allocating assets among various asset classes. At a high level, there are three main asset classes: (1) equities (stocks), (2) fixed income (bonds), and (3) cash and cash equivalents, each with different risk and reward profiles and behaviors. Asset classes are often further divided into domestic and foreign investments. Equities are often divided into small-, intermediate-, and large-cap, and fixed income into short-, intermediate-, and long-term. The general theory behind asset allocation is that each asset class will perform differently under different market conditions. By diversifying a portfolio across asset classes, advisors aim to reduce volatility and risk by avoiding overexposure to any single asset class during different market cycles. Asset allocation does not guarantee profits or protect against losses. Capital Growth and/or Income Strategy - A “growth and income strategy” often invests in companies with earnings growth and those that pay dividends. Risks associated with a capital growth and income strategy are similar to those experienced with income and growth strategies. For example, bonds can be called when interest rates drop, and replacing a called bond with another paying the same interest may be impossible, or companies can suspend dividends for certain stocks if they experience financial problems. A growth investing strategy involves seeking stocks with growth potential. The latter means the stock price will rise at some point. As a result, growth investors may target young companies with the potential to outperform their peers in the industry or sector. By its very nature, growth investing entails risk, as some young companies may fail. Dollar Cost Averaging - The technique of regularly buying a fixed dollar amount of a particular investment, regardless of the share price (“DCA”). More shares are purchased when prices are low and fewer when prices are high. This investment strategy is believed to reduce the risk of investing a large sum in a single asset at a higher price. DCA strategies are ineffective and do not prevent loss in declining markets. 30  Long-Term Purchases - Securities purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Short-Term Purchases - Securities are purchased with the expectation that they will be sold within a relatively short period, generally less than 1 year, to take advantage of their short-term price fluctuations. Margin Transactions - A securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Buying on margin means borrowing money from a broker-dealer to purchase stock. Margin trading allows investors to buy more stock than they could otherwise. An initial investment of at least $2,000 is required for a margin account, although some brokerages require more. This deposit is known as the minimum margin. Once the account is operational, the holder can borrow up to 50% of the purchase price of the stock. This portion of the deposit purchase price is the initial margin. Investors can be required to deposit more than 50% of the purchase price. Not all stocks qualify for purchase on margin. When selling stock in a margin account, the proceeds go to the broker-dealer to repay the loan until it is fully paid. A maintenance margin restriction also exists - the minimum account balance that must be maintained before the broker-dealer forces the deposit of additional funds or sell stock to pay down the loan (when this happens, it is known as a “margin call.”) If for any reason, a margin call is unmet, the broker-dealer has the right to sell account securities to increase the account equity until above the maintenance margin. Additionally, the broker-dealer may not be required to consult the account holder before selling. Under most margin agreements, a firm can sell the account's securities without waiting for the account holder to meet the margin call, and the account holder cannot control which stock is sold to cover the margin call. Interest on the loan must also be paid. The interest charges are applied to the account unless separate payments are made. Over time, the debt level increases as interest charges accrue. As debt rises, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer an investment is held, the greater the return needed to break even. In volatile markets, prices can fall quickly, and more money can be lost than invested. Options Writing - A securities transaction that involves selling options, which are the right, but not the obligation, to buy or sell a particular security at a specified price before the option's expiration date. When an investor sells an option, they must deliver a specified number of shares to the buyer if the option is exercised. The buyer pays the seller a premium (the option's market price at that time) to have the seller write the option. Short Selling - clients participating in these portfolios will receive additional disclosure information regarding the risks of short-sale investments. Unhedged, short selling is very risky. Unlike a straightforward investment in stocks, where shares are purchased with the expectation that their price will increase to sell at a profit, in a "short sale," stock is borrowed from a brokerage firm and then immediately sold in hopes that the price will have dropped when they are required to be purchased at a later date. Thus, a short seller hopes that a stock's price will decrease in the future, using market declines to their advantage. Short sellers make money when the stock prices fall and lose money when prices increase. The SEC has strict regulations regarding short selling. No ceiling exists on how much a short seller can lose in a trade - if the share price keeps increasing, the short seller must pay the prevailing stock price to buy back the shares. However, there is a ceiling on gains because a stock’s price cannot fall below zero. In addition, a short seller must pay interest on borrowed securities as long as their short position remains open. If a company declares huge dividends or issues bonus shares, the short seller must also pay that amount to the lender. Any such occurrence can skew the entire short investment and make it unprofitable. Finally, a broker can use the funds in the short seller's margin account to buy back the loaned shares or issue a “call away” to require the short seller to return the borrowed securities. If this call is made by the broker when the stock price is significantly higher than the price at the time of the short sale, the investor can suffer tremendous losses. Investment strategies implemented on behalf of registered investment companies are subject to the applicable fund’s stated investment objectives, policies, and restrictions, as disclosed in the fund’s prospectus and related offering documents. Accordingly, such strategies may differ, in whole or in part, from those employed for separately managed account clients, over which RMR typically exercises broader discretionary authority, subject to each client’s investment objectives, guidelines, and restrictions. Tax Considerations RMR’s strategies and investments can have unique and significant tax implications. However, unless expressly agreed upon otherwise and in writing, tax efficiency is not the primary consideration in managing client assets. Regardless of client account 31  size or other factors, RMR strongly recommends that our clients consult with a tax professional before and throughout investing their assets. Qualified custodians will typically default to the FIFO (“First-In, First-Out”) accounting method for calculating portfolio investment cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If a client or their tax advisor believes another accounting method is more advantageous, immediately notify our firm and the account's qualified custodian of the selected accounting method in writing. (Note: Decisions about cost-basis accounting methods must be made before trades settle, as the cost-basis method cannot be changed after settlement.) Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. clients have access to a wide selection of product offerings and securities, including, but not limited to, bonds (treasury inflation-protected and inflation-linked), business development companies, certificates of deposits, commercial paper, derivatives, Digital Assets, equities, exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships (real estate, oil, and gas), mutual funds (load and no-load), non-U.S. securities, options, private placements, real estate investment trusts, unit investment trusts, and warrants, among others, as appropriate and suitable for each account’s goals. Cash Management As indicated below, RMR usually invests clients' cash balances in Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts, money market funds, or certificates of deposit. In managing cash held in client accounts, we typically use the sole, exclusive cash vehicles made available by the custodian, in accordance with their parameters. Other cash management and money-market options may be available outside the custodian, offering higher yields or safer underlying investments. In most cases, at least a partial cash balance will be maintained in a money market or FDIC-insured deposit account to allow for the debit of advisory fees or anticipated client cash distributions. We will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: This type of investment product is usually not FDIC insured, insured by any Federal government agency, a deposit, other obligation, or guaranteed by the adviser.) StoneCastle Cash Management, LLC Program RMR makes the Keep® Program available and refers clients to it, which is sponsored by StoneCastle Cash Management, LLC (“StoneCastle”). The Federally Insured Cash account Program offered by StoneCastle allows clients the ability to protect their money by placing it in deposit accounts at banks, savings institutions, and credit unions in a manner that maintains full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of insured depositories. StoneCastle requires a minimum deposit of $100,000 to open a KEEP account, and RMR earns a referral fee from StoneCastle if clients participate in this program. RMR’s referral fee starts at 20 basis points and increases if the client's interest rate rises. clients' interest rates from the KEEP program are net of all fees, including the fee RMR receives for client referrals to the program. RMR will assist clients in signing up for this program and facilitating funds transfer between the client’s like-named accounts. Clients participating in the program receive a copy of StoneCastle’s Form ADV. The above cash management program creates a potential conflict of interest between clients who choose to participate and our firm, as recommending this program means RMR receives Promoter referral compensation if clients decide to engage StoneCastle's services. RMR addresses this conflict of interest by advising clients of the nature of the conflict whenever any referral is made. Clients are under no obligation to participate in the program. Risks of Specific Securities Utilized While RMR seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. IARs will recommend various types of securities, as indicated herein and deemed appropriate for each client’s situation, restrictions (if any), and goals. 32  Although advice is provided predominantly on the products listed within this brochure, RMR reserves the right to advise on any suitable investment product for a client's specific circumstances, needs, and individual goals and objectives. We will use other securities to help diversify a portfolio when applicable and appropriate. Investing also risks missing more favorable returns that could be achieved by investing in alternative securities or commodities. Any of the above investment strategies may result in losses, especially if markets move against the client. Additionally, we may advise on other assets held in the portfolio at the inception of the advisory relationship. Since investment strategies and advice are based on each client's financial situation, the advice we provide to one client may differ from or conflict with that for the same security or investment for another client, as each client's needs and risk tolerance differ. Clients should be aware of the 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. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains; they should not invest unless they can bear these losses. Recommendation of Particular Security Types RMR recommends various types of securities and does not primarily favor one type over another, as each client has different needs and risk tolerance. As each security type has its unique set of associated risks, it would be impossible to present every specific risk of each investment type. Even within the same kind of investment, risks can vary widely. However, in very general terms, the higher the anticipated return on an investment, the greater the risk of loss. A description of some of the security types we may recommend and some of their inherent risks follows: Annuities - Annuities are financial products that pay a fixed stream of payments to an individual, primarily used as a source of income for retirees. The period during which an annuity is funded before payouts begin is called the accumulation phase. The annuitization phase begins once payments commence. Annuities can be structured as fixed or variable. Fixed annuities provide regular periodic payments to the owner/annuitant. Variable annuities allow the owner/annuitant to receive larger periodic payments if the investments in the annuity do well; however, if the investments do poorly, the owner/annuitant will receive smaller payments. In addition, the annuity services offered by RMR will incur charges, expenses, and miscellaneous fees separate and distinct from the Advisory fee charged by the Adviser. Bank Obligations - Bank obligations, including bonds and certificates of deposit, may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates. They may be adversely affected by downturns in the US and foreign economies, as well as by changes in banking regulations. Bonds - Corporate debt securities (or "bonds") are typically safer investments than equity securities. Still, their risk can vary widely based on the issuer's financial health, the risk of issuer default at maturity, and whether the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character that pays the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in risk and reward. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Certificates of Deposit - Certificates of deposit (“CDs”) are generally a safe type of investment, as they are insured by the Federal Deposit Insurance Corporation (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Corporate Bonds - Corporate bonds are debt securities issued by corporations to raise capital. Issuers pay investors periodic interest and repay the borrowed amount periodically throughout the life of the security or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current 33  interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate based on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Digital Assets - As used herein, “Digital Assets” refers to an asset issued and/or transferred using a distributed ledger or blockchain technology. The investment objective of RMR’s Digital Asset account allocation is to offer interested clients exposure to the Digital Assets market via a portfolio comprised of Digital Assets available through our Fidelity Digital Asset Services, LLC custodial relationship. An investment in Digital Assets is appropriate only for clients who (1) understand the speculative nature of such securities, (2) can bear the economic risk of the investment, (3) have no urgent need for liquidity with the assets committed to this type of investment, and (4) and are willing to accept the risks of loss of their entire investment in exchange for the potential benefits and returns Digital Assets may offer. Given the complexity of this product, investment decisions made for the allocation of any portfolio of Digital Assets are expressly subject to various potential risks, including but not limited to the following: Custody Risk - Under the Advisers Act, SEC-registered investment advisers must hold securities with “qualified custodians,” among other requirements. Certain Digital Assets may be deemed to be securities. Some Digital Assets do not currently fall within the SEC's definition of a security. Therefore, many companies that provide Digital Asset custodial services fall outside the SEC’s definition of “qualified custodian.” Accordingly, clients seeking to purchase actual digital coins/tokens/currencies may need to use non-qualified custodians to hold all or a portion of their Digital Assets. Further, Digital Asset holdings are not considered legal tender or insured by the government, as U.S. bank deposits are. Therefore, investors do not have the same protections as a bank account can offer. Unlike most traditional currencies, such as the U.S. dollar, the value of a Digital Asset is not tied to promises by a government or a central bank - Digital Asset investments are uninsured. Exchange & Business Hours Risk - Exchanges can stop operating due to security breaches, fraud, insolvency, market manipulation, market surveillance, KYC/AML procedures, non-compliance with applicable rules and regulations, technical glitches, hackers, malware, or other reasons. Blockchain technology is a relatively new, untested distributed ledger. Blockchain systems could be subject to internet connectivity disruptions, consensus failures, or cybersecurity attacks, and the date or time an investor initiates a transaction may differ from when the transaction is recorded on the blockchain. Digital Asset prices can fluctuate, sometimes heavily, after traditional market hours. RMR accepts no responsibility for its inability to buy or sell Digital Assets outside standard industry trading hours. Government Oversight of Digital Assets Risk - Regulatory agencies and/or the entities responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and may be subject to change. Regulators may adopt laws, regulations, policies, or rules that directly or indirectly affect Digital Assets, their treatment, transactions, custody, and valuation. Liquidity Risk - Liquidity may be limited or disrupted, and there can be no guarantee of the ability to sell or exchange Digital Assets at any price. Trades may not settle, be challenging to settle, or be traded only at significantly adverse prices, depending on market conditions or volume. Loss of Confidence Risk - Digital Assets are part of a new, rapidly evolving “Digital Assets industry,” subject to high levels of uncertainty. For a relatively small use of Digital Assets in the retail and commercial marketplace, online platforms have generated a large trading activity by speculators seeking to profit from the short-term or long-term holding of Digital Assets. A central bank, national or international organization, assets or other credit do not back most Digital Assets. Their value is strictly determined by market participants' valuations through transactions, so a loss of confidence may trigger a collapse in trading activity and an abrupt drop in value. Peer-to-Peer Transaction Risk - Digital Assets can be traded on numerous online platforms through third- party service providers and through peer-to-peer transactions between parties. Many marketplaces bring together counterparties without providing clearing or intermediary services or being regulated. In such a case, all risks (such as double-selling) remain between the parties directly involved in the transaction. 34  Price Volatility of Digital Assets Risk - A principal risk in trading Digital Assets is rapid price fluctuations. The value of client portfolios is partly determined by the value of the Digital Assets held in those portfolios; fluctuations in the prices of Digital Assets could adversely affect a client’s portfolio. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex factors such as supply and demand, availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Digital Assets users and market participants; perceived or actual security vulnerability; and traditional risk factors including inflation levels; fiscal policy; interest rates; and political, natural and economic events. Protocol & Governance Risk - Digital Assets are a relatively recent technological innovation. Bitcoin, invented in 2009, is widely considered to be the first popular Digital Asset. Other Digital Assets we may invest in were created after Bitcoin. There can be no assurance that the Digital Asset industry will continue in its current form. Digital Assets are generally created and supported by an underlying blockchain or protocol, such as the Bitcoin or Ethereum Protocols. Any malfunction, malicious attack, breakdown, or abandonment of the network may adversely affect the Digital Asset’s protocol or network, leading to a loss of value for the Digital Asset. Moreover, advances in cryptography or technical advances such as quantum computing could pose risks to Digital Assets by rendering the cryptographic consensus mechanism that underpins a Digital Asset’s protocol ineffective. There can be no assurance that changes or developments in Digital Asset protocols will not adversely impact your account. Regulatory Risk - Regulatory uncertainties surrounding blockchain and distributed ledger technologies abound. Because global and national standards are far from fully established, fund managers face a heavy disclosure obligation to report existing regulatory considerations and the potential outcomes of regulatory issues that have yet to be decided. The comprehensive regulation facilitating institutional investment will require coordination of global standards, particularly for exchanges. In the U.S., regulatory standards will likely be set by a combination of state, national, international, and industry bodies, judicial precedent, international agreements, and industry associations. Service Providers Risk - Service providers supporting Digital Assets and Digital Asset marketplace(s) may not be subject to the same regulatory and professional oversight as traditional securities service providers. Further, there is no assurance that the availability and access to virtual currency service providers will not be negatively affected by government regulation or by changes in the supply and demand for Digital Assets. Accordingly, companies or financial institutions that currently support virtual currency may no longer do so. Tax Risk - It should be noted that there is substantial uncertainty regarding the tax treatment of investments in Digital Assets. Digital Assets may be considered assets in certain jurisdictions and currency in others. Sales or value-added taxes may be imposed on the purchase and sale of Digital Assets. Depending on their home jurisdiction, investors may need regular tax advice to ensure the tax treatment of their investments in Digital Assets. Technology & Security Risk - Digital Assets are computer-coded entries on a digital ledger, or blockchain, visible to and verifiable by nodes. Ownership is reflected in a string of numbers on a distributed ledger, accessible only via public and private keys in “wallets.” A custodian could hold a “private key” and a “public key” to the Digital Asset to satisfy regulatory requirements. A custodian can maintain private keys in digital form on a computer hard drive, disconnected from the internet and protected by multiple layers of cybersecurity. The custodian can also preserve and secure the private key in a “cold wallet,” such as by locking it in a physical vault. In any event, the technology used for safeguarding Digital Assets is emerging. Digital Assets are essentially bearer assets. In general, anyone who obtains possession of the private key can, in theory, misappropriate the asset, no matter where the private key is maintained. Unanticipated Risks - Digital Assets are new and still largely untested. In addition to the risks disclosed, there are other risks associated with purchasing Digital Assets that RMR cannot anticipate. Such risks may further materialize as unanticipated variations or combinations of the risks discussed. Digital Asset investments are inherently global; therefore, exchange platforms, custodians, counterparties, and issuers are rarely located within a single jurisdiction. Currently, the industry lacks a standard regulation or auditing practice for verifying ownership of accounts holding Digital Assets. The Investment has counterparty and custody risks, including 35  loss or theft of the Digital Asset itself. Valuation Risk - The valuation of Digital Assets can differ significantly depending on the pricing source or other factors, including but not limited to market fragmentation, unregulated markets, illiquidity, and volatility. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. Volatility & Loss Risks - Digital Assets are highly speculative and involve high risk. Prices of Digital Assets are incredibly volatile and can be more volatile than other traditional investments, such as stocks and bonds, and market movements can be challenging to predict. If the value goes down, it is not guaranteed to rise again. As a result, there is a significant risk of losing the entire principal investment. Gains and losses are unpredictable, and there is no guarantee of returns. Interests should not be purchased by anyone who cannot afford the loss of their entire investment. Transactions involving Digital Assets may be irreversible, and losses from fraudulent or accidental transactions may not be recoverable. There are counterparty and custody risks associated with Digital Assets, including loss or theft. Exchange-Traded Funds (“ETFs”) - ETFs are typically investment companies classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, particularly when ETF shares are listed on a securities exchange. An ETF is designed to track the price of an index or a collection of underlying assets as closely as possible. Shares can be bought and sold throughout the day, like those of publicly traded companies, and may trade at a discount or premium to their NAV. This difference between the bid and ask prices is often called the "spread." The spread varies over time based on the ETF's trading volume and market liquidity. It is generally lower when the ETF has high trading volume and market liquidity, and higher when it has low trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, like traditional mutual funds, some ETFs (particularly those that invest in commodities such as gold and precious metals) are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged ETFs, in particular, present distinct risks and are not appropriate for all investors. Leveraged ETFs should be used only by investors who understand the risks of seeking daily leveraged or inverse investment results, generally for short- term active trading within an actively monitored and managed investment program. Investors must be aware of the daily nature of leveraged and inverse investment strategies, the high expense ratios, and the lack of guarantee of long- term inverse returns, among other considerations, before participating in this type of investment. Exchange-Traded Notes (“ETNs”) - An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to various assets, such as commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN include the following. The repayment of principal, interest (if any), and any returns at maturity or upon redemption depends on the ETN issuer's ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer's credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class, or country, and may carry particular risks. ETNs may be closed and liquidated at the discretion of the issuing company. Fixed Income Call Options - Including agency, corporate, and municipal bonds and all mortgage-backed securities - contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk: investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Limited Partnerships, Limited Liability Companies & Business Development Companies - Limited partnerships, limited liability companies, and business development companies represent different forms of ownership of investment assets. These entities are investment vehicles that may own full or partial interests in various operating businesses. The types of operating companies may include, but are not limited to, equipment leasing, oil and gas, alternative energy, and real estate. 36  Managed Futures Funds - A managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that trade various derivative instruments, including options, futures, forwards, or spot contracts, which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks depending on its nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in the underlying funds. It may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds, as well as the fund's direct fees and costs. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees on each underlying fund's returns. There may be periods when fees are paid to one or more underlying fund managers even though the fund has lost money during that period. Money Market Funds - A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission notes, "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments, such as stocks, their long-term average returns tend to be lower than those of riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities - Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project, like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds - Mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. Mutual funds can also be "closed-end" or "open-end." So-called “open-end” mutual funds allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. Some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund; others charge such fees, which can also reduce returns. Mutual funds are sold in different share classes and may offer investors discounts on sales charges, as described in each fund's prospectus. Funds will have a manager who trades the fund's investments in line with the fund's investment objective. Mutual fund shares held in client accounts may also be subject to 12b-1 fees, short-term redemption fees, and other fund annual expenses. No-load or load-waived mutual funds used in client portfolios do not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Non-advisory accounts typically have upfront or back-end charges. Each fund's prospectus fully describes these fees and costs. If clients have mutual funds in their portfolio, they will pay their adviser, any third-party manager, custodian, and mutual fund manager to manage their assets, as well as any other fund expenses paid by the fund's shareholders. If clients transfer particular share classes of mutual funds and liquidate those shares after the transfer, the shares may also incur contingent deferred sales charges (“CDSCs”) from the mutual fund company if they are within the CDSC holding period. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. In short, all these costs of managing the funds can reduce the fund’s returns. 37  Options - Options are complex securities involving risks that are not necessarily in everyone’s best interest. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: 1. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Call buyers hope the stock will increase substantially before the option expires. 2. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to shorting a stock. Put buyers hope that the stock price will fall before the option expires. The risks for option buyers include the potential to lose their entire investment in a relatively short period. This risk increases as expiration nears if the stock is below the call's strike price (for a call) or above the put's strike price (for a put). European-style options that lack secondary markets for sale before expiration can only realize their value at expiration. In addition, specific exercise provisions of a specific option contract may create risks, and regulatory agencies may impose exercise restrictions, which stop you from realizing value. Selling options is more complicated and can be even riskier. The option trading risks for options sellers include, but are not limited to:  Options sold may be exercised at any time before expiration.  Covered call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock.  Writers of naked calls risk unlimited losses if the underlying stock rises.  Writers of a naked put are exposed to a maximum loss equal to the strike price minus the premium received from the sale.  Writers of naked positions run margin risks if the position goes into significant losses, and such risks may include liquidation by the broker.  Writers of call options can lose more money than a short seller of that stock on the same rise in that underlying stock - an example of how the leverage in options can work against the options trader.  Writers of naked calls must deliver shares of the underlying stock if those call options are exercised.  Call options can be exercised outside market hours, so the writer cannot take effective remedial action.  Writers of stock options are obligated under the options that they sold, even if a trading market is not available or they cannot perform a closing transaction.  The value of the underlying stock may surge or drop unexpectedly, leading to automatic exercises. Other option trading risks include the complexity of some option strategies carrying a significant risk on their own, option trading exchanges or markets and options contracts are open to changes at all times, options markets have the right to halt the trading of any options, thus preventing investors from realizing value, there is a risk of erroneous reporting of exercise value, investors trading through that firm may be affected If an options brokerage firm goes insolvent, and Internationally traded options have unique risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, since stock options are derivatives of stocks. Options Contracts - Options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Call buyers hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to shorting a stock. Put buyers hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Real Estate - Real estate is increasingly used as part of a long-term core strategy due to greater market efficiency and growing concerns about the long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still carries considerable market risk. Real estate 38  has proven very cyclical, mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors who wish to add real estate to their core investment portfolios need to consider property concentrations by area or property type. Because property returns are directly affected by local market fundamentals, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk-mitigating attributes and bear additional risk when overly influenced by local or sector market changes. Real Estate Investment Trusts - A real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs must declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations. Hence, cash flow must be strong, or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation risks due to cash flows, dividends paid in stock rather than cash, and debt payments that dilute shares. Securities Futures Contracts - A futures contract (on tangibles and intangibles) is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index at a specified price on a specified future date. Unlike options, the holder of a futures contract must exercise it at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include, but are not limited to, futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a specific commodity or underlying asset might move against the investor, requiring that the investor sell futures contracts at a loss. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss, and that past performance is not indicative of future results. Over time, assets will fluctuate in value, sometimes being worth more and sometimes less than the initial investment amount. Depending on the investment type, differing risk levels will exist. RMR cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, each client may view financial loss differently and may depend on many distinct risks, each affecting the probability and magnitude of potential losses. The following additional risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services. (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - The Adviser's investment activities involve significant risk. The performance of any investment is subject to numerous factors beyond RMR's control and beyond its predictive ability. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or deviate from expectations, adversely affecting a client's ability to realize profits or resulting in material losses. Client and RMR investment decisions will not always be profitable. Artificial Intelligence - We may leverage artificial intelligence ("AI") to enhance operational efficiency and improve client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment advice. Instead, our AI applications primarily automate administrative and client service tasks, including meeting preparation, note-taking, CRM updates, task management, and the generation of meeting recap notes. We believe AI streamlines client engagement, reduces administrative burdens, and ultimately enhances the overall client experience. It is essential to recognize that AI models are inherently complex and that their outputs may be incomplete, inaccurate, or biased. While AI augments our operations, its use introduces risks, including inaccuracies, decision-making errors, and challenges in its effective deployment. Additionally, AI usage may pose risks to the confidentiality of client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations 39  of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information— such as material non-public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both client and proprietary information. We continuously evaluate the performance of AI technologies to ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance. Business Risk - The risks associated with a specific industry or company. Competition Risk - The securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and when preparing financial reports. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and a Code of Ethics, ensuring that the client's interests are always held above those of the firm and its associates. Credit Risk - Credit risk typically applies to debt investments, such as corporate, municipal, and sovereign fixed-income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment's originating country. Diversification Risk - A portfolio may not be sufficiently diversified across sectors, industries, geographic areas, security types, or issuers. These portfolios might be subject to more rapid changes in value than would be the case if the investment vehicles were required to maintain broad diversification across companies or industry groups. Equity Investment Risk - Generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease in value; the investment may incur a loss. Financial Risk - The possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders in the event of insolvency. Financial risk also refers to the possibility that a corporation or government will default on its bonds, resulting in bondholders losing money. Foreign/Non-U.S. Investments - From time to time, advisers may invest and trade a portion of client portfolios in non- U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, and enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may hold foreign currencies directly and purchase and sell them through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the US dollar's strength relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may miss the benefits of favorable exchange rate movements. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' 40  operations in such markets. Hedging Transaction Risk - Investments in financial instruments such as forward contracts, options, commodities, and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in those positions' values or prevent losses if they decline, but rather establishes other positions designed to gain from the same developments, thus moderating the portfolio positions' decline in value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, such as losing your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you have to sell when markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state, and, therefore, are subject to transfer restrictions, and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - Leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements may require the pledging of additional collateral or the liquidation of account holdings, forcing the account to close positions at substantial losses not otherwise realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or using different leveraging strategies. Limited Partnerships Risk - A limited partnership is a financial arrangement with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business, has management authority, and is personally liable for the business's debts. And in the event of bankruptcy, it is responsible for all debts that remain unpaid or undischarged. The limited partners have no management authority and are liable only for their capital commitment. Profits are divided between general and limited partners according to an arrangement made at the partnership's creation. The range of risks depends on the nature of the partnership and is disclosed in the offering documents for privately placed offerings. Publicly traded limited partnerships share risk characteristics with equities. However, like privately placed limited partnerships, they are subject to a different tax regime than equities. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - Long-term trading is designed to capture returns and market rates. By its nature, the long- term investment strategy can expose clients to risks that typically surface at multiple points over time as they hold 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. Margin Risk - Securities purchased on margin in a client's account serve as the firm's collateral for the client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing advance written notice or the entitlement to an extension of time on the margin call. 41  Market Risk - Market risk is the possibility that an investment's current market value will decline due to a general market decline, regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Market Timing Risk - The risk of market timing based on charting and technical analysis is that charts may not accurately predict future price movements. Current securities prices may reflect all information known about the security. Daily changes in market prices of securities may follow random patterns and be difficult to predict with high accuracy. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, using fundamental analysis may not yield favorable returns. The risk of cyclical analysis is that economic/business cycles may be unpredictable and exhibit significant fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty of predicting economic trends and, consequently, the changing value of securities affected by these trends. Material Non-Public Information Risk - Because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction it otherwise might have and may not be able to sell an investment it otherwise might have. Non-U.S.Investment Risk - Investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - An account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of comparable-sized investment entities. Private Investment Risk - Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors over a short period could require a fund to liquidate its securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting its investment strategy. Private Placement Risks - A private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended period, making them difficult to sell. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - An adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data, or seek independent corroboration when appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Recommendation of Particular Types of Securities Risk - We may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible 42  to list all the specific risks of every investment type here. Even within the same kind of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - The risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - Occurs when investors lack the right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of a firm's key personnel, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not be able to find equally desirable replacements, and the accounts' performance could be adversely affected. Short-Sales Risk - Short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of an unlimited increase in the market price of the investment sold short, resulting in an inability to cover the short position and an unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - Securities of companies with small and medium market capitalizations are often more volatile and less liquid than those of larger companies. Small- and medium-cap companies may face a higher risk of business failure, thereby increasing the volatility of the client's portfolio. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially lower than those of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stock Risk - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health and the issuing of it. However, stock prices can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the issuing company's market sector, and the overall health of the market. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"). Still, the sheer size of an issuer is not, by itself, an indicator of the investment's safety. Stock Fund Risk - Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the greatest potential danger to investors in stock funds. Stock prices can fluctuate for various reasons, such as the overall strength of the economy and demand for products or services. Stock Market Risk - A stock's market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate in the short term due to factors affecting individual companies, industries, or the broader securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - Individual institutions may be restricted from directly using certain investment strategies that the Adviser may employ. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use a derivative component as a put option written by the investor, giving the buyer the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide a call option written by the investor, giving the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function that protects the principal if held to maturity. However, these products are not always insured by the Federal Deposit Insurance Corporation; the issuer may insure them, leaving the potential for principal loss in the event of a liquidity crisis or other solvency problems with the issuing 43  company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and other events that are difficult to predict. Supervision of Trading Operations Risk - An adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks -These are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - For all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions, thereby exposing the Adviser to potential losses. Turnover Risk - At times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would correspondingly increase brokerage commission expenses and may result in additional capital gains being distributed for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - Identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation, these investments involve significant financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - These are risks specific to a particular investment. Also known as "diversifiable risks," diversifying investments may, in theory, significantly reduce unsystematic risks. Warrant Risks - A warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, a warrant's lifetime is often measured in years, whereas a typical option's is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - An Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals over a short period could require a fund to liquidate its securities and other investments more rapidly than would otherwise be desirable, reducing the value of its assets and disrupting its investment strategy. RMR attempts to address the above risks by diversifying across multiple asset classes and strategies, creating distinct portfolio segments. Any security eligible for inclusion in a portfolio with low or no liquidity may be removed and replaced with the next- highest-ranked security in the same asset segment. Due to the fluctuating nature of security prices, the weighting of an individual security or sector in the portfolio may change after the portfolio is established. RMR does not represent or guarantee that the services provided or any analysis methods provided can predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of future client account performance or any level of performance; the success of any investment decision or strategy used; overall account management; or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. 44  The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including those noted above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed, may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate widely, mirroring the overall stock and bond market. Before acting on RMR’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, and other financial Investment Professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable IAR. ITEM 9: DISCIPLINARY INFORMATION ____________________________________________________________________________________________________ Legal or Disciplinary Event Disclosure Registered investment advisers are required to disclose all material facts concerning any legal or disciplinary events that may be relevant to a client's or prospective client's evaluation of the adviser or its management’s integrity. A state regulatory agency took disciplinary actions against certain members of RMR's management for violations of securities regulations, rules, and/or statutory provisions. These matters have since been resolved. For complete details on our disciplinary history and full disclosure documents, please visit the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov and search for our firm name or CRD #169005. Beyond these matters, neither the Adviser nor its management has any additional disciplinary or legal proceedings to disclose that would be material to a client’s evaluation of this advisory practice. RMR has no outstanding issues, and the firm, along with all Control Persons, is appropriately registered and free of restrictions. You may also view information about any affiliated person who is registered or required to be registered as an Investment Adviser Representative of the firm by similarly searching their name or CRD # on the same IAPD website. Copies of this information can also be obtained by contacting us directly. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ____________________________________________________________________________________________________ RMR is an independent registered investment advisory firm that provides investment advisory and other services indicated within this Form ADV 2A Disclosure brochure. The firm does not engage in business activities or offer services other than those described herein. Certain RMR Associates may sell additional products or provide services outside their roles with the Adviser, as indicated in their Form ADV 2B brochure Supplements and below. Broker-Dealer & Registered Representatives of a Broker-Dealer RMR is not registered and does not intend to register as a broker-dealer. From time to time, and in connection with their approved outside business activities, certain of RMR’s Associates may also be Registered Representatives (“RRs”) of non-affiliated broker-dealers, Members of FINRA and the SIPC. When acting in the capacity of RRs of such unaffiliated broker-dealers, these Associates will sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, variable annuities, or others to clients and receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. (See “Conflicts of Interest” at the end of this section for additional important information.) Investment Advisor Representatives of Other Unaffiliated Investment Advisory Firms Certain RMR IARs are also registered IARs of other non-affiliated registered investment advisory firms. IARs who maintain outside business activities with such firms are required to provide the disclosure documents of the outside investment adviser’s disclosure brochures and documentation. RMR clients should understand that any assets they place under the management or within any other outside investment advisory firm’s programs are separate and distinct from their Agreement and assets managed by RMR. Further, a conflict of interest arises to the extent that, while the services offered by RMR and another unaffiliated adviser may be similar, clients' fees and other costs for those services may differ. 45  RMR does not share any portion of the investment advisory fee a client will pay for another firm due to an RMR Associate’s outside business activity. Commissions or other compensation earned by our Associates in their capacities as employees of unaffiliated firms are separate and in addition to the advisory fees paid to RMR under our Agreements. (See “Conflicts of Interest” at the end of this section for additional important information.) Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither the Adviser nor any management persons are registered or intend to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an Associated Person of the preceding entities. Insurance Sales & Services Affiliated & Unaffiliated Insurance Agencies RMR Wealth Builders, Inc., the investment adviser, is affiliated with RMR Wealth Builders, Inc., a New Jersey Insurance Producer of a similar name (Insurance Producer License # 8729246). RMR’s insurance-licensed Investment Professionals will offer variable life, variable annuity, accident & health, sickness, and life or other insurance products from time to time and when appropriate to their RMR advisory clients in connection with their approved outside business activities for these products and recommend that advisory clients consider either insurance products or services. Insurance Company personnel also retain the discretion to introduce non-advisory clients to the investment adviser for advisory services. In this capacity, in addition to their compensation from RMR, insurance-licensed Investment Professionals can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of insurance products from the insurance agencies with whom they are presently or with whom they may become appointed in the future. The insurance commissions earned by these individuals are separate from and in addition to RMR’s advisory fees. Commissions are based on the insurance products provider's standard commission schedule and are generally not negotiable. This presents a conflict of interest since, to the extent that clients of the investment adviser can also use an Insurance Company’s services, the activities and fees of such companies are essential to understand. RMR Associates, licensed as Insurance Agents, are incentivized to effect suitable insurance transactions based on the potential for commission compensation received rather than the client’s best interests. Advisory clients should be aware that when using the services of any such insurance entity, such services are not provided by RMR, the investment adviser. Any insurance services offered are separate and distinct from the client's relationship, the Advisory Agreement, and the services provided by RMR (the investment adviser). The insurance commission paid to licensed Insurance Agents will be based on the standard commission schedule of the insurance products provider and is generally not negotiable. Insurance commissions are separate from RMR’s advisory fees. The services of companies other than the Adviser are also subject to separate and distinct contractual arrangements. Further, the protections afforded to clients under applicable investment advisory laws and regulations generally do not apply to those provided by any RMR affiliate or an unaffiliated company. Clients are under no contractual or other obligation to purchase insurance products through any person affiliated with the Adviser or to utilize the services of any affiliate or other industry relationship. Advisory clients maintain complete discretion regarding whether to use the services of RMR, RMR-affiliated entities, or other industry relationships that may be recommended. (See “Conflicts of Interest” at the end of this section for additional important information.) Designations & Other Outside Business Activities Our IARs can, with approval, operate their own independent companies outside of RMR. These unaffiliated companies include, among others, accounting and tax practices and insurance services. As such, there is a potential conflict of interest because RMR’s Investment Professionals can earn compensation from RMR and the unrelated business activity. In addition, RMR Associates holds various other designations in connection with these approved outside business activities, separate from their role as IARs with RMR. RMR does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from RMR’s advisory services and fees. (See “Conflicts of Interest” at the end of this section for additional important information.) Recommendation of Other Advisers & Third-Party Money Managers RMR may allocate all or a portion of client assets to a third-party adviser or manager. RMR receives compensation from third- party referred managers and advisers that we recommend, and, in such instances, the fees may be shared between RMR and 46  the third-party adviser or manager. Before selecting any outside manager, RMR will review the manager to ensure they fit the adviser’s models' criteria and conduct initial background due diligence. Referred managers must be registered with an appropriate regulatory body and enter RMR's Terms and Conditions Agreement before being included as a potential client referral. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which clients are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style - will be disclosed in each contract between the RMR, the third-party money managers, and the client. RMR reserves the right to add or delete managers as deemed necessary. These compensation arrangements create a conflict of interest because they give RMR a financial incentive to recommend the third party's services. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended referred managers. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access plan participants' accounts to offer advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to offer advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans for which RMR and its IARs are the advisors of record. Future Clients RMR may provide investment advisory services to other clients in the future. Other future clients may have investment objectives, programs, strategies, and positions that are similar to, or may conflict with, those of our current clients, or may compete with or have interests adverse to our current clients. This conflict could affect the prices and availability of financial instruments in which the current clients invest. However, there can be no assurance that future clients with similar investment objectives, programs, or strategies will hold the same positions or perform in substantially the same way as our current clients. Furthermore, our activities regarding future clients could conflict with those regarding our current clients. RMR may give advice or take action for the investments and transactions in one client account that may differ from the advice given or the timing or nature of action taken for financial instruments and transactions for other client accounts due to a variety of factors, such as regulatory and tax issues and differences in investment programs. As a result, even though our clients may share similar investment objectives and strategies, they may have substantially different portfolios and investment returns. Conflicts of interest may also arise when we make decisions on behalf of clients whose interests differ. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Other Business Relationships RMR uses third-party resources to help run its business and provide services to its clients, mostly back-office related. RMR sources these professionals, striving to act in a client’s best interest with fiduciary responsibility while focusing on finding the highest-value-added providers to serve clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise - neither RMR nor its Associates receive compensation for such use or referrals. Conflicts of Interest The practice of making clients aware of the above other financial activities, affiliations, designations, and relationships, and the services discussed above, presents a conflict of interest since RMR’s Investment Professionals may have an economic incentive to submit advisory clients to certain companies or services over others due to potential compensation received in connection with the transaction. This can incentivize them to introduce their clients to professionals or services for their own compensation rather than for their clients' needs. Likewise, persons associated with the affiliated companies or outside relationships may refer their non-advisory clients to RMR. 47  RMR addresses this conflict of interest by requiring Associates to always act in each client's best interests. Before the transaction, RMR’s Investment Professionals must fully disclose such relationships when making recommendations. If offering clients advice or products outside of RMR, they satisfy this obligation by advising and revealing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid/received before transaction execution. When acting in this capacity, RMR’s Investment Professionals are not acting on behalf of RMR, the investment adviser, concerning the client's services under an RMR Advisory Agreement. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. Further, they are not obligated to place the transaction through RMR if they elect to act on any recommendation received. The client may act on recommendations received by placing their business and securities transactions with any brokerage firm or third party. RMR makes no assurances that another entity's products or services are at the lowest available cost. Clients may obtain the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Additional details on how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance, supervisory policies and procedures, and Code of Ethics. RMR's Code is available for free review upon request to any client or prospective client. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. ITEM 11: CODE OF ETHICS, PARTICIPATION, OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ____________________________________________________________________________________________________ Description of Our Code of Ethics Rule 204A-1 of the Advisers Act requires all investment advisors registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires compliance with federal securities laws. RMR takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Personnel who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing, and that it holds Associates to a very high standard of business practices and integrity. To that end, RMR has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. RMR strives to comply with applicable laws and regulations governing our practices. The adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all RMR Associates, including individuals registered with the adviser as IARs or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the CCO designates. RMR's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to fully comply with all applicable industry regulations and the firm’s guiding principles, as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates to abide by all state and federal securities laws and provisions relating to client information confidentiality, insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Associates are required to attest, no less than annually, to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every licensed IAR of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required. Additional details on how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance, supervisory policies and procedures, and Code of Ethics. RMR's Code is available for free review upon request to any client or prospective client. An electronic copy of our Code of Ethics is also available for your review at www.rmrwealth.com. Participation or Interest in Client Transactions RMR and its Supervised Persons may buy or sell the same securities we recommend to clients or hold in client accounts. This practice creates a potential conflict of interest because associated persons could trade in these securities before or after client transactions and receive more favorable pricing. To mitigate this conflict, RMR’s policy prohibits the firm and its personnel from 48  having priority over client accounts. When the same or similar securities are traded, client transactions are executed first, and the firm monitors same‑day trading to ensure that clients receive execution prices equal to or better than those obtained by the advisor. All transactions that may give rise to a conflict are documented and reviewed in accordance with firm procedures. RMR also serves as the sub‑adviser to the publicly traded PeakShares RMR Prime Equity ETF (“PRMR”) and may invest client assets in PRMR when appropriate. Purchases of PRMR by related people are executed through a model account managed by RMR and are subject to the firm’s pre‑clearance procedures, unless a documented exception applies. In addition, RMR prohibits the firm and its Associates from sharing in the profits or losses of any securities transactions executed for client accounts. Personal Trading Practices RMR recognizes that personal investment transactions by its members and Associates require adherence to a high ethical standard and must never compromise a client’s interests. When clients' and the firm's personnel have similar investment objectives, it is reasonable for them to invest in some of the same securities. However, all such activity must occur in a manner that protects clients and complies with RMR’s Code of Ethics. RMR’s Code includes a Personal Securities Transactions & Trading Policy that establishes requirements for personal trading, including pre‑clearance of certain transactions and ongoing reporting designed to monitor compliance. The Code also contains policies and procedures addressing insider‑trading prohibitions, other personal securities transactions, and the safeguards expected of all Associates. Upon employment or affiliation—and annually thereafter—Associates must acknowledge in writing that they have read, understand, and agree to comply with the Code. Associates must also affirm that they will conduct business honestly, ethically, and fairly, avoiding any conduct or circumstances that could impair, or appear to impair, their duty of loyalty to clients. RMR strictly prohibits insider trading and has adopted comprehensive policies and procedures to ensure compliance with federal and state securities laws. Associates receive guidance on the handling of material non‑public information and are prohibited from benefiting from the short‑term market effects of client recommendations. While Associates may buy or sell securities for their personal accounts when consistent with the Code of Ethics, client interests always take precedence, and such transactions may not disadvantage any advisory client. Conflicts of Interest RMR’s policies prohibit the firm, its Associates, and any related persons from engaging in trading activity that is detrimental to clients or inconsistent with the firm’s written supervisory procedures, Code of Ethics, or applicable securities regulations, including all prohibitions on personal and insider trading. Associates must disclose, pre‑clear, and report certain personal securities transactions and maintain all required records to ensure that no Associate receives preferential treatment or otherwise affects the markets to the detriment of clients. To reinforce adherence to these requirements, RMR conducts Access Person trade reviews on a quarterly, annual, and as‑needed basis to verify compliance with the firm’s policies and to confirm that no conflicts of interest have occurred. Potential conflicts and any trades requiring review are documented and monitored in accordance with firm procedures. Additional information regarding RMR’s conflict‑mitigation practices is available in the firm’s comprehensive written compliance supervisory policies and procedures and its Code of Ethics. A copy of the Code is available to any client or prospective client upon request, free of charge. ITEM 12: BROKERAGE PRACTICES ____________________________________________________________________________________________________ Broker‑Dealer & Qualified Custodian Selection RMR does not maintain physical custody of client funds or securities, other than the limited authority to deduct advisory fees as disclosed herein. RMR recommends broker-dealers and qualified custodians that provide institutional brokerage, trading, custody, reporting, and related services to independent investment advisers and their clients. These services often differ from those available to retail investors; however, certain retail clients may be able to access similar services directly without engaging an adviser. 49  RMR conducts a formal review of its broker‑dealer and qualified custodian selections at least annually. In making these recommendations, RMR seeks firms that can provide custody and execution services on overall terms most favorable to clients, taking into account a broad range of factors. RMR’s client assets are maintained with independent, unaffiliated qualified custodians in accordance with each client’s Advisory Agreement. . For portfolio management services, Fidelity Investments Institutional Services Company, Inc. (“Fidelity”), or Charles Schwab & Co., Inc. (“Charles Schwab”), each an independent and unaffiliated registered broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), will take possession of client account cash, securities, and other assets, unless the client directs otherwise. Clients receiving Digital Asset services will maintain their Digital Assets with Fidelity Digital Assets®, custodied by Fidelity Digital Asset Services, LLC. For Retirement Plan Services, client assets remain held with the retirement plan’s custodian or trustee, as designated by the plan sponsor or Responsible Plan Fiduciary. RMR does not take custody of plan assets and provides advisory or fiduciary services in accordance with ERISA and the applicable plan documents. For Registered Investment Company Sub-Advisory Services, including exchange-traded funds, client assets are held by the fund’s independent custodian. Investors do not maintain individual custodial accounts with RMR, and RMR does not hold fund shareholders' assets in custody. Custody arrangements are disclosed in the applicable fund prospectus and related regulatory filings. Brokerage practices for registered investment companies, including ETFs, are subject to additional regulatory requirements under the Investment Company Act of 1940 and related SEC rules. In this capacity, RMR places trades in accordance with the fund’s prospectus, statement of additional information, board‑approved policies, and any trading instructions issued by the primary adviser. RMR’s brokerage practices are also subject to oversight by the fund’s adviser and board of trustees pursuant to the fund’s Compliance Program. (Note: When RMR recommends that a client purchase shares of an ETF, including a fund for which RMR serves as sub‑adviser, such recommendation relates solely to the client’s brokerage account and does not affect the custody, trading, or brokerage practices of the fund itself.) For Pontera Services, RMR does not have custody of client assets. Client accounts remain held at the plan’s recordkeeper or custodian. Pontera provides a technology platform that permits RMR, with client authorization, to obtain limited, functional access to accounts for advisory purposes only, without transferring custody, ownership, or control of assets. While RMR maintains relationships with certain preferred qualified custodians, other custodians, including mutual fund companies, may be utilized as appropriate based on the type of account established. (For example, certain 529 Plan accounts are maintained with American Funds.) All custodial relationships are disclosed to clients in advance. Factors Considered in Selecting/Recommending Broker-Dealers for Client Transactions & Determining Compensation Reasonableness Broker-dealers and third-party qualified custodians are in the business of serving independent investment advisory firms like RMR and provide advisers and their clients with access to institutional brokerage, trading, custody, reporting, and related services – many of which are not typically available to retail customers. However, certain retail investors may be able to obtain institutional brokerage services from broker-dealers and qualified custodians without going through us. The various support services that help an adviser oversee and administer client accounts and manage and grow their advisory business are typically available at no charge if qualifying amounts of client account assets are maintained with the custodian. In recognition of the value of the custodian's services, clients may pay higher commissions and/or trading costs than those available elsewhere. RMR reviews broker selection annually at a minimum and, in making its preferred broker-dealer/qualified custodian selection, seeks to recommend firms in this role that will hold client assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. RMR’s selection process is based on many factors. 50  When considering whether the terms provided are advantageous to clients, we take into account a wide range of factors, including but not limited to the following:  The combination of transaction execution and asset custody services.  Capability to execute, clear, and settle trades (i.e., buy and sell securities for client accounts).  Capability to facilitate transfers and payments to and from accounts (i.e., wire transfers, check requests, bill payments, etc.).  Availability of investment research and tools to assist in making investment decisions.  Best execution and the competitiveness of the price of those services (i.e., commission rates, margin interest rates, other fees, etc.).  The custodian’s reputation, financial strength, security, and stability.  The prior and existing relationship with our firm and our other clients.  Research or other products or services delivered or paid for by the approved custodian.  The overall quality of services.  Availability of other products and services that benefit us, as discussed below. Qualified Custodian Brokerage & Custody Costs Client accounts custodied at our preferred broker-dealers/qualified custodians typically do not incur separate custody fees. Instead, the custodian is compensated through commissions or other transaction-related fees. Certain trades, such as many mutual funds and ETFs, may not incur transaction fees; in those instances, custodians can earn revenue through interest spreads on uninvested cash or other internal sources. The client accounts maintained at our preferred broker-dealers/qualified custodians are generally not charged separately for custody services, but are compensated by charging clients commissions or other fees on trades executed or settled into the custodial account. Certain trades, such as mutual funds and ETFs, do not incur commissions or transaction fees. Instead, the qualified custodian is compensated by earning interest on the uninvested cash in the client’s Cash Features or similar account programs. RMR is not required to select the broker or dealer with the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. (For example, Schwab charges clients a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a different broker-dealer, but where the securities bought or the funds from the securities sold are deposited/settled into the Schwab account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. Because of this, we have Schwab execute most client account trades to minimize client trading costs. Although we are not required to execute all trades this way, we have determined that having Schwab execute most trades is consistent with our duty to seek "best execution" of client trades - the most favorable terms for a transaction based on all relevant factors, including those listed above. clients may pay lower transaction costs by using another broker or dealer.) Our preferred broker-dealers/qualified custodians also offer a range of support services. Some help us manage or administer our clients' accounts; others help us manage and grow our business. These custodial support services are generally unsolicited; advisers do not have to request them. The following provides a more detailed description of these support services: Services That Benefit Clients Our qualified custodian’s Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through them include some that we might not otherwise have access to, or that would require a significantly higher minimum initial investment for our clients. The services described in this paragraph benefit our clients and their accounts. Services That May Not Directly Benefit Clients Our qualified custodians also make other products and services available to us that may not directly benefit our clients or their accounts. These products and services help us manage and administer our clients' accounts and operate our firm. They include investment research, both the qualified custodian’s and third parties'. We may use this research to service all or a substantial number of our clients' accounts. In addition to investment research, they also make available software and other technology that: 51   Provide access to client account data (such as duplicate trade confirmations and account statements).  Facilitate trade execution and aggregate trade orders across multiple client accounts.  Provide pricing and other market data.  Facilitate payment of our fees from our client accounts.  Assist with back-office functions, recordkeeping, and client reporting. Services That Generally Benefit Only Us Other services to help us manage and further develop our business enterprise include:  Educational conferences and events.  Consulting on technology, compliance, legal, and business needs.  Publications and conferences on practice management and business succession.  Access to employee benefits providers, human capital consultants, and insurance providers.  Marketing consulting and support. Our preferred qualified custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services to us. They can also discount or waive their fees for some of these services for us, or pay all or part of a third party's fees. We are also provided other benefits, such as occasional business entertainment for our personnel, which we would be required to pay for out of our own resources if client accounts are held elsewhere. RMR regularly uses most of these services, some of which affect our daily operations, while others are used less frequently, as described herein. Research & Soft-Dollar Benefits An investment adviser receives custodial soft-dollar benefits when the firm obtains custodial research or other products or services related to client securities transactions. RMR can receive certain benefits from our broker-dealers/qualified custodians. These benefits include, but are not limited to, electronic access and download of trades, balances, and positions; confirmation and statements in the broker-dealer's or qualified custodian's portfolio management software; and access to related blotters, duplicate, and batched client statements, confirmations, and year-end summaries. RMR also receives a dedicated trading desk and service group that assists our clients, an account services manager dedicated to our accounts, access to a real-time order matching system, mutual funds with no transaction fees, and select institutional money managers. In addition, we can receive discounts on compliance, marketing, research, technology, and practice management products or services provided by third-party vendors, and the ability to have advisory fees directly debited from client accounts, in accordance with applicable federal and state requirements. Our approved, qualified custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services, offer discounts, waive fees for some of these services, or pay all or part of a third party's fees. In effect, the fees our clients pay generate the soft dollars used to pay for these administrative services. The Adviser will not seek to allocate soft-dollar benefits to client accounts in proportion to the soft-dollar credits the accounts generate. The availability of the above services, commonly called "soft dollars," benefits us because we do not have to produce, purchase, or pay for them, as long as our clients collectively maintain a minimum amount of assets in our qualified custodian accounts. Beyond that, these services are not contingent upon our committing any specific amount of business in trading commissions or assets in custody. A conflict exists in such situations because RMR can be incentivized to select or recommend a broker-dealer based on the Adviser’s interest in receiving research or other products or services rather than the Adviser’s clients’ interest in receiving the best value in custody services and most favorable execution of their transactions. While the conflict of interest exists, our clients also measure our overall performance; the cost of these services necessarily reduces portfolio performance. It is in our best interests to minimize these costs to improve the overall performance of client portfolios. Furthermore, we believe that selecting any qualified custodian and broker-dealer is in our clients' best interests. The scope, quality, and price of services received primarily support our selection, not services that benefit only us. (Please contact us directly for the most current qualifying amount of client assets.) 52  Brokerage for Client Referrals RMR and its Associated Persons do not receive client referrals from broker-dealers or third parties when selecting or recommending brokers for client accounts. Directed Brokerage Clients are free to use the broker-dealer/qualified custodian or financial institution of their choice for any recommendation. However, clients who select RMR as their investment manager must maintain their accounts at one of our approved broker- dealers/qualified custodians. Clients should be aware that not all advisers require their clients to direct brokerage. Clients who wish to direct brokerage will do so in writing and shall be responsible for negotiating the terms and arrangements with the broker-dealer/qualified custodian of their choosing. RMR will not be obligated to seek better execution services or prices, or to aggregate client account transactions for execution through other custodians, for orders on different accounts we manage. As a result, a disparity in commission charges can arise between those charged to clients who do not direct brokerage and those who do, potentially resulting in higher trading expenses and less favorable transaction execution for clients with directed brokerage. Directing brokerage may cost the client money. Clients wishing to direct brokerage should consider the costs or disadvantages of such requests, including paying higher commissions or other transaction costs, wider spreads, being unable to aggregate orders to reduce transaction costs, or receiving less favorable prices on transactions for the account than would otherwise be the case. Accordingly, clients should ensure that their designated broker can provide fair prices and execute their transactions. Subject to its duty to seek best execution, RMR may also decline a client's request to direct brokerage if, at our discretion, such brokerage arrangements would result in operational difficulties. Directed Brokerage - Special Considerations for ERISA clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted if the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. (Note: ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan.) Best Execution RMR has a duty to seek the best execution. RMR conducts initial and ongoing due diligence on soft dollars, directed brokerage, and best execution, as a matter of policy and practice. The Adviser seeks to ensure compliance with clients' Agreements and IPS documents if prepared for the type of account established, and observe best practices. For registered investment company sub-advisory services, RMR will seek best execution for fund transactions consistent with applicable legal and regulatory standards and the fund’s governing documents. However, a client may pay a higher commission than another qualified custodian would charge for the same transaction when it is determined, in good faith, that the commission is reasonable based on the value of the brokerage and research services received.. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the full range of services available, including, among others, the value of research provided, execution capability, financial strength, commission rates, and responsiveness. While RMR will seek competitive rates, they may not obtain the lowest commission rates for client transactions. Trade Aggregation RMR combines multiple orders for shares of the same securities purchased for the advisory accounts we manage ("aggregated trading"). The trade aggregation practices observed under each advisory offering are as follows: 53  Aggregation Practices by Program CIP Accounts - CIP Accounts Managed Outside RMR Programs – Not included in block trades. - CIP Accounts in RMR‑ Managed Model Programs – Included in block trades during model rebalancing; excluded from one‑off trades for cash needs. TPM Wrap Fee Programs - Aggregation, if any, is determined by the third‑party manager’s trading practices. Failure to aggregate orders may result in higher commissions or less favorable execution. Trade Errors RMR recognizes that, despite strong controls and oversight, trade errors may occur. A trade error is any transaction in a client account that breaches regulatory requirements, contractual obligations, investment guidelines, or account‑specific restrictions. When an error is identified, it is reported immediately for internal review so corrective action can be taken promptly and to ensure that the client is not disadvantaged. RMR’s policy is that client interests always come first. Trade errors are corrected promptly to return the client’s account to the position it would have been in had the error not occurred. Corrective actions may include canceling the transaction, reallocating or adjusting the trade, or reimbursing the client account. In general, clients are reimbursed for losses resulting from RMR’s trade errors and are made whole. Gains resulting from a trade error will either remain in the client’s account or be transferred to an error account to offset error‑related losses. A transaction that is executed at a different time or price than another client’s transaction due to an electronic malfunction or another issue outside of RMR’s control is not considered a trade error attributable to RMR. RMR is also not responsible for losses caused by third parties—such as custodians, clearing firms, mutual funds, or insurance companies—when RMR has correctly submitted an order in accordance with its procedures. Clients should note that mutual funds and certain other investment vehicles reserve the right, as disclosed in their prospectuses, to reject, delay, or otherwise restrict trades, and RMR has no authority to alter such provisions. If an error results from inaccurate, incomplete, or unclear instructions provided by the client, any resulting loss is the client’s responsibility. Clients or prospective clients may contact RMR’s CCO with any questions about these policies or to discuss any perceived conflicts of interest related to the handling of trade errors. ITEM 13: REVIEWS OF ACCOUNTS ____________________________________________________________________________________________________ Client Account Reviews - Frequency, Nature & Oversight Initial client Agreements are reviewed and approved by the CCO, their Designee, or another firm Principal, as appropriate. Designated Supervisors will also periodically review ongoing client account transactions and oversee IAR annual account review obligations. Because a client’s goals, objectives, and financial circumstances may change over time, RMR and the client’s assigned IAR will periodically review the client’s financial situation and portfolio through regular communications and, at a minimum, annual meetings. These reviews are intended to assess changes in the client’s circumstances or investment objectives, confirm the continued appropriateness of any account‑level limitations or restrictions, and determine whether the client wishes to modify any previously established guidelines or restrictions. Reviews for RMR’s specific advisory services occur as follows: Portfolio Management Services Accounts IARs will review, quarterly, periodically, and as needed, the portfolio management services client accounts they manage directly as part of the reporting process. No less than annually, as indicated herein and within each client's executed Advisory 54  Agreement, IARs will meet with clients to review their investment objectives and financial situation to determine the suitability of investments, financial plans, and portfolio exposures. Such reviews can also include addressing the following considerations:  How did the portfolio perform on a nominal and relative basis over the last reporting period?  Did the portfolio meet its benchmark and objective(s)?  What parts of the portfolio/investments performed well or poorly?  Is the current portfolio allocation aligned with the target allocation outlined in the client’s IPS? If not, what changes are required? Does the target portfolio continue to make sense? Have changes in personal circumstances or the broader world occurred that suggest a need to change target allocations?  Have any other material events occurred to suggest that an investment change be made at this time? Additional reviews are conducted based on various circumstances, including, but not limited to, changes in client risk/return objectives, contributions and withdrawals, market-moving events, security-specific events, and/or year-end tax planning. accounts may also be examined based on other triggering events, such as:  New cash flow of funds for investment.  Significant portfolio liquidation and disbursement requests.  A substantial change in the client's financial circumstances.  A considerable difference in financial market status. Non‑periodic reviews may also be triggered by factors including material market, economic, or political events; client complaints; transactions flagged by a Designated Supervisor; or material changes in a client’s financial situation, such as retirement, termination of employment, relocation, or inheritance. According to each TPM’s’ Wrap Fee Program account manager’s agreement, TPMs have internal procedures in place, as described within each manager’s client account contract and other account opening documents, to conduct periodic reviews of client accounts to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Annuity Management Services Accounts Annuity management services accounts are reviewed at least annually, following the above review parameters, as applicable to the account type established. Digital Asset Services Accounts Digital Asset services accounts are reviewed at least annually, following the above review parameters, as applicable to the account type established. Financial Planning & Consulting Services Financial planning and consulting services documents are reviewed upon completion and before delivery to the client. No investment account is required to engage in these advisory services. Additional reviews may be conducted at the client’s request. RMR encourages clients to contact the firm for a review when their personal or financial circumstances change, including, but not limited to, marriage, divorce, birth, death, inheritance, litigation, retirement, job loss, or disability. RMR may also recommend more frequent reviews as clients approach significant life transitions, such as a job change or retirement, to determine whether updates to the financial plan are appropriate. Written updates to a financial plan may be provided in conjunction with a review. Such updates may be subject to RMR’s then‑current hourly rate and require the client’s prior written approval before work commences. Retirement Plan Services Retirement plan services accounts are reviewed no less than annually, following the portfolio management services account review parameters as applicable to the account type established. 55  Registered Investment Company Sub‑Advisory Services RMR’s registered investment company sub-advisory services accounts are reviewed in accordance with the fund’s Compliance Program, including the requirements of Rule 38a‑1 under the Investment Company Act of 1940. These accounts are subject to oversight by the primary adviser and the fund’s board of trustees, consistent with their responsibilities under the fund’s governing documents and applicable SEC rules. RMR conducts ongoing reviews of its sub‑advisory activities in accordance with its internal compliance policies and procedures and performs an annual Compliance Program review as required under Rule 206(4)‑7. These reviews occur under the oversight of the primary adviser and the fund’s CCO. Other Advisory Services Pontera services and educational seminars and workshop services do not involve account reviews, as these services do not include discretionary or ongoing portfolio management. Content & Frequency of Regular Reports Provided to Clients RMR communicates with clients through several means. Client meetings are generally held annually to review the client’s account and evaluate whether its investment strategy and holdings remain appropriate. Additional communications—including phone calls, emails, letters, and other correspondence—occur throughout the year as circumstances or client needs warrant. RMR may also provide market commentaries, articles, newsletters, or other educational materials on investment or financial planning topics. Clients do not receive reports, reviews, or statements beyond those required under Rule 206(4)‑2 of the Advisers Act or expressly included in their advisory agreement; however, RMR may provide additional reporting on an ad‑hoc basis if agreed upon by the client. For clients receiving registered investment company sub‑advisory services (including ETF sub‑advisory services), RMR does not provide separate account‑level statements or performance reports, as investors do not maintain individual accounts with RMR. All required shareholder reporting—such as prospectus updates, semi‑annual and annual reports, and other fund documents—is provided directly by the fund, its adviser, administrator, or custodian pursuant to the Investment Company Act of 1940. Custodial Statements & Reports At account inception, clients instruct their qualified custodian to provide account statements at least quarterly. These statements reflect all account activity during the reporting period, including holdings and account balances, all transactions (including buys, sells, contributions, withdrawals), fees and expenses charged, and beginning‑ and end‑of‑period values. Clients typically also receive trade confirmations from the custodian for each buy or sell transaction executed in their account. Custodial statements may include performance information, tax‑related documents, and other appropriate reporting. Duplicate copies of custodial statements and reports are provided to RMR if authorized by the client. RMR encourages clients to review custodial statements promptly upon receipt to ensure that all account activity appears accurate. Clients should also compare the performance of their account with an appropriate blended benchmark for the investment strategy employed, as well as with any supplemental information or reports provided by RMR. Custodian‑generated information may differ from information provided by RMR due to differences in accounting methods, reporting dates or cycles, pricing sources, or valuation methodologies for certain securities. Clients are encouraged to contact RMR with any questions regarding the custody, safety, or security of their assets, or regarding any account statement, confirmation, or report they receive. If a client identifies, or believes there may be, an inaccuracy, discrepancy, or lack of understanding in any such document, the client should notify RMR promptly upon discovery and, in all cases, before the next statement cycle, so that the matter may be reviewed and addressed as appropriate. Unless a client notifies RMR in writing of concerns regarding an account statement or of any specific investment restrictions or limitations, investments made in accordance with the client’s stated investment objectives and the terms of the applicable Advisory Agreement are deemed to be consistent with those objectives. 56  ITEM 14: CLIENT REFERRALS & OTHER COMPENSATION ____________________________________________________________________________________________________ Preferred Qualified Custodians RMR receives an economic benefit from its preferred qualified custodians through the custodial support products and services they make available to the firm. These services benefit RMR by reducing the resources the firm would otherwise need to devote to technology, operational support, research access, compliance tools, and practice‑management needs. Although clients do not pay higher fees because of these arrangements, the availability of these benefits creates a conflict of interest, as RMR has an incentive to recommend custodians that provide the firm with such services. Clients should carefully consider these conflicts, including the products and services offered by custodians, the benefits to RMR, and any related conflicts described in this brochure, when selecting a custodian. (See Item 12: Brokerage Practices for additional disclosures regarding research and other benefits received from custodians.) Economic Benefits Provided by Third Parties Certain custodians, mutual fund companies, or fund distributors can provide RMR’s Investment Professionals with educational programs, marketing support, product information, and occasional attendance at conferences or due diligence events. RMR can also receive 12b‑1 fees, as disclosed in applicable fund prospectus fee tables, and certain expense reimbursements related to these activities. These payments are typically made out of fund assets or fund affiliates’ assets and therefore do not appear in a fund’s expense table. RMR advisers do not receive higher compensation for recommending one mutual fund over another, and the percentage of compensation paid to individual IARs does not change based on the fund recommended. However, fund‑sponsored marketing and educational activities create a conflict of interest, as they may incentivize RMR or its IARs to favor funds that provide such benefits. No portion of these payments is derived from brokerage commissions generated by the funds. Promoter Relationships RMR reserves the right to engage compensated solicitors (“Promoters”) to refer prospective clients to the Adviser. When Promoters are used, they act as independent contractors and not as employees, representatives, or agents of RMR. Promoters may receive compensation in the form of either a flat fee or a percentage of the advisory fees earned from the accounts they refer, as outlined in a written agreement between RMR and the Promoter. This compensation creates a material conflict of interest, because Promoters have a financial incentive to recommend RMR’s services. Promoters who work with multiple advisers may also be incentivized to recommend advisers offering more favorable compensation. RMR conducts due diligence to reasonably confirm that any Promoter is not an “ineligible person” under Rule 206(4)-1 and is properly licensed or qualified where required. Unlicensed Promoters are limited to providing impersonal recommendations of RMR’s services and may not make statements regarding specific advice, portfolio construction, or the appropriateness of services for any individual. RMR also oversees its activities in accordance with regulatory requirements. To mitigate these conflicts, RMR requires Promoters to provide referred prospects, at the time of solicitation, with written disclosures that include whether the Promoter is a client or non‑client of RMR, that the Promoter is compensated for the referral, the material conflicts of interest arising from the relationship and compensation structure, and the material terms of the Promoter agreement, including a description of any compensation received. The Promoter will use its best efforts to solicit and refer to RMR those individuals or entities that it believes are in the client's best interests to be introduced to the investment advisory services we provide. Promoter services typically include introducing prospective clients to RMR and providing general information about the Adviser. In certain cases, Promoters may assist with updating client information or facilitating communications. Promoters must maintain the confidentiality of client information and may not disclose such information without proper consent. Promoters have no authority to accept clients on behalf of RMR, and RMR retains sole discretion to accept or decline any prospective client referred by a Promoter. Clients referred by Promoters do not pay higher advisory fees as a result of these arrangements. Required disclosures regarding the Promoter’s compensation, conflicts of interest, and relationship with RMR will be provided to each solicited client at the time of solicitation, consistent with the SEC’s Marketing Rule. As of the date of this brochure, RMR is not actively engaged in any Promoter arrangements. 57  Third‑Party Referral Program RMR may refer clients to the KEEP® Program, sponsored by StoneCastle Cash Management, LLC, and may receive a referral fee from StoneCastle when clients participate. RMR complies with similar requirements as those listed in the Promoter Relationship section when acting as a compensated Promoter for the KEEP® Program sponsored by StoneCastle Cash Management, LLC. (Additional information regarding this program and related conflicts is provided in Item 8: Methods of Analysis, Investment Strategies & Risk of Loss.) Sub‑Advisory Services RMR receives economic benefits in connection with its sub‑advisory relationships with registered investment companies, including revenue‑sharing and expense‑sharing arrangements pursuant to its agreements with fund advisers. These benefits are not paid directly by advisory clients. For the PeakShares RMR Prime Equity ETF, RMR participates in:  Expense‑sharing arrangements related to the launch and operation of the fund, under which certain non‑Fund expenses are allocated between the adviser and the sub‑adviser.  Revenue participation through a 50% share of Net Surplus advisory revenue received by the adviser, calculated quarterly.  Equity ownership interests in PeakShares LLC, determined by a formula tied to RMR‑related assets under management, which may increase RMR’s incentive to grow assets in PeakShares‑sponsored funds. These arrangements create conflicts of interest because RMR may have financial incentives to increase or maintain assets in PeakShares‑sponsored funds or in products associated with the adviser. RMR has adopted policies and procedures, including its Code of Ethics and conflict‑management processes, to identify, disclose, and manage these conflicts in a manner consistent with its fiduciary obligations under the Advisers Act. Conflicts of Interest Except for advisory fees paid by clients and the compensation arrangements described in this brochure, RMR does not receive additional economic benefits. Additional information on how we mitigate conflicts of interest can be found in our comprehensive written compliance supervisory policies and procedures and Code of Ethics. A copy of RMR’s Code of Ethics is available to clients and prospective clients for review upon request at no cost. ITEM 15: CUSTODY ____________________________________________________________________________________________________ Custodial Practices RMR does not maintain custody of client funds or securities for purposes of safekeeping. Client assets are maintained with independent, unaffiliated qualified custodians in accordance with each client’s Advisory Agreement and a separate written brokerage or custodial agreement between the client and the qualified custodian. Account checks, funds, wire transfers, and securities are delivered directly between the client and the custodian of record. (Additional information regarding RMR’s brokerage and custodial relationships is described in Item 12: Brokerage Practices.) RMR’s authority with respect to client assets is limited to the standard business practice of deducting advisory fees from client custodial accounts, provided the client has authorized it in writing. RMR does not otherwise have authority to withdraw, transfer, or take possession of client funds, securities, or other assets. (This authority applies only to advisory services for which fee deduction is expressly authorized and is further described in Item 12: Brokerage Practices.) To facilitate advisory fee payments, the independent qualified custodian will typically debit the client’s account directly pursuant to the client’s written authorization. Clients provide this authorization on the custodian’s required form and receive notice of each advisory fee deduction directly from the qualified custodian at their address of record. Although RMR does not have custody of client funds or securities for safekeeping purposes, its authority to deduct advisory fees constitutes limited custody under applicable SEC rules. RMR complies with the custody requirements applicable to advisers with limited custody, including maintaining client assets with qualified custodians and ensuring clients receive custodial account statements directly from such custodians. 58  Wire Transfers, Check-Writing Authority & Standing Letters of Authorization As described in Item 12: Brokerage Practices, only certain advisory services may permit third‑party wire transfers, check‑writing authority, or Standing Letters of Authorization (“SLOAs”), and only where expressly authorized by the client and permitted under the applicable Advisory Agreement or third‑party program documents. RMR or persons associated with our firm may affect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, or we may have signatory and check-writing authority for client accounts if the client has provided us with written authorization to do so. Such written authorization is known as a “Standing Letter of Authorization” (or “SLOA”). An adviser with authority to conduct third-party wire transfers or sign checks on a client's behalf has access to the client's assets and, therefore, has custody of the client's holdings in any related accounts. However, RMR is not required to obtain a surprise annual audit, as otherwise would be necessary by reason of having custody, as long as we meet the following criteria: 1. The client provides a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian. 2. The client authorizes us in writing to direct transfers to the third party either on a specified schedule or from time to time. 3. The qualified custodian verifies the client’s authorization (i.e., signature review) and promptly provides a funds transfer notice to the client after each transfer. 4. The client can terminate or change the instruction. 5. RMR has no authority or ability to designate or change the third party's identity, address, or any other information about the third party. 6. We maintain records showing that the third party is not a related party to us or located at the same address, and 7. The client’s qualified custodian sends them, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Annuity management services and TPM Wrap Fee Program services clients will follow the custody and SLOA procedures of the TPM. Clients should refer to the third-party manager’s contract for exact details. (Custodial arrangements applicable to these services are also summarized in Item 12: Brokerage Practices.) Custodial Account Statements Clients will receive account statements at least quarterly from the qualified custodian(s) holding their funds and securities to their e-mail or postal mailing address of record as provided to the qualified custodian. The reports will reflect all account positions, transactions, and disbursements made, including the amounts of any assessed advisory fees deducted from their account(s) during each billing period. Clients should promptly review the statements provided by their custodian upon receipt. RMR urges clients to compare the statements they receive directly from their custodian with the information outlined in any reports or periodic portfolio statements received by us to ensure the accuracy of all account transactions. Our reports may differ from custodial statements due to accounting procedures, reporting dates, or valuation methodologies for particular securities. RMR encourages our clients to promptly raise any questions regarding the custody, safety, or security of their assets with us. Clients should carefully review account statements for accuracy. We will also provide statements to clients reflecting the amount of the advisory fee deducted from their accounts. Clients should also compare our statements with their account custodian(s) statements to reconcile the information reflected on each report. Clients should contact their IAR or RMR immediately if they have questions regarding their account statement(s) or did not receive a statement from their qualified custodian. 59  ITEM 16: INVESTMENT DISCRETION ____________________________________________________________________________________________________ Account Management Style RMR advisory services are offered on either a discretionary or non‑discretionary basis. The specific authority granted is fully disclosed before services begin, and each client’s executed Advisory Agreement clearly identifies the applicable account management style and any limitations. Discretionary Authority Under discretionary account management authority, RMR will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client:  Determine the security to buy or sell.  Determine the amount of security to buy or sell.  Determine the timing of when to buy or sell. For this type of management style, clients will grant discretionary authority through written authorization, typically via their Advisory Agreement, Limited Power of Attorney, or custodian‑required trading authorization forms. This authority allows RMR to manage investments and reinvestments as appropriate based on the client’s Investment Policy Statement (“IPS”) and the mutually agreed‑upon Investment Guidelines. RMR will not transfer or wire funds to third parties without the client's written approval. Discretionary authority is limited to the assets in a client’s managed account. Clients may impose restrictions on particular securities or security types, or otherwise limit RMR’s authority by providing written instructions. Such limitations may be amended at any time through written notice. RMR will obtain or maintain client consent for trades involving any positions explicitly discussed during the introductory interview (e.g., inherited or sentimental holdings), or as otherwise specified in the Advisory Agreement. All discretionary authority is exercised consistent with the stated investment objectives for the client’s account and remains in effect until revoked in writing, even in the event of the client’s disability or incompetence. Non-Discretionary Authority Clients may also engage RMR on a non‑discretionary basis. Under this structure, RMR provides recommendations, but clients must pre‑approve each transaction before it is executed. Clients retain full authority to decline any recommendation, delay approval, or restrict transactions in any security or security type. Clients must complete all documents required by RMR and/or their custodian to grant limited trading authorization for non‑discretionary management. Until RMR can reach the client for approval, no transactions will be processed on the account. Similar to discretionary arrangements, non‑discretionary authority remains in effect until terminated through written notice, even in the event of disability or incompetence. For both discretionary and non‑discretionary relationships, if clients object to any investment decision, RMR will work with the client to reach a mutually acceptable approach, which will be documented if necessary. It is always preferred that the client and RMR discuss any potential differences of opinion. However, if a client repeatedly acts inconsistently with agreed‑upon investment objectives, RMR reserves the right to terminate the advisory relationship with written notice. Clients may likewise terminate their Agreement in accordance with its terms. Once an investment portfolio is constructed, RMR provides ongoing supervision and may rebalance a portfolio as changes in market conditions or client circumstances warrant. RMR seeks to limit unnecessary trading to minimize transaction costs, tax implications, and other related expenses. Service‑Specific Discretion Guidance Because discretion varies across RMR’s different advisory programs, the sections below outline how discretionary authority applies to each service. 60  Portfolio Management Services RMR exercises discretionary or non‑discretionary authority under its portfolio management services, CIP Program services, and TPM Wrap Fee Program services, as elected by the client and documented in their Advisory Agreement. Under the TPM Wrap Fee Program, discretionary authority may involve manager selection by RMR and investment management by the TPM, consistent with the client’s investor profile and Program Agreement. Annuity Management Services Annuity management services accounts are generally managed on a discretionary basis under the terms of the Program Agreement with the referred third‑party manager. In most Program Agreements, RMR retains discretion to select or replace the investment manager, and the third‑party manager exercises discretionary authority to allocate among the investment options available within the annuity contract. However, discretion can vary by annuity carrier and platform, as some insurers restrict trading authority, limit available investment subaccounts, impose allocation timing restrictions, or require client approval for certain changes. Clients should consult their Program Agreement and the carrier’s platform‑specific documentation for precise information on the permitted level of discretion. Discretion may be granted via the Program Agreement, the Advisory Agreement, a power of attorney, or platform‑specific authorization forms. When a non‑discretionary structure applies, RMR will obtain the client’s approval before executing trades, and clients retain the unrestricted right to decline any recommendation. Digital Asset Management Services Digital Asset management services may be discretionary or non‑discretionary depending on the account type and custodian requirements. Discretionary authority is limited to the allocation and reallocation of funds among the investment products supported by the Digital Asset custodian. Financial Planning & Consulting Services Financial planning and consulting services do not involve investment discretion, as no trading authority is involved under these services. Retirement Plan Services Under our retirement plan services, RMR may serve in either a 3(21) fiduciary (non‑discretionary) or 3(38) fiduciary (discretionary) capacity, as defined in the Retirement Plan Advisory Agreement. Registered Investment Company Sub‑Advisory Services RMR exercises discretionary authority over assets managed in connection with its registered investment company sub- advisory services, subject to the investment guidelines, compliance policies, prospectus/statement of additional information (“SAI”) requirements, and trading instructions established by the fund’s primary adviser and the fund’s board of trustees. This authority includes managing the portion of fund assets allocated to RMR, placing trades consistent with fund‑level requirements, and complying with all applicable provisions under the Investment Company Act of 1940. RMR’s discretionary authority in this context is exercised under the supervision of the primary adviser and oversight of the fund’s Chief Compliance Officer and board. Pontera Services Pontera services do not involve investment discretion. Although RMR may implement allocation changes through the Pontera platform when authorized by the client, this functional access does not grant RMR discretionary trading authority, and all activity occurs within parameters established by the client and the plan provider. Educational Seminars & Workshops Services Educational seminars and workshop services do not involve any investment discretion or account‑level authority. ITEM 17: VOTING CLIENT SECURITIES ____________________________________________________________________________________________________ Proxy Voting RMR does not accept authority to vote client securities and does not vote proxies on behalf of clients. RMR does not assume responsibility to review, evaluate, or act upon any proxy solicitations received. Clients will receive proxy materials directly from 61  the security issuer, their qualified custodian, the Insurance Company, and/or the Insurance Company’s approved custodian(s). Clients are solely responsible for exercising their right to vote proxies. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), proxy voting authority generally resides with the Plan Fiduciary under the Plan's governing documents. If an ERISA Plan document designates RMR as the fiduciary responsible for voting proxies, such responsibility will be reassigned to another fiduciary and reflected in the applicable Plan documents. RMR will not act as the proxy‑voting fiduciary for ERISA accounts. RMR may, from time to time, recommend or refer certain clients to third‑party asset allocation programs or managed account platforms. Depending on the referred manager’s proxy‑voting policies and the authority granted under the TPM’s separate contract and Form ADV, clients participating in these programs may appoint the TPM as their agent and attorney‑in‑fact with discretion to vote proxies for securities held in their account. Clients should review the TPM’s Form ADV, disclosure brochures, and advisory agreement to understand the TPM’s proxy‑voting policies, procedures, and responsibilities. RMR may assist clients by answering questions about proxy materials; however, doing so does not confer or imply proxy‑voting authority. Clients remain responsible for making all proxy‑voting decisions. Clients should review the materials provided by the issuer or contact the issuer directly before voting. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. RMR does not evaluate clients’ eligibility to participate in securities class action settlements, nor does RMR monitor for, advise on, or file claims related to class actions, bankruptcies, or other legal actions involving securities held currently or previously in a client’s account. RMR has no obligation to determine whether a client’s securities are the subject of a pending or settled legal action, nor to forward notices, filings, or other materials related to such actions. RMR does not provide legal or tax advice, engage in activities that may be deemed the practice of law or accountancy, or act for the client in any capacity regarding legal proceedings involving securities issuers. RMR is not responsible for forwarding written or electronic notices of legal actions, bankruptcy proceedings, or class‑action settlements. Clients are solely responsible for responding to any legal notices, evaluating their rights or eligibility, and initiating litigation or claims related to any injury, misconduct, or negligence by corporate issuers or their management. Clients should consult qualified legal counsel regarding class actions, bankruptcy claims, or other legal proceedings. ITEM 18: FINANCIAL INFORMATION ____________________________________________________________________________________________________ Balance Sheet Requirement RMR does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair the Adviser’s Ability to Meet Contractual Commitments Neither RMR nor its management has any financial condition that is reasonably likely to impair the firm’s ability to meet its contractual commitments to clients. RMR has been the subject of an administrative order issued by a state securities regulator, resulting in the payment of an administrative penalty exceeding $2,500. The matter did not involve allegations of client harm, misappropriation, or fraud, and the penalty does not impair RMR’s ability to meet its contractual obligations to clients. Other than as disclosed above, RMR and its management have not been the subject of any award or been found liable in an arbitration claim or civil, self‑regulatory organization, or administrative proceeding involving allegations of fraud, false statements or omissions, theft, embezzlement, or other dishonest, unfair, or unethical practices. 62  Bankruptcy Disclosure RMR has no financial impairment that will preclude it from meeting contractual client commitments. Neither RMR nor any of its management persons has been the subject of a bankruptcy petition in the past ten (10) years. Disciplinary Disclosures Certain of RMR's financial professionals have legal or disciplinary histories that require disclosure. Please visit the SEC’s website at www.adviserinfo.sec.gov for a free and simple search tool to research RMR and its IARs, Management Members, Officers, and firm Principals. ITEM 19: REQUIREMENT FOR STATE REGISTERED ADVISERS ____________________________________________________________________________________________________ RMR’s registration with the Securities and Exchange Commission became effective on October 14, 2014; therefore, the requirements for Item 19 do not apply to the firm. ITEM 20: ADDITIONAL INFORMATION ____________________________________________________________________________________________________ Business Continuity Plan Securities industry regulations and regulatory guidance require investment advisers to maintain written business continuity and disaster recovery plans and to disclose material information to clients regarding how the firm addresses the possibility of significant business disruption (“SBD") from unexpected events such as power outages, natural disasters, or other such occurrences. Since the timing and impact of disasters and disruptions are unpredictable, firms must be flexible in acting. Well-thought-out, advanced preparations and effective procedures can significantly minimize downtime in the face of a disaster or outage. To satisfy this requirement, RMR has developed a comprehensive Business Continuity Plan ("BCP" or "Plan") summarizing how the firm intends to respond to SBDs. While no contingency plan can eliminate all service interruption risks, RMR's BCP sets forth the firm's policies and practices for various SBD situations and is designed to mitigate reasonably foreseeable risks while keeping up with changes to the Adviser’s business, structure, operations, and location. Firm Policy RMR's guiding principle is that protecting clients, employees/Associates, and family members always takes precedence over preserving business assets. Accordingly, RMR's policy is to respond to an SBD by first safeguarding the lives of its clients, employees (Associates), family members, and others, and then firm property. In the event of an SBD, RMR intends to make a quick financial and operational assessment, protect and preserve all advisory books and records, and promptly recover and resume business operations. If it is determined that the firm cannot continue its business, RMR will take reasonable steps to assist clients in obtaining prompt access to their funds and securities. Recovery times may vary depending on the nature and severity of the disruption; however, the objective is to restore mission‑critical operations as promptly as practicable, which may range from several hours to multiple days. BCP Summary RMR's BCP - reviewed, tested regularly, and updated no less than annually- anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the firm's ability to communicate and conduct business, such as in a building fire. External SBDs can disrupt the operations of several firms and may include terrorist attacks, floods, or wide-scale regional disruptions. RMR's BCP addresses all mission-critical systems, office closing and relocation procedures, and employee alternative physical locations. Regulatory reporting/alternate communications between the Adviser and its clients, Associates, critical business constituents, banks, counterparties, regulators, and others are detailed to preserve uninterrupted communication. The BCP also defines data backup and recovery procedures (hard copy and electronic) and succession planning in the event of the absence of key personnel. Further, RMR requires its primary internal and external vendors supporting mission‑critical systems to periodically verify and test their backup capabilities to promptly provide the necessary information and applications to continue or resume business in emergencies and other SBD situations. 63  RMR carries out its BCP under the direction of the Disaster Recovery Executive Coordinator (“DREC”). The DREC is responsible for assessing the extent of any disruption and communicating with employees, clients, critical business constituents, and regulators, as appropriate. When an internal or external event occurs or appears to be developing, RMR's DREC will be notified. Upon notification, the DREC will implement the Adviser’s BCP emergency procedures, secure the headquarters to the extent feasible, and advise all employees to contact the firm using the primary or alternative contact methods designated by RMR at the time of the event, including T: 201.836.2460. If the firm’s primary telephone line is disrupted, the lines will be forwarded to an alternative line. If a business disruption affects only the Adviser or a specific area within the firm and the primary office is inaccessible, RMR will transfer operations to a local worksite and provide notice as appropriate. If a disruption affects the broader business district, city, or region, operations will be transferred to an alternate worksite outside the affected area. Telephone service will continue, and work processes will resume at the alternate location(s). RMR will continue conducting business in either situation and will notify its clients by a recorded message on its main phone line and/or through a website posting. RMR does not maintain custody of client funds or securities for safekeeping; clients maintain all account assets with an independent qualified custodian, with whom they can communicate directly at any time. In the event of an SBD, RMR will assist clients in accessing external accounts by providing status updates and contact information for custodians and, if applicable, third‑party managers. If you cannot reach us after an SBD, as you usually do, please check your email. If our office number is unavailable, please contact your qualified custodian using the number listed on your account statements. If it is determined that the firm cannot continue its advisory business, clients will be assured access to their funds, securities, and any prepaid fees by direct contact with their respective qualified custodians and TPAs, as applicable. Contact Us RMR's BCP is designed to help the firm continue providing services to clients. Please contact us at 201.836.2460 with any questions about these practices or to request a copy of our BCP summary. A summary of our BCP disclosure is also posted on our website @ www.rmrwealth.com. Information Security Program RMR maintains a Written Information Security Program (“WISP”) designed to safeguard client records and information and to reduce the risk of unauthorized access, use, or disclosure of clients’ personal and confidential information. RMR’s WISP includes administrative, technical, and physical safeguards appropriate to the firm’s size, scope of business, and the sensitivity of information maintained. Please contact us directly at T: 201.836.2460 or @ compliance@rmrwealth.com with any questions about this topic. Privacy Practices Your relationship with us is built on trust and confidence. This privacy policy (“Privacy Policy” or “Policy”) explains how RMR collects, uses, stores, shares, and protects the personal information we obtain in the course of providing advisory services. We treat all information you provide with care and maintain safeguards designed to protect the confidentiality and security of your data. RMR’s privacy practices are implemented in accordance with Regulation S‑P under the Gramm‑Leach‑Bliley Act and applicable state privacy laws. We remain committed to maintaining your privacy and protecting your information. What Is Customer Information? For purposes of Regulation S‑P, “Customer Information” includes any record containing non-public personal information about a client that RMR maintains, handles, or processes, whether in paper, electronic, or other form. Non-public personal information includes personally identifiable financial information, such as a client’s name, address, telephone number, email address, Social 64  Security number, tax identification number, account numbers, and other information provided by a client in connection with receiving financial products or services. Customer Information may also include information relating to a client obtained from account activity, transactions, or interactions with RMR, as well as information received from third parties in connection with providing advisory services. Certain information may constitute Sensitive Customer Information under Regulation S‑P if its unauthorized access or use could result in substantial harm or inconvenience to a client. Information that is publicly available or aggregated, de‑identified data that cannot reasonably be linked to an individual client, is generally not considered non-public personal information for purposes of Regulation S‑P. Categories of Information We Collect The personal information we collect depends on the services you receive. This may include, but is not limited to:    Information you provide on applications and account forms, including name, address, phone number, Social Security number, occupation, investment objectives, income, assets, and household information. Information about your transactions with us, or with broker‑dealers, banks, custodians, or other financial services providers, including account numbers, balances, holdings, transaction history, and other account activity. Information provided during planning discussions, reviews, or consultations. How We Collect Your Information We collect personal information when you engage us for advisory services, open or modify accounts, provide financial information, or interact with our professionals. We may also receive information from third parties such as custodians, broker‑dealers, employers, plan sponsors, insurance companies, or other financial institutions, as permitted by law. We do not knowingly collect or retain information from children, nor do we market products or services to children. How We Use Your Information We may use your information for purposes permitted under federal and state law, including to:  Provide, administer, and service the advisory relationship.  Verify your identity and protect against unauthorized access or fraud.  Communicate with you about your accounts, services, or requested information.  Process transactions and maintain accurate records.  Conduct internal business operations, such as compliance, auditing, analytics, or risk management. Improve or enhance our services and client experience.   Comply with legal, regulatory, or contractual obligations. We may also contact you about services related to your existing advisory relationship. You may request limitations on certain communications at any time. RMR does not sell client information and does not share personal information with unaffiliated third parties for their independent marketing purposes. Sharing Non‑Public Personal & Financial Information Financial companies share certain client information to conduct everyday business. We share information only as permitted or required by law and only with parties that agree to protect its confidentiality. This may include sharing:  With custodians, broker‑dealers, insurance companies, banks, or other service providers to open, service, or maintain accounts.  With accountants, attorneys, auditors, or consultants assisting us in providing services or meeting compliance obligations.  With technology, data security, or business‑continuity service providers supporting our operations.  With regulators, courts, or law enforcement when required by applicable law.  With fiduciaries, trustees, or authorized individuals acting on your behalf. 65  In connection with a corporate transaction such as a merger, acquisition, or business reorganization.   With your consent or at your instruction. The categories of personal information shared may include any information described in this Policy that is necessary to perform the service or meet the requirement. Protection of Personal Information RMR maintains administrative, technical, and physical safeguards to protect client information from unauthorized access, use, or disclosure, in accordance with Regulation S‑P. Access to personal information is restricted to employees and service providers who require it to perform their duties. Safeguards include secure physical facilities, controlled system access, data encryption where applicable, vulnerability management, and business‑continuity and incident‑response processes. Although no security system is impenetrable, we maintain procedures designed to detect, respond to, and mitigate cybersecurity incidents or unauthorized access attempts. Internet Use You may visit our website at www.rmrwealthbuilders.com without identifying yourself. Our systems may automatically collect technical data such as domain names, IP addresses, browser information, or pages visited. This information is used to improve website performance, enhance security, and optimize functionality. We do not sell or transfer browsing‑behavior information to ad networks, data brokers, or advertising services. Sharing Information & Consumer Choice We may share your information with affiliated companies and approved service providers to fulfill your requests, administer accounts, or provide advisory‑related services. We do not share your personal information with third parties for their independent marketing. You may contact us to request limitations on certain types of information sharing where permitted by law. State or jurisdiction‑specific privacy rights may provide additional protections or choices. Notification in the Event of a Data Breach If an incident occurs that compromises your personally identifiable information, RMR will comply with applicable federal and state notification requirements and will inform you as required by law. Former Customers We maintain personal information about former clients in accordance with federal and state record‑retention requirements. When retention periods expire, data is securely destroyed. Accessing or Correcting Your Information You may request access to or correction of personal information we maintain by contacting us at the address below. We will take steps to verify your identity before making any changes or providing any information, in accordance with regulatory requirements. Changes to Our Privacy Policy We may update this Privacy Policy from time to time. If material changes occur, we will notify existing clients as required and update our website to reflect the revised Policy and effective date. Questions Please contact us with any questions regarding our privacy practices: RMR WEALTH BUILDERS, INC. 111 Grove Street, Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 www.rmrwealthbuilders.com compliance@rmrwealth.com 66 

Item 1: Cover Page ____________________________________________________________________________________________________ RMR WEALTH BUILDERS, INC. FORM ADV PART 2A APPENDIX 1 Wrap Fee Program brochure (CRD # 169005 / SEC # 801-80404) 111 Grove Street Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 https://www.rmrwealth.com http://www.rmrwealthbuilders.com https://www.facebook.com/rmrwealth/ https://www.linkedin.com/company/rmr-wealth-builders-inc-/ https://www.linkedin.com/showcase/rmr-wealth-workforce-solutions-retirement/posts January 1, 2026 This Wrap Fee Program brochure provides information about the qualifications and business practices of RMR Wealth Builders, Inc., an investment advisory firm registered with the United States Securities and Exchange Commission. If you have questions about this brochure's contents, please contact us at 201.836.2460 or compliance@rmrwealth.com. The information in this brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority. Registration does not imply any level of skill or training. Investments involve risk, including the possible loss of principal. Additional information about RMR Wealth Builders, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in RMR Wealth Builders, Inc. or CRD # 169005. Results will provide you with all firm disclosure brochures.) 1  Item 2: Material Changes ____________________________________________________________________________________________________ In this item, RMR Wealth Builders, Inc. ("RMR" or "the Adviser") is required to summarize only those material changes made to this brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 31, 2025, we have made changes to the following brochure sections: Item 4: Services, Fees & Compensation This section was updated to reflect that RMR charges its Wrap Fee Program services fees as a single, flat percentage of the total account value. Fees are calculated by applying a fixed annual rate to the entire account value as of the end of the last billing period. This simplified fee structure means the same percentage rate is applied uniformly across the entire account balance. This change clarifies the manner in which wrap fees are assessed and disclosed under the Program and replaces prior tiered or blended fee descriptions. Annual Advisory Fee Schedule Assets Under Management (“AUM”) All Maximum Annual Fee 2.65% *Lower fees for comparable services can sometimes be available from other sources. The annual account management fee is billed quarterly based on the number of days in the quarter divided by 365, multiplied by the AUM fee. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are negotiable based on account value and type, but will not exceed the maximum Annual Fee indicated above. The final fee schedule is documented in the client’s executed Agreement. Additional funds and/or securities deposits during a particular calendar quarter will be billed on a pro rata basis, as stated in the client Agreement. Clients who withdraw funds from a managed account during a billing period are generally not entitled to a pro rata refund unless they terminate their client Agreement or it is otherwise stated in the client Agreement. No changes were made to the refund or termination provisions of the Wrap Fee Program. Item 6: Portfolio Manager Selection & Evaluation Digital Assets This section was updated to reflect that Digital Asset services clients maintain their Digital Assets through Fidelity Digital Assets® (Fidelity Investments®’ digital asset platform), with assets custodied at Fidelity Digital Asset Services, LLC. Full Brochure Availability At any time, we may amend this document to reflect changes in RMR’s business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary due to material changes, we will provide the client - either by electronic means or hard copy - with a new brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "RMR Wealth Builders, Inc.” or CRD # 169005. The SEC's website also provides information about any RMR-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may also request a free copy by contacting us directly at 201.836.2460 or compliance@rmrwealth.com. 2  Item 3: Table of Contents ____________________________________________________________________________________________________ Item 1: Cover Page.........................................................................................................................................................1 Item 2: Material Changes................................................................................................................................................2 Item 3: Table of Contents.................................................................................................................................................3 Item 4: Services, Fees & Compensation.........................................................................................................................4 Item 5: Account Requirements & Types of Clients.........................................................................................................17 Item 6: Portfolio Manager Selection & Evaluation..........................................................................................................18 Item 7: Client Information Provided to Portfolio Managers.............................................................................................36 Item 8: Client Contact with Portfolio Managers..............................................................................................................36 Item 9: Additional Information.......................................................................................................................................36 3  Item 4: Services, Fees & Compensation ____________________________________________________________________________________________________ Types of Advisory Services RMR Wealth Builders, Inc. (hereafter “RMR” or the “Adviser”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”), as amended. Founded in 1986 and incorporated in the State of New Jersey, the Adviser’s principal place of business is located at 111 Grove Street, Suite 203, Montclair, New Jersey. The Adviser maintains additional offices in AZ, CA, CT, FL, IL, MA, NY, PA, RI, and WY. For over 36 years, RMR, through its founding partners, has embraced the discipline and practice of aligning fiduciary standards and professional principles. The equal owners of the privately owned company are Ryan P. DeGrau (Chief Executive Officer), Douglas R. Roth (Co-Chairman), Joseph J. Russo (Co-Chairman), and Edward A. Majitenyi (President), who undertake all of the Adviser's significant strategic and administrative decisions. Their combined industry experience exceeds 100 years. (Please refer to each Principal’s Form ADV Part 2B brochure Supplement for additional details on their formal education and business background.) RMR acts as a fiduciary to its advisory clients, as defined under applicable federal and state securities laws. As a fiduciary, the Adviser owes clients a duty of loyalty and care and is required to act in good faith and in their best interests. In fulfilling these obligations, RMR seeks to identify, disclose, and address potential conflicts of interest and endeavors to avoid situations in which one client’s interests are placed ahead of another’s. As used in this brochure, the terms “we,” “our,” or “us” refer to RMR Wealth Builders, Inc. The terms “you,” “your,” and “client” refer to any client or prospective client of the firm. The term “Associated Persons” (or “Associates”) refers collectively to RMR’s Supervised Persons, as that term is defined under the Advisers Act, including the firm’s officers and directors (each a “Control Person”), employees, and investment professionals—namely, the firm’s Investment Advisor Representatives (“IARs”)—who, whether as employees or independent contractors, are subject to RMR’s supervision and control and are authorized to provide investment advice or advisory services on behalf of the Adviser. RMR’s investment advisory services are designed to help clients pursue their financial goals. Our IARs play a central role in establishing, maintaining, and managing each client relationship. Clients are introduced to RMR through these experienced IARs, and each advisory relationship is managed by one or more IARs registered with the firm. These investment professionals serve as the primary point of contact between the Adviser and its clients. IARs are required under applicable laws, rules, and firm policies to obtain appropriate licenses and complete required training to recommend specific investment products and services. Clients should be aware that an IAR may or may not be able to recommend certain services, investments, or models depending on the licenses held, training completed, or other regulatory limitations. Additionally, IARs may conduct advisory business and respond to client inquiries only in the state(s) in which they are properly registered or otherwise exempt from registration. (For additional information regarding the IARs providing advisory services, clients should refer to their investment professional’s Form ADV Part 2B brochure Supplement. This separate disclosure document is required to be delivered to clients before or at the inception of the advisory relationship, together with the Adviser’s disclosure brochures. Clients who did not receive these documents should contact their IAR or RMR’s Chief Compliance Officer at T: 201. 836.2460 or via email @ compliance@rmrwealth.com to request copies of these important disclosures.) RMR supports and maintains an open environment where its Associates and IARs have access to the technology, tools, products, and support we believe are necessary to achieve our goal of providing diverse, high-quality client services. Together with our preferred qualified custodian(s), we aim to deliver a white-glove approach to the resources, support, operations, technology, compliance, guidance, oversight, business development, investment selection, and platform access we make available to our Investment Professionals and clients. Non-Exclusive Relationship RMR's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Accordingly, since investment strategies and advice are tailored to each client's specific financial situation, the advice we provide to one client may differ from or conflict 4  with that for the same security or investment for another client. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations At the client's request, RMR may recommend the services of independent third‑party professionals for implementation or related purposes. Such professionals may include, but are not limited to, attorneys, accountants, insurance agents, or other specialists. These professionals are engaged directly by the client on an as‑needed basis, and clients are under no obligation to engage any recommended professional. Clients who elect to engage a recommended professional will enter into a separate agreement directly with the selected provider, governing the scope of services, fees, and other contractual terms. Unless otherwise disclosed, RMR is not a party to any such arrangement, does not share in any fees earned by the referred professional, and does not have the authority to accept clients on behalf of, or otherwise bind, any such professional. Each referred professional retains the sole discretion to accept or decline any client referral, for any reason or no reason. In selecting a third‑party professional, clients are responsible for reviewing and understanding the provider’s separate agreement, including all applicable fees and charges. Clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation made by RMR. RMR is not responsible for the acts, omissions, or services provided by any third‑party professional engaged by a client. Clients must resolve any disputes arising from their engagement of a recommended professional directly with the engaged provider. Client Responsibilities RMR’s advisory services depend on information provided by clients. The Adviser cannot adequately perform its contractual obligations or fulfill its fiduciary duties unless clients provide accurate, complete, and timely information regarding their financial circumstances, investment objectives, and needs. Clients are responsible for promptly providing requested information or documentation, notifying us of material changes, and otherwise fulfilling their obligations under their written contract. Regardless of whether a client has granted discretionary authority or retains final decision‑making authority, it is the client’s responsibility to ensure that their IAR has all information reasonably necessary to make appropriate recommendations and/or manage the account in the client’s best interest. Clients are responsible for promptly notifying RMR, in writing, of any material changes in circumstances, including changes to information previously provided that may affect account management, or if any prior disclosures become inaccurate. RMR and its IARs will generally rely on the accuracy of information furnished by the client or on the client’s behalf, without independent verification, and are not required to verify information received from clients or from other professionals, such as accountants or attorneys. Clients (or their successors or authorized representatives) must also promptly notify RMR, in writing, of any event that may affect the validity of the contract or RMR’s authority thereunder, including the dissolution, merger, termination, or bankruptcy of a client that is not a natural person. RMR reserves the right to decline or terminate an advisory engagement if a client willfully withholds, conceals, or refuses to provide information that RMR determines is material to the advisory services provided. The Wrap Fee Program RMR, as Sponsor and Manager, provides investment advisory and portfolio management services through its Wrap Fee Program (the “Program”). Based on a client’s individual circumstances, RMR’s IARs may recommend participation in the Program and act as the IARs for client accounts managed under the Program (the “Managed Accounts”). In connection with these services, RMR receives a portion of the wrap fee paid by participating clients, as further described in this brochure and the client’s executed Advisory Agreement. Under the Program, clients generally pay a single, negotiable, asset‑based fee (the “wrap fee” or “Program fee”) calculated on the market value of assets managed in the account. The wrap fee is intended to cover RMR’s investment advisory and portfolio management services, certain administrative services, specified transaction‑related services, and, where applicable, the portfolio management services of one or more independent, unaffiliated third‑party managers (“TPMs”). Unlike traditional advisory arrangements, the Program fee replaces separate advisory fees and transaction‑based charges; however, it does not 5  include all costs or expenses that a client may incur, as disclosed elsewhere in this brochure. Depending on factors such as trading activity, account size, and the services selected, participation in the Wrap Fee Program may result in higher or lower overall costs than paying separately for advisory services and transaction‑based charges. Establishing the Advisory Relationship RMR begins each Wrap Fee Program advisory relationship with a suitability discovery process designed to evaluate the client’s financial circumstances, investment objectives, time horizon, and risk tolerance. This information is used to determine the appropriateness of participation in the Wrap Fee Program and the selected portfolio management services and to establish goals consistent with the client’s needs and objectives. Clients’ accounts are reviewed for qualification and suitability both initially and on an ongoing basis. Clients are responsible for promptly notifying RMR and, where applicable, the TPM of any material changes in financial circumstances, objectives, or other information provided during the suitability process. The Advisory Agreement RMR provides Wrap Fee Program investment advisory services pursuant to a written Investment Management Agreement (the Program’s “Advisory Agreement” or “Agreement”), which serves as the foundational contract governing the client’s participation in the Wrap Fee Program. The Agreement describes, among other things: the scope of advisory services to be provided; the client’s selected Wrap Fee Program services; the level of investment discretion (discretionary or non‑discretionary), the applicable wrap fee or the method for calculating such fees, billing frequency, proration and termination provisions, and the client’s investment objectives, restrictions, and any other agreed‑upon limitations. Clients receive copies of all material operative documents and disclosures relating to the Program, including disclosures describing compensation arrangements and the roles of RMR and any TPMs. The Agreement further reflects the custodial arrangements applicable to the client’s Wrap Fee Program account(s). RMR does not maintain physical custody of client funds or securities, except for its limited authority to deduct advisory fees from client accounts, as disclosed herein. Client assets are held with independent, unaffiliated qualified custodians. Clients receive the applicable custodial agreements and related account‑opening documentation in advance, either directly from the custodian or through materials provided in connection with the Advisory Agreement. (Refer to Item 4: Services, Fees & Compensation and Item 9: Additional Information for additional disclosures.) This Agreement governs the client’s participation in the Wrap Fee Program and serves as the primary legal document for the advisory relationship. The client’s executed Agreement, together with any applicable supplemental agreements, documents the agreed‑upon terms of the relationship. Advisory services under the Wrap Fee Program will commence only after all required Agreement(s) and related documents have been fully executed. RMR and its IARs may provide only those services and assess only those fees expressly authorized under the executed Agreement and consistent with the client’s stated objectives, limitations, and restrictions. Any amendments to an existing Agreement will be made in accordance with its amendment provisions. (Refer to Item 4: Services, Fees & Compensation for additional details.) Investment Policy Statement Following completion of the discovery process and execution of the client’s Agreement, and when requested and appropriate in connection with the selected Wrap Fee Program services, RMR may prepare an Investment Policy Statement (“IPS”). The IPS reflects the client’s approved investment parameters and provides a framework for constructing and managing a diversified portfolio aligned with the client’s long‑term objectives and risk considerations. The IPS is a guideline only; it is not a contract, does not amend the Advisory Agreement, and does not guarantee performance or outcomes. Clients remain responsible for reviewing and approving their IPS. The client’s IAR will use the information obtained through the discovery process and, where applicable, the IPS to recommend the services that the IAR believes are in the client’s best interest. 6  Wrap Fee Program Structure, Fees, & Expenses While the wrap fee generally covers advisory services and the execution of securities transactions within the Program, certain expenses are not included in the wrap fee and are charged to the client separately. Expenses not included in the wrap fee may include, but are not limited to:  Fees imposed by the qualified custodian, such as account maintenance, wire transfer, or termination fees.  Internal expenses of mutual funds, exchange‑traded funds, or other pooled investment vehicles, including management fees and expense ratios.  Transaction‑related charges associated with trading away from the Program’s designated broker or custodian, where applicable.  Fixed‑income markups or markdowns charged by the executing broker.  Taxes, governmental fees, or other extraordinary expenses not covered under the Program. Overall costs under RMR’s Wrap Fee Program may be higher or lower than if clients separately purchased the types of securities and services available through the Program, depending on factors such as trading activity and account characteristics. (Clients should consult their Agreement and the appropriate disclosure brochure(s) for additional information regarding fees and expenses.) Annual Account Administration Fee & Client Reporting Platform Effective April 1, 2024, RMR increased its annual Account Administration Fee for accounts billed directly from $52 to $80. This fee is prorated daily and charged quarterly, calculated by dividing the number of days in the quarter by 365, and is assessed to RMR fee‑based program clients in accordance with their executed Agreement. This Account Administration Fee is charged separately from, and in addition to, the wrap fee, when applicable, as specified in the client’s executed Agreement. Regardless of the amount of assets under management, clients receive access to and use the Black Diamond Wealth Platform, an online trading and reporting system that provides clients with direct login access to portfolio information, including holdings, account summaries, reports, educational materials, training resources, and other communications designed to help clients monitor their investments. RMR does not maintain physical custody of client funds or securities, except for its limited authority to deduct advisory fees. Clients participating in the Program will establish one or more accounts (each a separately managed account, or “SMA”) with the Program’s unaffiliated qualified custodian, selected by RMR or the TPM, as applicable. Clients will receive account statements directly from the qualified custodian and are encouraged to review them promptly and compare them with any reports provided by RMR. Supervision of Wrap Fee Accounts RMR supervises the management of client accounts within the Wrap Fee Program, including accounts managed by independent TPMs, in accordance with the client’s stated investment objectives, applicable restrictions, and the Adviser’s supervisory policies and procedures. RMR supervises and directs investments in client accounts as provided under the Advisory Agreement and, where applicable, the Investment Policy Statement (“IPS”). RMR’s discretion with respect to accounts managed by TPMs is generally limited to the selection, monitoring, and replacement of the TPM. TPM Wrap Fee Program Under RMR’s TPM Wrap Fee Program, RMR may select, recommend, and provide clients access—following appropriate due diligence—to independent, unaffiliated investment advisers from a group of approved TPMs with whom RMR has entered into written agreements to make discretionary portfolio management services available through the Wrap Fee Program. RMR evaluates and selects TPMs it deems suitable based on a client’s investment objectives, risk profile, and other specified account parameters. RMR refers only to those clients it believes are appropriate candidates for the TPM Wrap Fee Program, which is offered as a wrap fee account. RMR’s role includes assessing client suitability for participation in the Program, reviewing investable assets and client objectives, assisting clients in completing an investor profile used to support the TPM’s portfolio allocation determinations, and monitoring the TPM’s ongoing management to help ensure consistency with the client’s stated objectives and guidelines. While RMR 7  retains discretion over the selection, monitoring, and replacement of the TPM, it does not trade client accounts managed by the TPM. Portfolio management discretion for these accounts rests solely with the TPM. TPM Portfolio Management Clients who elect the TPM Wrap Fee Program are offered model portfolios with varying strategies and risk levels, as described in each TPM’s Form ADV brochure. The client’s investor profile, together with the applicable agreements, dictates portfolio selection, investment discretion, and any limitations applicable to the account. Each TPM manages client assets on a fully discretionary basis in accordance with the client’s selected strategy, objectives, and restrictions. TPM accounts are typically maintained at RMR’s qualified custodian, which holds client cash, securities, and other assets. The TPM must have the ability to access the account to effect trades and manage the portfolio. Both RMR and the TPM act as fiduciaries with respect to their respective responsibilities under the Wrap Fee Program. The TPM is responsible for day‑to‑day portfolio management and investment decision‑making, while RMR oversees the Program relationship and monitors the TPM’s performance and adherence to client objectives. Client accounts are reviewed in the context of the client’s stated investment objectives and guidelines. The client’s IAR monitors the TPM and may recommend replacing a manager when appropriate, to align the account with the client’s goals. Because the information provided by the client informs portfolio construction and allocation decisions, clients are responsible for promptly notifying both RMR and the TPM of any material changes in financial circumstances, investment objectives, or other information relevant to account management. RMR does not have the authority to accept clients on behalf of any TPM, and TPMs are not obligated to accept any prospective client referred by RMR. Each TPM may decline any referred client in its sole discretion. Participation in the TPM Wrap Fee Program requires clients to review and receive all applicable disclosure documents, including the TPM’s Form ADV brochure. Certain TPM arrangements require the client to enter into a separate agreement directly with the TPM (and, where applicable, the TPM’s designated custodian) to grant discretionary trading authority or satisfy the manager’s operational requirements. Such agreements are supplemental to, and distinct from, the client’s Advisory Agreement with RMR. TPMs included in the Program are subject to RMR’s ongoing review and may be added or removed from the approved manager list from time to time. Conflicts of Interest A conflict of interest exists when RMR recommends its Wrap Fee Program because RMR has a financial incentive to recommend wrap arrangements over non‑wrap arrangements. RMR’s IARs do not receive additional compensation solely as a result of a client’s participation in the Wrap Fee Program. IAR compensation is paid in accordance with RMR’s standard compensation arrangements, as reflected in the client’s executed Advisory Agreement. In addition, RMR pays certain transaction costs in wrap accounts, which may reduce the incentive to trade, and TPMs receive compensation from RMR under existing business arrangements, which may create incentives to recommend certain managers. RMR addresses these conflicts through its suitability and cost‑effectiveness analysis, ongoing due diligence and monitoring of TPMs, full and fair disclosure, and observance of its fiduciary obligations. RMR also maintains written supervisory and compliance policies and procedures, as well as a Code of Ethics addressing conflicts of interest, including personal trading. Copies are available to clients upon request at no cost. Wrap Fee Program Disclosures Wrap Fee Program clients must understand the following:  The benefits under the Wrap Fee Program largely depend on the account's size, the management fee charged, and the number of transactions expected to be generated in the account.  RMR and its IARs receive compensation due to client participation in our Wrap Fee Program. This compensation may exceed the amount RMR or its IARs would receive if the client paid separately for investment advice, brokerage, and other services. (For example, this type of Program may not be suitable for accounts with little trading activity.) 8   To evaluate whether our Wrap Fee Program is suitable for their circumstances, clients should compare our wrap fee and any other costs of the Wrap Fee Program with the amounts that other advisers would charge broker-dealers and custodians for advisory fees, brokerage, other execution costs, and custodial services comparable to those provided under the Wrap Fee Program.  Participating in a Wrap Fee Program may cost a client more or less than purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. Similar services may be available at lower cost, unbundled, from different firms. Accordingly, a conflict of interest exists because we have a financial incentive to recommend our Wrap Fee Program. Receiving a portion of advisory fees incentivizes IARs to recommend that clients participate in RMR’s Wrap Fee Program rather than a non-Wrap Fee Program or other programs or services in which clients pay trade execution costs over brokerage accounts that charge commissions. The following summarizes the services available through RMR's Wrap Fee Program. Clients should carefully review this brochure and consult with their IAR, the applicable Program Agreement, and the corresponding Program fee schedule for complete information regarding each service. Wrap Fee Program Advisory Services RMR's IARs will emphasize continuous, personal client contact and interaction when providing the following Wrap Fee Program services from which clients may choose: IAR Client Investment Portfolio Wrap Fee Program (hereafter “CIP Program.”) 1. 2. Third-Party Manager Wrap Fee Program (hereafter “TPM Wrap Fee Program,” with RMR as investment adviser and the third-party manager as sub-adviser.) Clients will indicate their selected advisory services Program and applicable billing or management arrangement directly within the Advisory Agreement. CIP Wrap Fee Program Clients may alternatively elect to participate in the CIP Program under a wrap‑fee billing structure. Under this option, clients pay a single, asset‑based “wrap fee” or “Program fee” that covers RMR’s investment advisory services and certain transaction and execution costs charged by the custodian. Participation in a wrap‑fee arrangement may result in higher or lower overall costs than a non‑wrap fee arrangement, depending on factors such as trading activity, account size, and the services selected. (Note: Additional information regarding the Wrap Fee Program—including services, fees, expenses, and conflicts of interest—is provided in this Wrap Fee Program Brochure (particularly within Item 4 and Item 9) and the client’s executed Advisory Agreement.) TPM Wrap Fee Program In addition to managing client portfolios directly through the CIP Program, RMR offers clients the option to engage independent third‑party portfolio managers (“TPMs”) to manage their accounts on a discretionary basis. Clients who elect this service participate in RMR’s TPM Wrap Fee Program. All TPM accounts are offered exclusively on a wrap‑fee basis. The wrap fee generally includes RMR’s advisory services, the TPM’s portfolio management fee, and applicable transaction‑execution costs. Portfolio management responsibility for TPM‑managed accounts rests with the selected TPM; RMR does not manage the underlying investments in TPM accounts. Instead, RMR’s role is generally limited to selecting, recommending, monitoring, and replacing TPMs, as appropriate. RMR conducts due diligence on TPMs before making them available to clients and maintains written agreements with approved TPMs to facilitate their participation in the program and support overall program administration. Certain TPMs may require clients to enter into additional, manager‑specific agreements to authorize discretionary management or to satisfy operational or custodial requirements. Minimum account sizes for TPMs generally range from $25,000 to $1,000,000, depending on the specific manager. 9  Trading Authorization & Account Management Style RMR advisory services are offered on either a discretionary or non‑discretionary basis. The specific authority granted is fully disclosed before services begin, and each client’s executed Advisory Agreement clearly identifies the applicable account management style and any limitations. Discretionary Authority Under discretionary account management authority, RMR will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client:  Determine the security to buy or sell.  Determine the amount of security to buy or sell.  Determine the timing of when to buy or sell. For this type of management style, clients will grant discretionary authority through written authorization, typically via their Advisory Agreement, Limited Power of Attorney, or custodian‑required trading authorization forms. This authority allows RMR to manage investments and reinvestments as appropriate based on the client’s Investment Policy Statement (“IPS”) and the mutually agreed‑upon Investment Guidelines. RMR will not transfer or wire funds to third parties without the client's written approval. Discretionary authority is limited to the assets in a client’s managed account. Clients may impose restrictions on particular securities or security types, or otherwise limit RMR’s authority by providing written instructions. Such limitations may be amended at any time through written notice. RMR will obtain or maintain client consent for trades involving any positions explicitly discussed during the introductory interview (e.g., inherited or sentimental holdings), or as otherwise specified in the Advisory Agreement. All discretionary authority is exercised consistent with the stated investment objectives for the client’s account and remains in effect until revoked in writing, even in the event of the client’s disability or incompetence. Non-Discretionary Authority Clients may also engage RMR on a non‑discretionary basis. Under this structure, RMR provides recommendations, but clients must pre‑approve each transaction before it is executed. Clients retain full authority to decline any recommendation, delay approval, or restrict transactions in any security or security type. Clients must complete all documents required by RMR and/or their custodian to grant limited trading authorization for non‑discretionary management. Until RMR can reach the client for approval, no transactions will be processed on the account. Similar to discretionary arrangements, non‑discretionary authority remains in effect until terminated through written notice, even in the event of disability or incompetence. For both discretionary and non‑discretionary relationships, if clients object to any investment decision, RMR will work with the client to reach a mutually acceptable approach, which will be documented if necessary. It is always preferred that the client and RMR discuss any potential differences of opinion. However, if a client repeatedly acts inconsistently with agreed‑upon investment objectives, RMR reserves the right to terminate the advisory relationship with written notice. Clients may likewise terminate their Agreement in accordance with its terms. Once an investment portfolio is constructed, RMR provides ongoing supervision and may rebalance a portfolio as changes in market conditions or client circumstances warrant. RMR seeks to limit unnecessary trading to minimize transaction costs, tax implications, and other related expenses. Service‑Specific Discretion Guidance RMR exercises discretionary or non‑discretionary authority under its portfolio management services, CIP Program services, and TPM Wrap Fee Program services, as elected by the client and documented in their Advisory Agreement. Under the TPM Wrap Fee Program, discretionary authority may involve manager selection by RMR and investment management by the TPM, consistent with the client’s investor profile and Program Agreement. 10  A conflict of interest exists because RMR has a financial incentive to recommend wrap‑fee arrangements, including both RMR’s CIP Wrap Fee Program and the TPM Wrap Fee Program, over non‑wrap fee arrangements. In wrap‑fee accounts, RMR may pay certain transaction costs, thereby reducing the incentive to trade. In addition, TPMs are compensated through existing business arrangements with RMR. RMR seeks to address these conflicts through its fiduciary obligations, suitability and cost‑effectiveness analyses, ongoing monitoring of client accounts and TPM performance, and full and fair disclosure. Wrap Fee Program Fees RMR’s Wrap Fee Program fees are charged as a single, flat percentage of the total account value. The fee is calculated by applying a fixed annual rate to the entire account value as of the end of the last billing period. This simplified fee structure means the same percentage rate is applied uniformly across the entire account balance. Annual Advisory Fee Schedule Assets Under Management (“AUM”) All Maximum Annual Fee 2.65% *Lower fees for comparable services can sometimes be available from other sources. The annual account management fee is billed quarterly based on the number of days in the quarter divided by 365 multiplied by the AUM fee. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are negotiable based on account value and type, but will not exceed the maximum Annual Fee indicated above. The final fee schedule is documented in the client’s executed Agreement. Additional funds and/or securities deposits during a particular calendar quarter will be billed on a pro rata basis, as stated in the client Agreement. Clients who withdraw funds from a managed account during a billing period are generally not entitled to a pro rata refund unless they terminate their Agreement or it is otherwise stated in the client Agreement. For ease of reference and to avoid repetition, the Program fee schedule and billing methodology are presented once in Item 4 and apply as described in the client’s executed Agreement Annual Account Administration Fee Effective April 1, 2024, RMR increased its annual Administrative Fee for accounts billed directly from $52 to $80. This Administrative Fee applies to both non‑wrap‑fee and wrap‑fee investment advisory programs. The Administrative Fee is prorated daily and charged quarterly, based on the number of days in the quarter divided by 365, as further described in the client’s Advisory Agreement. The fee is assessed to RMR fee‑based program clients in accordance with the terms of their executed Advisory Agreement. Regardless of the amount of assets under management, clients subject to the Administrative Fee receive access to and use of the BlackDiamond Wealth Platform, an online trading and reporting system. Through BlackDiamond, clients are provided with a secure, direct login to view portfolio information, review holdings, access account summaries and reports, and obtain educational and training materials. Clients may access this information independently or with the assistance of a dedicated Service Team Member, and the platform also supports ongoing client communications and tools to help clients monitor their investments. CIP Wrap Fee Program Services Fees Clients who elect to receive asset management services through RMR’s IAR Client Investment Portfolio (“CIP”) Wrap Fee Program pay a single, bundled wrap fee based on a percentage of assets under management (“AUM”), as set forth in the Annual Advisory Fee Schedule above and documented in the client’s executed Advisory Agreement. The wrap fee is calculated by applying the applicable annual rate to the total account value and is generally billed quarterly, in advance, in accordance with the terms of the client’s Agreement. The maximum annual advisory fee charged under the CIP Wrap Fee Program will not exceed 2.65% of AUM. 11  The CIP wrap fee covers RMR’s investment advisory, portfolio management, administrative, and oversight services, as described in this brochure. Certain costs and expenses are not included in the wrap fee and are charged separately, as disclosed herein. TPM Wrap Fee Program Services Fees Clients participating in RMR’s Third‑Party Manager (“TPM”) Wrap Fee Program pay a single, bundled wrap fee calculated as a percentage of assets managed within the Program, as disclosed in this Wrap Fee Program brochure and the client’s executed Agreement. Under the TPM Wrap Fee Program, the wrap fee is allocated between RMR and the referred TPM pursuant to contractual arrangements. Depending on the Agreement, a portion of the advisory fee paid by the client may be shared between RMR and the TPM. Fee structures under the TPM Wrap Fee Program vary by manager and account and are fully disclosed in the client’s Agreement and the TPM’s Form ADV disclosure brochure. TPM Wrap Fee Program fees may be structured in one or more of the following ways, as applicable:     A management fee split between RMR and the TPM. A fixed, flat percentage fee applied to total account assets. A tiered fee schedule applying different rates to different asset levels. A linear fee schedule applying a breakpoint percentage fee to total account assets. RMR’s portion of the wrap fee represents the maximum advisory fee RMR may receive under the TPM Wrap Fee Program and will not exceed applicable regulatory limits. The portion of the fee retained by RMR is disclosed in RMR’s Form ADV and the client’s Advisory Agreement and Fee Disclosure Statement. Additional details are provided in the referred TPM’s Form ADV disclosure brochure and separate manager agreement. Under both Wrap Fee Programs, advisory fees are generally billed quarterly, in advance, based on the account value as of the end of the prior billing period, unless otherwise stated in the client’s Agreement. The following billing practices apply:   Fees for the initial billing period are calculated on a pro‑rata basis at account inception. Advisory fees are calculated through Black Diamond and debited from the client’s custodial account pursuant to the client’s written authorization.   RMR generally remits the TPM’s portion of the fee; however, in certain cases, the TPM may debit the client’s account directly. In such cases, clients may see two line items reflecting the allocation of a single wrap fee, rather than duplicative fees. Payment of all fees is expected in accordance with the applicable Agreement. Additional Fees & Expenses Referred TPMs may charge fees that differ from, and are in addition to, those reflected in RMR’s Annual Advisory Fee Schedule. TPMs typically reserve the right, at their sole discretion, to reduce or waive their fees. In addition, certain investment vehicles used within portfolio model(s), such as mutual funds or exchange‑traded funds, impose internal management fees and operating expenses that are separate from and in addition to the Wrap Fee Program fee. Clients participating in the TPM Wrap Fee Program will receive account statements or electronic notifications through their qualified custodian or, where applicable, the TPM’s custodial platform, detailing all account activity, including advisory fee payments. Clients are encouraged to promptly review all statements upon receipt to verify accuracy and reconcile them with any reports provided by RMR. Clients should refer to their Advisory Agreement, any applicable TPM agreement, and the TPM’s Form ADV disclosure brochure for complete details regarding services, fees, billing practices, and expenses. RMR may amend its standard Annual Advisory Fee Schedule by providing clients with at least 30 days’ advance written notice, as required by applicable law and the client’s Agreement. Conflicts of Interest Fee‑sharing arrangements under the TPM Wrap Fee Program create a potential conflict of interest, as RMR and its IARs may have a financial incentive to recommend managers with whom such arrangements exist. These arrangements and the 12  associated compensation are disclosed to clients in advance. Because Wrap Fee Programs charge a single, bundled fee, the overall cost of participation may be higher than in traditional non‑wrap advisory arrangements, particularly for clients who engage in limited trading activity. Fees & Fee Billing Clients have two options to pay their RMR advisory fees: either via (1) direct debit or (2) billed, and will select their chosen method by indicating their preference in the Agreement they execute with RMR. As authorized by the client, RMR or its administrative agent typically requests that, for discretionary accounts, the qualified custodian debit account management fees from the client’s account automatically. For non-discretionary accounts, the client will be contacted to provide consent. Clients may also be billed for fees by writing a check directly to RMR or its administrative agent for the fee amount. For all advisory services, full payment of fees is expected promptly upon presentation of the invoice. The exact process for fee payment is as follows: Directly Debited Fees - For directly debited fees, clients will authorize RMR in writing to deduct advisory fees due from their custodial account and provide the custodian with authorization to deduct such fees and instructions to remit them directly to RMR.   For this type of fee payment, when fees are due, RMR will provide the qualified custodian with an advisory fee calculation based on the terms of the client's Agreement and direct the qualified custodian to remit the client a statement of the activity to the client's address of record - or another authorized address, as otherwise designated in writing by the client, reflecting the fee amounts paid to RMR for the quarter in question. If paid directly, the qualified custodian will deduct the client's advisory fees due, as instructed by RMR, on a quarterly basis, consistent with the billing terms disclosed in the client’s executed Agreement (typically in advance, unless otherwise stated in the Agreement), regardless of the portfolio's market performance during the quarter just ended. The account management fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings, according to the discretionary authority granted by the client to RMR, IAR, and the referred third-party manager, as applicable for the type of account established. When authorized by the client to debit advisory fees from client accounts, RMR is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct the fees. RMR urges clients to compare their custodial account statements with any periodic portfolio report or date they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us may vary based on accounting procedures, reporting dates, or valuation methodologies. If a client is not receiving statements directly from their custodian, in addition to advising their IAR promptly, RMR also recommends contacting their custodian directly. Billed Fees - Clients who wish to be directly billed by RMR for their advisory services fees will authorize this payment in writing on their advisory services contract and request that RMR invoice them directly quarterly for any fees due. Clients will then make their fee payments to RMR by separate check or credit card, and under no circumstances will any RMR advisory fees be deducted from amounts held in their custodial account(s). Other Fees & Expenses The fees client pay for RMR’s investment advisory services are separate and distinct from administrative fees, annual custody fees, brokerage costs, commissions, debit and credit interest, default charges, direct investments (such as limited partnerships and limited liability companies), margin and trade extensions, mailgrams, money market fees, physical reorganization costs, renege assessments, legal return/bounced check/stop payment/transfer and ship or safekeeping fees, transfer and sub-transfer agent and distributor fees, and other miscellaneous charges when purchasing or selling securities or for products and services customarily assessed by product manufacturers (which include but are not limited to, insurance companies, mutual or exchange- traded funds, real estate, oil and gas, and other providers of direct investments, as described in each product sponsors product prospectus to their shareholders) and the client’s account broker-dealers/qualified custodians. 13  RMR does not share in any portion of such additional fees or expenses imposed. Additional details on some of the above- mentioned and other customary fees and expenses the client may pay to other parties in connection with their portfolio accounts and investments follow: Margin Interest If a client purchases securities on margin, the client will incur interest charges imposed by the applicable broker‑dealer or qualified custodian on amounts borrowed to finance such purchases. The interest rate, calculation methodology, and associated risks are described in the margin agreement executed between the client and the broker‑dealer or custodian. Securities Transaction & Execution Fees Clients may also incur securities execution transaction fees charged by clearing broker‑dealers and passed through by the introducing broker‑dealer or custodian in connection with the purchase and sale of securities. Each broker‑dealer or qualified custodian provides its clients with a schedule of applicable transaction charges by security type and will notify clients of any changes to such fee schedules. Further, any mutual fund share classes that pay asset‑based sales charges or service fees (such as 12b‑1 fees) and that are received by RMR will be credited back to the client’s account. Additional information regarding fees and expenses assessed by mutual funds is available in the applicable fund prospectuses. Revenue Sharing & Other Considerations RMR makes available and may recommend a broad range of investment products and mutual funds. Certain product sponsors maintain marketing, educational, or distribution support arrangements intended to facilitate awareness of their investment offerings. As a result of such arrangements, RMR’s IARs may attend educational meetings, seminars, due diligence presentations, or conferences covering general industry topics, regulatory developments, or product‑specific information. Clients should be aware that different investment products may charge different commissions or internal expenses; however, RMR’s IARs do not receive a higher or lower commission percentage based on the selection of particular products. Nonetheless, receiving educational or promotional support from product sponsors presents a potential conflict of interest, as it could influence the focus or selection of the products recommended. Clients are under no obligation to purchase securities or insurance products through RMR or any person affiliated with RMR. Clients may buy recommended products through unaffiliated brokers or agents. Before transferring securities into an advisory account, clients are encouraged to consider and discuss with their investment adviser representative, tax professional, and other investment professionals, as appropriate:  Whether any commissions were previously paid or will continue to be owed under a deferred compensation arrangement.  Whether the client wishes to have the security managed in an advisory account, subject to an ongoing advisory fee.  Whether the client prefers to hold the security in an unmanaged brokerage account, not subject to an advisory fee. Clients are encouraged to review RMR’s Advisory Agreement, the agreements of any TPMs, and all applicable prospectuses, offering documents, and disclosures to understand the fees, costs, expenses, commissions, and other charges associated with their accounts and investments. Clients are encouraged to contact their IAR, tax professional, or other investment professionals with any questions. Account Additions, Withdrawals, Terminations & Assignments Clients may make additions to their accounts in cash or securities at any time. RMR reserves the right to liquidate any transferred securities or decline to accept particular securities into the client’s account. If RMR liquidates transferred securities, the client may be subject to additional fees, such as transaction fees and other fees assessed at the mutual fund level, such as contingent deferred sales charges, as well as tax ramifications. Clients may make withdrawals from their RMR accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. 14  Additions or withdrawals to a client account > $10,000 per month will incur additional prorated fees/prorated refunds. Generally, terminations of an RMR services Agreement may be made by written notice without penalty within five (5) business days after the Agreement execution date. After that, the Advisory Agreements between RMR and the client will continue in effect until either party terminates the Agreement in accordance with its terms, which state that Agreements may be terminated by either party upon at least thirty (30) days' written notice to the other party. (A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect:  The validity of any action previously taken by the Adviser under the Agreement.  Liabilities or obligations of the parties from transactions initiated before termination of the Agreement.  The client’s obligation to pay management and other fees due, pro-rated through the termination date. RMR will refund any unearned fees resulting from client advance payments to the Adviser. Likewise, if RMR bills the client in arrears for services already rendered, RMR will prorate those fees up to the termination date of the client Agreement. Any prepaid, unearned fees will be promptly refunded to the client pro rata based on the termination date. If the client is a natural person, the client’s death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of written notice of the client’s death. The disability or incompetency of the client will not terminate or change the terms of this Agreement; however, the client’s executor, guardian, attorney-in-fact, or other authorized representative may terminate this Agreement by giving written notice to RMR. Before termination, all directions given, actions taken, or omitted by RMR prior to the effective termination of the Agreement shall be binding upon the client and any successor or legal representative. RMR will no longer be entitled to receive fees from the termination date and has no obligation to recommend or act with respect to an account's securities, cash, or other investments under the terminated Agreement. The executed Advisory Agreement will govern additions, withdrawals, and terminations to third-party manager services. Each TPM’s agreement will continue until the client or the TPM terminates it by written notice to the other party. The third-party manager is responsible for refunding unearned fees in accordance with their contract terms. If the total value of the client’s account or aggregated accounts falls below the TPM’s minimum account size because of a withdrawal or other reasons, the TPM may terminate the Program Agreement. Before participating in any TPM offering, the client should review all applicable disclosure brochures, investor profiles, and third-party manager contracts. Finally, no RMR Agreement may be assigned, within the meaning of the Advisers Act, as amended, by the Adviser without the client's prior consent. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Investment Advisers Act of 1940, as amended, shall not be considered an assignment.) Brokerage Practices RMR does not maintain custody of the assets we manage on your behalf. Client assets must be held in an account at a "qualified custodian," generally a Broker-Dealer or bank. RMR’s preferred qualified custodian are Fidelity Investments Institutional Services Company, Inc. (“Fidelity”) and Charles Schwab & Co., Inc. (“Charles Schwab” or “Schwab”), both independent and separate registered broker-dealers, Members of FINRA and the SIPC, who will take possession of the cash, securities, and other assets within the client’s portfolio account and buy and sell securities upon our instructions, as indicated within each client’s written Agreement and the documents they execute to establish their custodial account with each qualified custodian unless the client directs otherwise. Research & Other Benefits An investment adviser receives custodial soft-dollar benefits when the firm obtains custodial research or other products or services related to client securities transactions. RMR may receive certain benefits from our Broker-Dealers/qualified custodian. These benefits include, but are not limited to, electronic access and download of trades, balances, and positions; confirmation 15  and statements in the broker-dealer or qualified custodian's portfolio management software; and access to related blotters, duplicate and batched client statements, confirmations, and year-end summaries. RMR also provides a dedicated trading desk and service group that assists our clients, an account services manager dedicated to our accounts, access to a real-time order-matching system, mutual funds with no transaction fees, and select institutional money managers. In addition, we can receive discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third-party vendors, and we can have advisory fees directly debited from client accounts in accordance with applicable federal and state requirements. Our approved, qualified custodian provides some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services, offer discounts, waive fees for some of these services, or pay all or part of a third party's fees. In effect, the fees our client pays generate the soft dollars used to pay for these administrative services. The Adviser will not seek to allocate soft-dollar benefits to client accounts in proportion to the soft-dollar credits the accounts generate. The availability of the above services, commonly called "soft dollars," benefits us because we do not have to produce, purchase, or pay for them, as long as our client collectively maintains a minimum amount of assets in our qualified custodian accounts. Beyond that, these services are not contingent on us committing to any specific volume of trading commissions or assets in custody. A conflict exists in such situations because RMR can be incentivized to select or recommend a Broker-Dealer based on the Adviser’s interest in receiving research or other products or services rather than the Adviser’s client’s interest in receiving the best value in custody services and most favorable execution of their transactions. While the conflict of interest exists, our client also measures our overall performance; the cost of these services necessarily reduces portfolio performance. It is in our best interests to minimize these costs to improve the overall performance of client portfolios. Furthermore, we believe that selecting any qualified custodian and broker-dealer is in our client's best interests. The scope, quality, and price of services received primarily support our selection, not services that benefit only us. (Please contact us directly for the most current qualifying amount of client assets.) Directed Brokerage RMR’s Wrap Fee Program requires that the client open and maintain a brokerage account through our pre-approved Broker- Dealer/qualified custodian. Wrap Fee Program accounts are generally maintained with one of RMR’s approved broker‑dealers/qualified custodians as a condition of participation in the Program. Clients should be aware that not all advisers require their clients to direct brokerage. A client who wishes to direct brokerage shall be responsible for negotiating the terms and arrangements with the broker- dealer/qualified custodian of their choosing. RMR will not be obligated to seek better execution services or prices, or to aggregate client account transactions for execution through other custodians, for orders on accounts we manage. As a result, a disparity in commission charges can exist between those charged to clients who do not direct brokerage and those who do, potentially resulting in higher trading expenses and less favorable transaction execution for clients with directed brokerage transactions. Directing brokerage may cost the client money. A client wishing to direct brokerage should consider the costs or disadvantages of such requests, including paying higher commissions or other transaction costs, wider spreads, being unable to aggregate orders to reduce transaction costs, or receiving less favorable prices on transactions for the account than would otherwise be the case. Accordingly, the client should satisfy themselves that their designated broker can provide adequate pricing and execute their transactions. Subject to its duty to seek best execution, RMR may also decline a client’s request to direct brokerage if, at our discretion, such brokerage arrangements would result in operational difficulties. Directed Brokerage - Special Considerations for ERISACclients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted if the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. (Note: ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan.) 16  Trade Aggregation RMR combines multiple orders for shares of the same securities purchased for the advisory accounts we manage ("aggregated trading"). Under RMR’s CIP Wrap Fee Program, when accounts are being traded, they are included in the block trades processed to rebalance model accounts. If we are trading a one-off position to raise cash, they are not traded. For TPM Wrap Fee Programs, since RMR does not trade these accounts, trade aggregation will be handled according to the third-party manager’s direction. The costs of not aggregating orders when the opportunity exists include the inability to facilitate best execution, potentially increasing brokerage commissions or other costs. RMR may aggregate (“block”) transactions for Program accounts when it determines that doing so is consistent with seeking best execution and fair allocation. RMR does not aggregate transactions for the purpose of obtaining or allocating any brokerage‑based benefits among accounts. Types of Investments Clients will invest by establishing one or more accounts (the "Managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Assets managed as part of the Wrap Fee Program are regularly monitored, with investment strategy purchase and sale transactions based on the client’s specific needs and investment goals. Wrap Fee Program Services typically provide investment advice for various investment types and security types, including, but not limited to, stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), unit investment trusts, derivatives, and other investments as discussed herein. The client’s Suitability Information helps us in selecting and allocating assets as follows: Capital Preservation - A portfolio geared towards capital preservation that invests predominantly in the fixed-income sleeve while striving to minimize potential losses. This option is focused on clients who prefer more loss protection than a stock-invested portfolio may offer. Conservative - A portfolio designed for a client with interests primarily concerned with reducing asset risk, such as those approaching retirement or who desire decreased risk of loss but still desire some exposure to stocks to provide asset growth potential. Conservative Growth - This portfolio is designed for clients who want the potential for some asset growth. Most assets are invested in the fixed-income sleeve, yet there is a reasonable exposure to equity sleeves. Moderate - this portfolio seeks capital preservation and investment growth as near-equal objectives. The risk/return goal is designed to address a client’s wish for the potential for higher returns from stocks over time, without the extreme short-term variations that can occur. Moderate Growth - A portfolio weighted more toward equity sleeves but with a significant amount of funds in the fixed- income sleeve. This option is designed for clients with a medium to long-term investment horizon. Growth - This portfolio seeks growth through equities while balancing risk with fixed-income funds. It is designed for clients who are comfortable accepting some risk in exchange for the potential for higher returns from stocks over time. Aggressive - A portfolio invested predominantly in equity with only a small proportion invested in bonds. The goal is to produce investment growth. This portfolio is designed for clients willing to accept a much higher equity allocation in exchange for the potential for higher returns. The client should typically have an investment time horizon of more than five years. Item 5: Account Requirements & Types of Clients ____________________________________________________________________________________________________ Types of Clients RMR primarily provides investment advisory services to individuals, high-net-worth individuals, partnerships, trusts, corporations, retirement/pension and profit-sharing plans, charitable organizations, and other institutions and business entities. Minimum Account Size There is no account minimum for RMR’s services, and there are no ongoing contribution requirements for client accounts. However, this practice is highly recommended for continued savings, asset allocation, and tax efficiency. 17  Accounts managed by unaffiliated third-party managers are subject to the independent TPM’s account minimums (typically between $25,000 and $1,000,000), as disclosed in each referred manager's contract. In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they execute with their referred TPM. Item 6: Portfolio Manager Selection & Evaluation ____________________________________________________________________________________________________ RMR is the sponsor and Portfolio Manager for CIP and TPM investment accounts. Should we choose to utilize one or more portfolio managers throughout serving you, the evaluation of each portfolio manager will be based on data and information from several sources, including the manager and independent databases. Among the types of information analyzed are historical performance, investment philosophy, investment style, historical volatility, and asset-class correlations. Performance-Based Fees & Side-by-Side Management Performance-based fees are fees based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. RMR does not accept performance-based fees or participate in side-by-side management. Methods of Analysis We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Cyclical Analysis - A technical analysis involving evaluating recurring price patterns and trends. With this type of analysis, economic/business cycles may be unpredictable, fluctuating between long-term expansions and contractions, and their lengths may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty of predicting economic trends and, consequently, the changing value of securities affected by these trends. Fundamental Analysis - A security evaluation method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price to determine what position to take with that security (underpriced = buy, overpriced = sell or short). This security analysis method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, using fundamental analysis may not yield favorable returns. Quantitative Analysis - An analysis technique that seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research. By assigning numerical values to variables, quantitative analysts aim to model reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Technical Analysis (“Charting”) - A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that a stock's performance, rather than the company's performance, is more closely tied to its future stock price. Some risks of this type of analysis include biased opinions or indicators that, while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. Our investment strategies and advice will vary depending on each client’s financial situation. Therefore, it is essential that the client notify us immediately of any material changes to their financial circumstances, including, for example, changes in their current or expected income level, tax circumstances, or employment status. While RMR’s IARs may provide advice on any investment held in a client’s portfolio at the inception of the advisory relationship and explore other investment options at the client’s request, they reserve the right to advise client on any other type of investment 18  deemed suitable based on the client’s stated goals and objectives. Additionally, when balancing portfolios, IARs will consider only the account’s managed assets, not other investments the client may hold elsewhere. Investment Strategies Our investment strategies and advice will vary depending on each client’s financial situation as we determine investments and allocations based on their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in their best interest objective. client restrictions and guidelines will also affect the composition of their portfolio. In addition to the “Risks of Loss & Other Types of Risks” provided for review herein, the following are other items can also be items for consideration when determining investment strategies and practices: Asset Allocation - an investment strategy that aims to balance risk and reward by allocating assets among various asset classes. At a high level, there are three main asset classes - (1) equities (stocks), (2) fixed income (bonds), and (3) cash and cash equivalent, each with different risk and reward profiles and behaviors. Asset classes are often further divided into domestic and foreign investments. Equities are frequently divided into small, intermediate, and large capitalization and fixed income into short, intermediate, and long-term durations. The general theory behind asset allocation is that each asset class will perform differently from others in changed market conditions. By diversifying a portfolio of investments among various asset classes, advisors seek to reduce a portfolio's overall volatility and risk by avoiding overexposure to any asset class during different market cycles. Asset allocation does not guarantee a profit or protect against loss. Capital Growth and/or Income Strategy - a“growth and income strategy” often invests in companies with earnings growth and those that pay dividends. Risks associated with a capital growth and income strategy are similar to those experienced with income and growth strategies. For example, bonds can be called when interest rates drop, and replacing a called bond with another paying the same interest may be impossible. Companies can suspend dividends for certain stocks if they experience financial problems. A growth investing strategy includes the search for stocks that have growth potential. The latter means that the stock price will rise at a certain point in time. As a result, growth investors may target young companies that have the potential to exceed their peers in the industry or sector. By its very nature, growth investing implies risk because some of the young companies may fail. Dollar Cost Averaging - the technique of regularly buying a fixed dollar amount of a particular investment, regardless of the share price (“DCA”). More shares are purchased when prices are low and fewer when prices are high. This investment strategy is believed to lessen the risk of investing a large amount at a single investment at a higher price. DCA strategies are ineffective and do not prevent loss in declining markets. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Short-Term Purchases - securities are purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Buying on margin means borrowing money from a Broker-Dealer to purchase stock. Margin trading allows investors to buy more stock than they would typically be able to buy. An initial investment of at least $2,000 is required for a margin account, although some brokerages require more. This deposit is known as the minimum margin. Once the account is operational, the holder can borrow up to 50% of the stock purchase price. This portion of the deposit purchase price is the initial margin. Investors can be required to deposit more than 50% of the purchase price. Not all stocks qualify to be bought on margin. When selling the stock in a margin account, the proceeds go to the Broker-Dealer against the repayment of the loan until it is fully paid. A maintenance margin restriction also exists - the minimum account balance that must be maintained before the Broker-Dealer forces the deposit of additional funds or sell stock to pay down the loan (when this happens, it is known as a “margin call.”) If, for any reason, a margin call is unmet, the Broker-Dealer has the right to sell account securities to increase the account equity until above the maintenance margin. Additionally, the Broker-Dealer may not be required to consult the account holder before selling. Under most margin agreements, a firm can sell the account securities without waiting for the account holder to meet the margin call, and the account holder cannot control which stock is sold to cover the margin call. Interest on the loan must also be paid. The interest charges are applied to the account unless separate payments are made. Over time, the debt level increases as interest charges accrue. As debt rises, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer an investment 19  is held, the greater the return needed to break even. In volatile markets, prices can fall quickly, and more money can be lost than invested. (Note: RMR requires the pre-approval of a designated Home Office Principal before implementing any margin strategy.) Options Writing - a securities transaction that involves selling options, which are the right, but not the obligation, to buy or sell a particular security at a specified price before the option's expiration date. When an investor sells an option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. The buyer pays the seller a premium (the option's market price at a particular time) in exchange for the seller writing the option. Short Selling - client participating in these portfolios will receive additional disclosure information regarding the risks of short-sale investments. Unhedged, short selling is very risky. Unlike a straightforward investment in stocks, where shares are purchased with the expectation that their price will increase to sell at a profit, in a "short sale," stock is borrowed from a brokerage firm and then immediately sold in hopes that the price will have dropped when they are required to be purchased at a later date. Thus, a short seller hopes a stock's price will decrease in the future to use market declines to their advantage. Short sellers make money when the stock prices fall and lose money when prices increase. The SEC has strict regulations regarding short selling. No ceiling exists on how much a short seller can lose in a trade - if the share price keeps increasing, the short seller must pay the prevailing stock price to buy back the shares. However, a ceiling exists on gains that can be made because a stock’s price cannot fall below zero. In addition, a short seller must undertake to pay the earnings on their borrowed securities as long as they choose to keep their short position open. If a company declares huge dividends or issues bonus shares, the short seller must also pay that amount to the lender. Any such occurrence can skew the entire short investment and make it unprofitable. Finally, a broker can use the funds in the short seller's margin account to buy back the loaned shares or issue a “call away” to require the short seller to return the borrowed securities. If this call is made by the broker when the stock price is significantly higher than the price at the time of the short sale, the investor can suffer tremendous losses. Tax Considerations RMR’s strategies and investments can have unique and significant tax implications. However, unless expressly agreed upon otherwise and in writing, tax efficiency is not the primary consideration in managing client assets. Regardless of client account size or any other factors, RMR strongly recommends that our clients continuously consult with a tax professional before and throughout investing their assets. The qualified custodian will typically default to the FIFO (“First-In, First-Out”) accounting method for calculating portfolio investment cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If a client or their tax advisor believes another accounting method is more advantageous, immediately notify our firm and the account qualified custodian of the selected accounting method in writing. (Note: Decisions about cost-basis accounting methods must be made before trades settle, as the cost-basis method cannot be changed after settlement.) Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation, as we determine investments and allocations based on their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in their best interest objective. Client restrictions and guidelines will also affect the composition of their portfolio. In addition to the “Risks of Loss & Other Types of Risks” provided for review herein, the following are other items that can also be considered when determining investment strategies and practices: Asset Allocation - This investment strategy aims to balance risk and reward by allocating assets among various asset classes. At a high level, there are three main asset classes: (1) equities (stocks), (2) fixed income (bonds), and (3) cash and cash equivalents, each with different risk and reward profiles and behaviors. Asset classes are often further divided into domestic and foreign investments. Equities are often divided into small-, intermediate-, and large-cap, and fixed income into short-, intermediate-, and long-term. The general theory behind asset allocation is that each asset class will perform differently under different market conditions. By diversifying a portfolio across asset classes, advisors aim to reduce volatility and risk by avoiding overexposure to any single asset class during different market cycles. Asset allocation does not guarantee profits or protect against losses. Capital Growth and/or Income Strategy - A “growth and income strategy” often invests in companies with earnings growth and those that pay dividends. Risks associated with a capital growth and income strategy are similar to those experienced with income and growth strategies. For example, bonds can be called when interest rates drop, and 20  replacing a called bond with another paying the same interest may be impossible, or companies can suspend dividends for certain stocks if they experience financial problems. A growth investing strategy involves seeking stocks with growth potential. The latter means the stock price will rise at some point. As a result, growth investors may target young companies with the potential to outperform their peers in the industry or sector. By its very nature, growth investing entails risk, as some young companies may fail. Dollar Cost Averaging - The technique of regularly buying a fixed dollar amount of a particular investment, regardless of the share price (“DCA”). More shares are purchased when prices are low and fewer when prices are high. This investment strategy is believed to reduce the risk of investing a large sum in a single asset at a higher price. DCA strategies are ineffective and do not prevent loss in declining markets. Long-Term Purchases - Securities purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Short-Term Purchases - Securities are purchased with the expectation that they will be sold within a relatively short period, generally less than 1 year, to take advantage of their short-term price fluctuations. Margin Transactions - A securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Buying on margin means borrowing money from a broker-dealer to purchase stock. Margin trading allows investors to buy more stock than they could otherwise. An initial investment of at least $2,000 is required for a margin account, although some brokerages require more. This deposit is known as the minimum margin. Once the account is operational, the holder can borrow up to 50% of the purchase price of the stock. This portion of the deposit purchase price is the initial margin. Investors can be required to deposit more than 50% of the purchase price. Not all stocks qualify for purchase on margin. When selling stock in a margin account, the proceeds go to the broker-dealer to repay the loan until it is fully paid. A maintenance margin restriction also exists - the minimum account balance that must be maintained before the broker-dealer forces the deposit of additional funds or sell stock to pay down the loan (when this happens, it is known as a “margin call.”) If for any reason, a margin call is unmet, the broker-dealer has the right to sell account securities to increase the account equity until above the maintenance margin. Additionally, the broker-dealer may not be required to consult the account holder before selling. Under most margin agreements, a firm can sell the account's securities without waiting for the account holder to meet the margin call, and the account holder cannot control which stock is sold to cover the margin call. Interest on the loan must also be paid. The interest charges are applied to the account unless separate payments are made. Over time, the debt level increases as interest charges accrue. As debt rises, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer an investment is held, the greater the return needed to break even. In volatile markets, prices can fall quickly, and more money can be lost than invested. Options Writing - A securities transaction that involves selling options, which are the right, but not the obligation, to buy or sell a particular security at a specified price before the option's expiration date. When an investor sells an option, they must deliver a specified number of shares to the buyer if the option is exercised. The buyer pays the seller a premium (the option's market price at that time) to have the seller write the option. Short Selling - clients participating in these portfolios will receive additional disclosure information regarding the risks of short-sale investments. Unhedged, short selling is very risky. Unlike a straightforward investment in stocks, where shares are purchased with the expectation that their price will increase to sell at a profit, in a "short sale," stock is borrowed from a brokerage firm and then immediately sold in hopes that the price will have dropped when they are required to be purchased at a later date. Thus, a short seller hopes that a stock's price will decrease in the future, using market declines to their advantage. Short sellers make money when the stock prices fall and lose money when prices increase. The SEC has strict regulations regarding short selling. No ceiling exists on how much a short seller can lose in a trade - if the share price keeps increasing, the short seller must pay the prevailing stock price to buy back the shares. However, there is a ceiling on gains because a stock’s price cannot fall below zero. In addition, a short seller must pay interest on borrowed securities as long as their short position remains open. If a company declares huge dividends or issues bonus shares, the short seller must also pay that amount to the lender. Any such occurrence can skew the entire short investment and make it unprofitable. Finally, a broker can use the funds in the short seller's margin account to buy back the loaned shares or issue a “call away” to require the short seller to return the borrowed securities. If this call is made by the broker when the stock price is significantly higher than the price at the time of the short sale, the investor can suffer tremendous losses. 21  Investment strategies implemented on behalf of registered investment companies are subject to the applicable fund’s stated investment objectives, policies, and restrictions, as disclosed in the fund’s prospectus and related offering documents. Accordingly, such strategies may differ, in whole or in part, from those employed for separately managed account clients, over which RMR typically exercises broader discretionary authority, subject to each client’s investment objectives, guidelines, and restrictions. Tax Considerations RMR’s strategies and investments can have unique and significant tax implications. However, unless expressly agreed upon otherwise and in writing, tax efficiency is not the primary consideration in managing client assets. Regardless of client account size or other factors, RMR strongly recommends that our clients consult with a tax professional before and throughout investing their assets. Qualified custodians will typically default to the FIFO (“First-In, First-Out”) accounting method for calculating portfolio investment cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If a client or their tax advisor believes another accounting method is more advantageous, immediately notify our firm and the account's qualified custodian of the selected accounting method in writing. (Note: Decisions about cost-basis accounting methods must be made before trades settle, as the cost-basis method cannot be changed after settlement.) Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. clients have access to a wide selection of product offerings and securities, including, but not limited to, bonds (treasury inflation-protected and inflation-linked), business development companies, certificates of deposits, commercial paper, derivatives, Digital Assets, equities, exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships (real estate, oil, and gas), mutual funds (load and no-load), non-U.S. securities, options, private placements, real estate investment trusts, unit investment trusts, and warrants, among others, as appropriate and suitable for each account’s goals. Cash Management As indicated below, RMR usually invests clients' cash balances in Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts, money market funds, or certificates of deposit. In managing cash held in client accounts, we typically use the sole, exclusive cash vehicles made available by the custodian, in accordance with their parameters. Other cash management and money-market options may be available outside the custodian, offering higher yields or safer underlying investments. In most cases, at least a partial cash balance will be maintained in a money market or FDIC-insured deposit account to allow for the debit of advisory fees or anticipated client cash distributions. We will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: This type of investment product is usually not FDIC insured, insured by any Federal government agency, a deposit, other obligation, or guaranteed by the adviser.) StoneCastle Cash Management, LLC Program RMR makes the Keep® Program available and refers clients to it, which is sponsored by StoneCastle Cash Management, LLC (“StoneCastle”). The Federally Insured Cash account Program offered by StoneCastle allows clients the ability to protect their money by placing it in deposit accounts at banks, savings institutions, and credit unions in a manner that maintains full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of insured depositories. StoneCastle requires a minimum deposit of $100,000 to open a KEEP account, and RMR earns a referral fee from StoneCastle if clients participate in this program. RMR’s referral fee starts at 20 basis points and increases if the client's interest rate rises. clients' interest rates from the KEEP program are net of all fees, including the fee RMR receives for client referrals to the program. RMR will assist clients in signing up for this program and facilitating funds transfer between the client’s like-named accounts. Clients participating in the program receive a copy of StoneCastle’s Form ADV. The above cash management program creates a potential conflict of interest between clients who choose to participate and our firm, as recommending this program means RMR receives Promoter referral compensation if clients decide to engage 22  StoneCastle's services. RMR addresses this conflict of interest by advising clients of the nature of the conflict whenever any referral is made. Clients are under no obligation to participate in the program. Risks of Specific Securities Utilized While RMR seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. IARs will recommend various types of securities, as indicated herein and deemed appropriate for each client’s situation, restrictions (if any), and goals. Although advice is provided predominantly on the products listed within this brochure, RMR reserves the right to advise on any suitable investment product for a client's specific circumstances, needs, and individual goals and objectives. We will use other securities to help diversify a portfolio when applicable and appropriate. Investing also risks missing more favorable returns that could be achieved by investing in alternative securities or commodities. Any of the above investment strategies may result in losses, especially if markets move against the client. Additionally, we may advise on other assets held in the portfolio at the inception of the advisory relationship. Since investment strategies and advice are based on each client's financial situation, the advice we provide to one client may differ from or conflict with that for the same security or investment for another client, as each client's needs and risk tolerance differ. Clients should be aware of the 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. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains; they should not invest unless they can bear these losses. Recommendation of Particular Security Types RMR recommends various types of securities and does not primarily favor one type over another, as each client has different needs and risk tolerance. As each security type has its unique set of associated risks, it would be impossible to present every specific risk of each investment type. Even within the same kind of investment, risks can vary widely. However, in very general terms, the higher the anticipated return on an investment, the greater the risk of loss. A description of some of the security types we may recommend and some of their inherent risks follows: Annuities - Annuities are financial products that pay a fixed stream of payments to an individual, primarily used as a source of income for retirees. The period during which an annuity is funded before payouts begin is called the accumulation phase. The annuitization phase begins once payments commence. Annuities can be structured as fixed or variable. Fixed annuities provide regular periodic payments to the owner/annuitant. Variable annuities allow the owner/annuitant to receive larger periodic payments if the investments in the annuity do well; however, if the investments do poorly, the owner/annuitant will receive smaller payments. In addition, the annuity services offered by RMR will incur charges, expenses, and miscellaneous fees separate and distinct from the Advisory fee charged by the Adviser. Bank Obligations - Bank obligations, including bonds and certificates of deposit, may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates. They may be adversely affected by downturns in the US and foreign economies, as well as by changes in banking regulations. Bonds - Corporate debt securities (or "bonds") are typically safer investments than equity securities. Still, their risk can vary widely based on the issuer's financial health, the risk of issuer default at maturity, and whether the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character that pays the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in risk and reward. Some risks associated with bond funds include credit, interest rate, and prepayment risks. 23  Certificates of Deposit - Certificates of deposit (“CDs”) are generally a safe type of investment, as they are insured by the Federal Deposit Insurance Corporation (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Corporate Bonds - Corporate bonds are debt securities issued by corporations to raise capital. Issuers pay investors periodic interest and repay the borrowed amount periodically throughout the life of the security or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate based on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Digital Assets - As used herein, “Digital Assets” refers to an asset issued and/or transferred using a distributed ledger or blockchain technology. The investment objective of RMR’s Digital Asset account allocation is to offer interested clients exposure to the Digital Assets market via a portfolio comprised of Digital Assets available through Fidelity Digital Assets® (Fidelity Investments®’ digital asset platform), with assets custodied at Fidelity Digital Asset Services, LLC. An investment in Digital Assets is appropriate only for clients who (1) understand the speculative nature of such securities, (2) can bear the economic risk of the investment, (3) have no urgent need for liquidity with the assets committed to this type of investment, and (4) and are willing to accept the risks of loss of their entire investment in exchange for the potential benefits and returns Digital Assets may offer. Given the complexity of this product, investment decisions made for the allocation of any portfolio of Digital Assets are expressly subject to various potential risks, including but not limited to the following: Custody Risk - Under the Advisers Act, SEC-registered investment advisers must hold securities with “qualified custodians,” among other requirements. Certain Digital Assets may be deemed to be securities. Some Digital Assets do not currently fall within the SEC's definition of a security. Therefore, many companies that provide Digital Asset custodial services fall outside the SEC’s definition of “qualified custodian.” Accordingly, clients seeking to purchase actual digital coins/tokens/currencies may need to use non-qualified custodians to hold all or a portion of their Digital Assets. Further, Digital Asset holdings are not considered legal tender or insured by the government, as U.S. bank deposits are. Therefore, investors do not have the same protections as a bank account can offer. Unlike most traditional currencies, such as the U.S. dollar, the value of a Digital Asset is not tied to promises by a government or a central bank - Digital Asset investments are uninsured. Exchange & Business Hours Risk - Exchanges can stop operating due to security breaches, fraud, insolvency, market manipulation, market surveillance, KYC/AML procedures, non-compliance with applicable rules and regulations, technical glitches, hackers, malware, or other reasons. Blockchain technology is a relatively new, untested distributed ledger. Blockchain systems could be subject to internet connectivity disruptions, consensus failures, or cybersecurity attacks, and the date or time an investor initiates a transaction may differ from when the transaction is recorded on the blockchain. Digital Asset prices can fluctuate, sometimes heavily, after traditional market hours. RMR accepts no responsibility for its inability to buy or sell Digital Assets outside standard industry trading hours. Government Oversight of Digital Assets Risk - Regulatory agencies and/or the entities responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and may be subject to change. Regulators may adopt laws, regulations, policies, or rules that directly or indirectly affect Digital Assets, their treatment, transactions, custody, and valuation. Liquidity Risk - Liquidity may be limited or disrupted, and there can be no guarantee of the ability to sell or exchange Digital Assets at any price. Trades may not settle, be challenging to settle, or be traded only at significantly adverse prices, depending on market conditions or volume. Loss of Confidence Risk - Digital Assets are part of a new, rapidly evolving “Digital Assets industry,” subject to high levels of uncertainty. For a relatively small use of Digital Assets in the retail and commercial marketplace, online platforms have generated a large trading activity by speculators seeking to profit from the 24  short-term or long-term holding of Digital Assets. A central bank, national or international organization, assets or other credit do not back most Digital Assets. Their value is strictly determined by market participants' valuations through transactions, so a loss of confidence may trigger a collapse in trading activity and an abrupt drop in value. Peer-to-Peer Transaction Risk - Digital Assets can be traded on numerous online platforms through third- party service providers and through peer-to-peer transactions between parties. Many marketplaces bring together counterparties without providing clearing or intermediary services or being regulated. In such a case, all risks (such as double-selling) remain between the parties directly involved in the transaction. Price Volatility of Digital Assets Risk - A principal risk in trading Digital Assets is rapid price fluctuations. The value of client portfolios is partly determined by the value of the Digital Assets held in those portfolios; fluctuations in the prices of Digital Assets could adversely affect a client’s portfolio. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex factors such as supply and demand, availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Digital Assets users and market participants; perceived or actual security vulnerability; and traditional risk factors including inflation levels; fiscal policy; interest rates; and political, natural and economic events. Protocol & Governance Risk - Digital Assets are a relatively recent technological innovation. Bitcoin, invented in 2009, is widely considered to be the first popular Digital Asset. Other Digital Assets we may invest in were created after Bitcoin. There can be no assurance that the Digital Asset industry will continue in its current form. Digital Assets are generally created and supported by an underlying blockchain or protocol, such as the Bitcoin or Ethereum Protocols. Any malfunction, malicious attack, breakdown, or abandonment of the network may adversely affect the Digital Asset’s protocol or network, leading to a loss of value for the Digital Asset. Moreover, advances in cryptography or technical advances such as quantum computing could pose risks to Digital Assets by rendering the cryptographic consensus mechanism that underpins a Digital Asset’s protocol ineffective. There can be no assurance that changes or developments in Digital Asset protocols will not adversely impact your account. Regulatory Risk - Regulatory uncertainties surrounding blockchain and distributed ledger technologies abound. Because global and national standards are far from fully established, fund managers face a heavy disclosure obligation to report existing regulatory considerations and the potential outcomes of regulatory issues that have yet to be decided. The comprehensive regulation facilitating institutional investment will require coordination of global standards, particularly for exchanges. In the U.S., regulatory standards will likely be set by a combination of state, national, international, and industry bodies, judicial precedent, international agreements, and industry associations. Service Providers Risk - Service providers supporting Digital Assets and Digital Asset marketplace(s) may not be subject to the same regulatory and professional oversight as traditional securities service providers. Further, there is no assurance that the availability and access to virtual currency service providers will not be negatively affected by government regulation or by changes in the supply and demand for Digital Assets. Accordingly, companies or financial institutions that currently support virtual currency may no longer do so. Tax Risk - It should be noted that there is substantial uncertainty regarding the tax treatment of investments in Digital Assets. Digital Assets may be considered assets in certain jurisdictions and currency in others. Sales or value-added taxes may be imposed on the purchase and sale of Digital Assets. Depending on their home jurisdiction, investors may need regular tax advice to ensure the tax treatment of their investments in Digital Assets. Technology & Security Risk - Digital Assets are computer-coded entries on a digital ledger, or blockchain, visible to and verifiable by nodes. Ownership is reflected in a string of numbers on a distributed ledger, accessible only via public and private keys in “wallets.” A custodian could hold a “private key” and a “public key” to the Digital Asset to satisfy regulatory requirements. A custodian can maintain private keys in digital form on a computer hard drive, disconnected from the internet and protected by multiple layers of cybersecurity. The custodian can also preserve and secure the private key in a “cold wallet,” such as by locking it in a physical vault. In any event, the technology used for safeguarding Digital Assets is emerging. 25  Digital Assets are essentially bearer assets. In general, anyone who obtains possession of the private key can, in theory, misappropriate the asset, no matter where the private key is maintained. Unanticipated Risks - Digital Assets are new and still largely untested. In addition to the risks disclosed, there are other risks associated with purchasing Digital Assets that RMR cannot anticipate. Such risks may further materialize as unanticipated variations or combinations of the risks discussed. Digital Asset investments are inherently global; therefore, exchange platforms, custodians, counterparties, and issuers are rarely located within a single jurisdiction. Currently, the industry lacks a standard regulation or auditing practice for verifying ownership of accounts holding Digital Assets. The Investment has counterparty and custody risks, including loss or theft of the Digital Asset itself. Valuation Risk - The valuation of Digital Assets can differ significantly depending on the pricing source or other factors, including but not limited to market fragmentation, unregulated markets, illiquidity, and volatility. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. Volatility & Loss Risks - Digital Assets are highly speculative and involve high risk. Prices of Digital Assets are incredibly volatile and can be more volatile than other traditional investments, such as stocks and bonds, and market movements can be challenging to predict. If the value goes down, it is not guaranteed to rise again. As a result, there is a significant risk of losing the entire principal investment. Gains and losses are unpredictable, and there is no guarantee of returns. Interests should not be purchased by anyone who cannot afford the loss of their entire investment. Transactions involving Digital Assets may be irreversible, and losses from fraudulent or accidental transactions may not be recoverable. There are counterparty and custody risks associated with Digital Assets, including loss or theft. Exchange-Traded Funds (“ETFs”) - ETFs are typically investment companies classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, particularly when ETF shares are listed on a securities exchange. An ETF is designed to track the price of an index or a collection of underlying assets as closely as possible. Shares can be bought and sold throughout the day, like those of publicly traded companies, and may trade at a discount or premium to their NAV. This difference between the bid and ask prices is often called the "spread." The spread varies over time based on the ETF's trading volume and market liquidity. It is generally lower when the ETF has high trading volume and market liquidity, and higher when it has low trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, like traditional mutual funds, some ETFs (particularly those that invest in commodities such as gold and precious metals) are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged ETFs, in particular, present distinct risks and are not appropriate for all investors. Leveraged ETFs should be used only by investors who understand the risks of seeking daily leveraged or inverse investment results, generally for short- term active trading within an actively monitored and managed investment program. Investors must be aware of the daily nature of leveraged and inverse investment strategies, the high expense ratios, and the lack of guarantee of long- term inverse returns, among other considerations, before participating in this type of investment. Exchange-Traded Notes (“ETNs”) - An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to various assets, such as commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN include the following. The repayment of principal, interest (if any), and any returns at maturity or upon redemption depends on the ETN issuer's ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer's credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class, or country, and may carry particular risks. ETNs may be closed and liquidated at the discretion of the issuing company. Fixed Income Call Options - Including agency, corporate, and municipal bonds and all mortgage-backed securities - contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk: investors 26  will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Limited Partnerships, Limited Liability Companies & Business Development Companies - Limited partnerships, limited liability companies, and business development companies represent different forms of ownership of investment assets. These entities are investment vehicles that may own full or partial interests in various operating businesses. The types of operating companies may include, but are not limited to, equipment leasing, oil and gas, alternative energy, and real estate. Managed Futures Funds - A managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that trade various derivative instruments, including options, futures, forwards, or spot contracts, which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks depending on its nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in the underlying funds. It may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds, as well as the fund's direct fees and costs. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees on each underlying fund's returns. There may be periods when fees are paid to one or more underlying fund managers even though the fund has lost money during that period. Money Market Funds - A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission notes, "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments, such as stocks, their long-term average returns tend to be lower than those of riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities - Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project, like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds - Mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. Mutual funds can also be "closed-end" or "open-end." So-called “open-end” mutual funds allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. Some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund; others charge such fees, which can also reduce returns. Mutual funds are sold in different share classes and may offer investors discounts on sales charges, as described in each fund's prospectus. Funds will have a manager who trades the fund's investments in line with the fund's investment objective. Mutual fund shares held in client accounts may also be subject to 12b-1 fees, short-term redemption fees, and other fund annual expenses. No-load or load-waived mutual funds used in client portfolios do not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Non-advisory accounts typically have upfront or back-end charges. Each fund's prospectus fully describes these fees and costs. If clients have mutual funds in their 27  portfolio, they will pay their adviser, any third-party manager, custodian, and mutual fund manager to manage their assets, as well as any other fund expenses paid by the fund's shareholders. If clients transfer particular share classes of mutual funds and liquidate those shares after the transfer, the shares may also incur contingent deferred sales charges (“CDSCs”) from the mutual fund company if they are within the CDSC holding period. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. In short, all these costs of managing the funds can reduce the fund’s returns. Options - Options are complex securities involving risks that are not necessarily in everyone’s best interest. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: 1. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Call buyers hope the stock will increase substantially before the option expires. 2. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to shorting a stock. Put buyers hope that the stock price will fall before the option expires. The risks for option buyers include the potential to lose their entire investment in a relatively short period. This risk increases as expiration nears if the stock is below the call's strike price (for a call) or above the put's strike price (for a put). European-style options that lack secondary markets for sale before expiration can only realize their value at expiration. In addition, specific exercise provisions of a specific option contract may create risks, and regulatory agencies may impose exercise restrictions, which stop you from realizing value. Selling options is more complicated and can be even riskier. The option trading risks for options sellers include, but are not limited to:  Options sold may be exercised at any time before expiration.  Covered call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock.  Writers of naked calls risk unlimited losses if the underlying stock rises.  Writers of a naked put are exposed to a maximum loss equal to the strike price minus the premium received from the sale.  Writers of naked positions run margin risks if the position goes into significant losses, and such risks may include liquidation by the broker.  Writers of call options can lose more money than a short seller of that stock on the same rise in that underlying stock - an example of how the leverage in options can work against the options trader.  Writers of naked calls must deliver shares of the underlying stock if those call options are exercised.  Call options can be exercised outside market hours, so the writer cannot take effective remedial action.  Writers of stock options are obligated under the options that they sold, even if a trading market is not available or they cannot perform a closing transaction.  The value of the underlying stock may surge or drop unexpectedly, leading to automatic exercises. Other option trading risks include the complexity of some option strategies carrying a significant risk on their own, option trading exchanges or markets and options contracts are open to changes at all times, options markets have the right to halt the trading of any options, thus preventing investors from realizing value, there is a risk of erroneous reporting of exercise value, investors trading through that firm may be affected If an options brokerage firm goes insolvent, and Internationally traded options have unique risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, since stock options are derivatives of stocks. Options Contracts - Options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a 28  long position on a stock. Call buyers hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to shorting a stock. Put buyers hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Real Estate - Real estate is increasingly used as part of a long-term core strategy due to greater market efficiency and growing concerns about the long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still carries considerable market risk. Real estate has proven very cyclical, mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors who wish to add real estate to their core investment portfolios need to consider property concentrations by area or property type. Because property returns are directly affected by local market fundamentals, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk-mitigating attributes and bear additional risk when overly influenced by local or sector market changes. Real Estate Investment Trusts - A real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs must declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations. Hence, cash flow must be strong, or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation risks due to cash flows, dividends paid in stock rather than cash, and debt payments that dilute shares. Securities Futures Contracts - A futures contract (on tangibles and intangibles) is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index at a specified price on a specified future date. Unlike options, the holder of a futures contract must exercise it at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include, but are not limited to, futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a specific commodity or underlying asset might move against the investor, requiring that the investor sell futures contracts at a loss. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss, and that past performance is not indicative of future results. Over time, assets will fluctuate in value, sometimes being worth more and sometimes less than the initial investment amount. Depending on the investment type, differing risk levels will exist. RMR cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, each client may view financial loss differently and may depend on many distinct risks, each affecting the probability and magnitude of potential losses. The following additional risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services. (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - The Adviser's investment activities involve significant risk. The performance of any investment is subject to numerous factors beyond RMR's control and beyond its predictive ability. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or deviate from expectations, adversely affecting a client's ability to realize profits or resulting in material losses. Client and RMR investment decisions will not always be profitable. Artificial Intelligence - We may leverage artificial intelligence ("AI") to enhance operational efficiency and improve client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment 29  advice. Instead, our AI applications primarily automate administrative and client service tasks, including meeting preparation, note-taking, CRM updates, task management, and the generation of meeting recap notes. We believe AI streamlines client engagement, reduces administrative burdens, and ultimately enhances the overall client experience. It is essential to recognize that AI models are inherently complex and that their outputs may be incomplete, inaccurate, or biased. While AI augments our operations, its use introduces risks, including inaccuracies, decision-making errors, and challenges in its effective deployment. Additionally, AI usage may pose risks to the confidentiality of client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information— such as material non-public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both client and proprietary information. We continuously evaluate the performance of AI technologies to ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance. Business Risk - The risks associated with a specific industry or company. Competition Risk - The securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and when preparing financial reports. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and a Code of Ethics, ensuring that the client's interests are always held above those of the firm and its associates. Credit Risk - Credit risk typically applies to debt investments, such as corporate, municipal, and sovereign fixed-income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment's originating country. Diversification Risk - A portfolio may not be sufficiently diversified across sectors, industries, geographic areas, security types, or issuers. These portfolios might be subject to more rapid changes in value than would be the case if the investment vehicles were required to maintain broad diversification across companies or industry groups. Equity Investment Risk - Generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease in value; the investment may incur a loss. Financial Risk - The possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders in the event of insolvency. Financial risk also refers to the possibility that a corporation or government will default on its bonds, resulting in bondholders losing money. Foreign/Non-U.S. Investments - From time to time, advisers may invest and trade a portion of client portfolios in non- U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, and enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may hold foreign currencies directly and purchase and sell them through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the US dollar's strength relative to these other currencies 30  may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may miss the benefits of favorable exchange rate movements. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - Investments in financial instruments such as forward contracts, options, commodities, and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in those positions' values or prevent losses if they decline, but rather establishes other positions designed to gain from the same developments, thus moderating the portfolio positions' decline in value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, such as losing your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you have to sell when markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state, and, therefore, are subject to transfer restrictions, and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - Leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements may require the pledging of additional collateral or the liquidation of account holdings, forcing the account to close positions at substantial losses not otherwise realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or using different leveraging strategies. Limited Partnerships Risk - A limited partnership is a financial arrangement with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business, has management authority, and is personally liable for the business's debts. And in the event of bankruptcy, it is responsible for all debts that remain unpaid or undischarged. The limited partners have no management authority and are liable only for their capital commitment. Profits are divided between general and limited partners according to an arrangement made at the partnership's creation. The range of risks depends on the nature of the partnership and is disclosed in the offering documents for privately placed offerings. Publicly traded limited partnerships share risk characteristics with equities. However, like privately placed limited partnerships, they are subject to a different tax regime than equities. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - Long-term trading is designed to capture returns and market rates. By its nature, the long- term investment strategy can expose clients to risks that typically surface at multiple points over time as they hold 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. Margin Risk - Securities purchased on margin in a client's account serve as the firm's collateral for the client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm 31  can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing advance written notice or the entitlement to an extension of time on the margin call. Market Risk - Market risk is the possibility that an investment's current market value will decline due to a general market decline, regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Market Timing Risk - The risk of market timing based on charting and technical analysis is that charts may not accurately predict future price movements. Current securities prices may reflect all information known about the security. Daily changes in market prices of securities may follow random patterns and be difficult to predict with high accuracy. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, using fundamental analysis may not yield favorable returns. The risk of cyclical analysis is that economic/business cycles may be unpredictable and exhibit significant fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty of predicting economic trends and, consequently, the changing value of securities affected by these trends. Material Non-Public Information Risk - Because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction it otherwise might have and may not be able to sell an investment it otherwise might have. Non-U.S.Investment Risk - Investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - An account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of comparable-sized investment entities. Private Investment Risk - Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors over a short period could require a fund to liquidate its securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting its investment strategy. Private Placement Risks - A private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended period, making them difficult to sell. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. 32  Public Information Accuracy Risk - An adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data, or seek independent corroboration when appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Recommendation of Particular Types of Securities Risk - We may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same kind of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - The risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - Occurs when investors lack the right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of a firm's key personnel, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not be able to find equally desirable replacements, and the accounts' performance could be adversely affected. Short-Sales Risk - Short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of an unlimited increase in the market price of the investment sold short, resulting in an inability to cover the short position and an unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - Securities of companies with small and medium market capitalizations are often more volatile and less liquid than those of larger companies. Small- and medium-cap companies may face a higher risk of business failure, thereby increasing the volatility of the client's portfolio. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially lower than those of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stock Risk - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health and the issuing of it. However, stock prices can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the issuing company's market sector, and the overall health of the market. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"). Still, the sheer size of an issuer is not, by itself, an indicator of the investment's safety. Stock Fund Risk - Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the greatest potential danger to investors in stock funds. Stock prices can fluctuate for various reasons, such as the overall strength of the economy and demand for products or services. Stock Market Risk - A stock's market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate in the short term due to factors affecting individual companies, industries, or the broader securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - Individual institutions may be restricted from directly using certain investment strategies that the Adviser may employ. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at 33  a predetermined rate, and the derivative component provides for the payment at maturity. Some products use a derivative component as a put option written by the investor, giving the buyer the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide a call option written by the investor, giving the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function that protects the principal if held to maturity. However, these products are not always insured by the Federal Deposit Insurance Corporation; the issuer may insure them, leaving the potential for principal loss in the event of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and other events that are difficult to predict. Supervision of Trading Operations Risk - An adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks -These are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - For all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions, thereby exposing the Adviser to potential losses. Turnover Risk - At times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would correspondingly increase brokerage commission expenses and may result in additional capital gains being distributed for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - Identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation, these investments involve significant financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - These are risks specific to a particular investment. Also known as "diversifiable risks," diversifying investments may, in theory, significantly reduce unsystematic risks. Warrant Risks - A warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, a warrant's lifetime is often measured in years, whereas a typical option's is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - An Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals over a short period could require a fund to liquidate its securities and other investments more rapidly than would otherwise be desirable, reducing the value of its assets and disrupting its investment strategy. RMR attempts to address the above risks by diversifying across multiple asset classes and strategies, creating distinct portfolio segments. Any security eligible for inclusion in a portfolio with low or no liquidity may be removed and replaced with the next- highest-ranked security in the same asset segment. Due to the fluctuating nature of security prices, the weighting of an individual security or sector in the portfolio may change after the portfolio is established. 34  RMR does not represent or guarantee that the services provided or any analysis methods provided can predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of future client account performance or any level of performance; the success of any investment decision or strategy used; overall account management; or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including those noted above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed, may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate widely, mirroring the overall stock and bond market. Before acting on RMR’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, and other financial Investment Professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable IAR. Voting Client Securities Proxy Voting RMR will not request or accept voting authority for client securities and is not obligated to forward proxy notices to the client or its agents. Clients will receive proxy material directly from the security issuer, their qualified custodian, or the Insurance Company and/or its approved Custodian(s). Clients are responsible for exercising their right to vote by proxy. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the Plan Fiduciary holds proxy voting authority and responsibility for the Plan account in accordance with the Plan's documentation. If the Investment Manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the Plan document. RMR may recommend and refer certain clients to third-party asset allocation or Managed account programs. Depending on the referred manager’s proxy voting policies and procedures - and as disclosed within the TPM’s Form ADV 2A and separate advisory contract, client participating in one of these programs may appoint the referred manager as their agent and attorney- in-fact with discretion to vote proxies for securities held in their account. Clients should carefully review the TPM’s disclosure brochures and advisory contract to understand the proxy voting policies and procedures of the referred manager. While RMR will assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because it supplies client information about a particular proxy vote in any of the above situations. The client must vote for their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. RMR has no duty or obligation to evaluate a client’s eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client’s account or securities issuers. RMR does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client’s account or the issuers of such securities. RMR is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client’s responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they 35  may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. For TPM investment accounts, depending on the TPM's proxy voting policies and procedures, the TPM may require that you appoint them as your agent and attorney-in-fact with discretion to vote proxies on your behalf. Please review the TPM's disclosure brochure carefully to understand their proxy voting policies and procedures. Item 7: Client Information Provided to Portfolio Managers ____________________________________________________________________________________________________ In addition to the personal data required to open an account, such as your name, address, birth date, Social Security number and employment information, we supply the IAR and/or Program Sponsor with information regarding your financial background and investment objectives to the extent such information is provided by you, at the time it is received from you, and when it is of benefit to the manager for performance of their responsibilities. We communicate changes in your policy to the IAR as they occur. Item 8: Client Contact with Portfolio Managers ____________________________________________________________________________________________________ There are no restrictions on clients contacting managers directly. Each Managed account is managed individually and separately from the accounts of other managed clients. You receive confirmations of each securities transaction placed by the manager for your account, as well as periodic custodian account statements and reports. There are no restrictions on a client’s ability to contact their IAR or us directly with any questions regarding their account. RMR, through its IARs, is available to the client on an ongoing basis to discuss client financial circumstances, the selected portfolio and the securities therein, or to process client instructions concerning advisory assets. Clients are encouraged to contact us directly with questions regarding their Wrap Fee Program account, investment objectives, changes in risk tolerance, or restrictions on managing their Wrap Fee Program assets. Item 9: Additional Information ____________________________________________________________________________________________________ Disciplinary Information Registered investment advisers are required to disclose all material facts concerning any legal or disciplinary events that may be relevant to a client’s or prospective client’s evaluation of the adviser or its management’s integrity. A state regulatory agency took disciplinary actions against certain members of RMR's management for violations of securities regulations, rules, and/or statutory provisions. These matters have since been resolved. For complete details on our disciplinary history and full disclosure documents, please visit the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov and search for our firm name or CRD #169005. Beyond these matters, neither the Adviser nor its management has any additional disciplinary or legal proceedings to disclose that would be material to a client’s evaluation of this advisory practice. RMR has no outstanding issues, and the firm, along with all Control Persons, is appropriately registered without restriction. You may also view information about any affiliated person who is registered or required to be registered as an Investment Adviser Representative of the firm by similarly searching their name or CRD # on the same IAPD website. Copies of this information can also be obtained by contacting us directly. Other Financial Industry Activities & Affiliations RMR is an independent registered investment advisory firm that provides investment advisory and other services indicated within this Form ADV 2A Disclosure brochure. The firm does not engage in business activities or offer services other than those described herein. Certain RMR Associates may sell additional products or provide services outside their roles with the Adviser, as indicated in their Form ADV 2B brochure Supplements and below. Broker-Dealer & Registered Representatives of a Broker-Dealer RMR is not registered and does not intend to register as a broker-dealer. From time to time, and in connection with their approved outside business activities, certain of RMR’s Associates may also be Registered Representatives (“RRs”) of non-affiliated broker-dealers, Members of FINRA and the SIPC. When acting in the capacity of RRs of such unaffiliated broker-dealers, these Associates will sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, variable annuities, or others to clients and receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. (See “Conflicts of Interest” at the end of 36  this section for additional important information.) Investment Advisor Representatives of Other Unaffiliated Investment Advisory Firms Certain RMR IARs are also registered IARs of other non-affiliated registered investment advisory firms. IARs who maintain outside business activities with such firms are required to provide the disclosure documents of the outside investment adviser’s disclosure brochures and documentation. RMR clients should understand that any assets they place under the management or within any other outside investment advisory firm’s programs are separate and distinct from their Agreement and assets managed by RMR. Further, a conflict of interest arises to the extent that, while the services offered by RMR and another unaffiliated adviser may be similar, clients' fees and other costs for those services may differ. RMR does not share any portion of the investment advisory fee a client will pay for another firm due to an RMR Associate’s outside business activity. Commissions or other compensation earned by our Associates in their capacities as employees of unaffiliated firms are separate and in addition to the advisory fees paid to RMR under our Agreements. (See “Conflicts of Interest” at the end of this section for additional important information.) Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither the Adviser nor any management persons are registered or intend to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an Associated Person of the preceding entities. Insurance Sales & Services Affiliated & Unaffiliated Insurance Agencies RMR Wealth Builders, Inc., the investment adviser, is affiliated with RMR Wealth Builders, Inc., a New Jersey Insurance Producer of a similar name (Insurance Producer License # 8729246). RMR’s insurance-licensed Investment Professionals will offer variable life, variable annuity, accident & health, sickness, and life or other insurance products from time to time and when appropriate to their RMR advisory clients in connection with their approved outside business activities for these products and recommend that advisory clients consider either insurance products or services. Insurance Company personnel also retain the discretion to introduce non-advisory clients to the investment adviser for advisory services. In this capacity, in addition to their compensation from RMR, insurance-licensed Investment Professionals can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of insurance products from the insurance agencies with whom they are presently or with whom they may become appointed in the future. The insurance commissions earned by these individuals are separate from and in addition to RMR’s advisory fees. Commissions are based on the insurance products provider's standard commission schedule and are generally not negotiable. This presents a conflict of interest since, to the extent that clients of the investment adviser can also use an Insurance Company’s services, the activities and fees of such companies are essential to understand. RMR Associates, licensed as Insurance Agents, are incentivized to effect suitable insurance transactions based on the potential for commission compensation received rather than the client’s best interests. Advisory clients should be aware that when using the services of any such insurance entity, such services are not provided by RMR, the SEC-registered investment adviser. Any insurance services offered are separate and distinct from the client's relationship, the Advisory Agreement, and the services provided by RMR (the investment adviser). The insurance commission paid to licensed Insurance Agents will be based on the standard commission schedule of the insurance products provider and is generally not negotiable. Insurance commissions are separate from RMR’s advisory fees. The services of companies other than the Adviser are also subject to separate and distinct contractual arrangements. Further, the protections afforded to clients under applicable investment advisory laws and regulations generally do not apply to those provided by any RMR affiliate or an unaffiliated company. Clients are under no contractual or other obligation to purchase insurance products through any person affiliated with the Adviser or to utilize the services of any affiliate or other industry relationship. Advisory clients maintain complete discretion regarding whether to use the services of RMR, RMR-affiliated entities, or other industry relationships that may be recommended. (See “Conflicts of Interest” at the end of this section for additional important information.) Designations & Other Outside Business Activities Our IARs can, with approval, operate their own independent companies outside of RMR. These unaffiliated companies include, among others, accounting and tax practices and insurance services. As such, there is a potential conflict of interest because 37  RMR’s Investment Professionals can earn compensation from RMR and the unrelated business activity. In addition, RMR Associates holds various other designations in connection with these approved outside business activities, separate from their role as IARs with RMR. RMR does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from RMR’s advisory services and fees. (See “Conflicts of Interest” at the end of this section for additional important information.) Recommendation of Other Advisers & Third-Party Money Managers RMR may allocate all or a portion of client assets to a third-party adviser or manager. RMR receives compensation from third- party referred managers and advisers that we recommend, and, in such instances, the fees may be shared between RMR and the third-party adviser or manager. Before selecting any outside manager, RMR will review the manager to ensure they fit the adviser’s models' criteria and conduct initial background due diligence. Referred managers must be registered with an appropriate regulatory body and enter RMR's Terms and Conditions Agreement before being included as a potential client referral. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which clients are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style - will be disclosed in each contract between the RMR, the third-party money managers, and the client. RMR reserves the right to add or delete managers as deemed necessary. These compensation arrangements create a conflict of interest because they give RMR a financial incentive to recommend the third party's services. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended referred managers. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access plan participants' accounts to offer advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to offer advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans for which RMR and its IARs are the advisors of record. Future Clients RMR may provide investment advisory services to other clients in the future. Other future clients may have investment objectives, programs, strategies, and positions that are similar to, or may conflict with, those of our current clients, or may compete with or have interests adverse to our current clients. This conflict could affect the prices and availability of financial instruments in which the current clients invest. However, there can be no assurance that future clients with similar investment objectives, programs, or strategies will hold the same positions or perform in substantially the same way as our current clients. Furthermore, our activities regarding future clients could conflict with those regarding our current clients. RMR may give advice or take action for the investments and transactions in one client account that may differ from the advice given or the timing or nature of action taken for financial instruments and transactions for other client accounts due to a variety of factors, such as regulatory and tax issues and differences in investment programs. As a result, even though our clients may share similar investment objectives and strategies, they may have substantially different portfolios and investment returns. Conflicts of interest may also arise when we make decisions on behalf of clients whose interests differ. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Other Business Relationships RMR uses third-party resources to help run its business and provide services to its clients, mostly back-office related. RMR sources these professionals, striving to act in a client’s best interest with fiduciary responsibility while focusing on finding the highest-value-added providers to serve clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise - neither RMR nor its Associates receive compensation for such use or referrals. 38  Conflicts of Interest The practice of making clients aware of the above other financial activities, affiliations, designations, and relationships, and the services discussed above, presents a conflict of interest since RMR’s Investment Professionals may have an economic incentive to submit advisory clients to certain companies or services over others due to potential compensation received in connection with the transaction. This can incentivize them to introduce their clients to professionals or services for their own compensation rather than for their clients' needs. Likewise, persons associated with the affiliated companies or outside relationships may refer their non-advisory clients to RMR. RMR addresses this conflict of interest by requiring Associates to always act in each client's best interests. Before the transaction, RMR’s Investment Professionals must fully disclose such relationships when making recommendations. If offering clients advice or products outside of RMR, they satisfy this obligation by advising and revealing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid/received before transaction execution. When acting in this capacity, RMR’s Investment Professionals are not acting on behalf of RMR, the investment adviser, concerning the client's services under an RMR Advisory Agreement. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. Further, they are not obligated to place the transaction through RMR if they elect to act on any recommendation received. The client may act on recommendations received by placing their business and securities transactions with any brokerage firm or third party. RMR makes no assurances that another entity's products or services are at the lowest available cost. Clients may obtain the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Additional details on how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance, supervisory policies and procedures, and Code of Ethics. RMR's Code is available for free review upon request to any client or prospective client. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Rule 204A-1 of the Advisers Act requires all investment advisors registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires compliance with federal securities laws. RMR takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Personnel who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing, and that it holds Associates to a very high standard of business practices and integrity. To that end, RMR has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. RMR strives to comply with applicable laws and regulations governing our practices. The adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all RMR Associates, including individuals registered with the adviser as IARs or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the CCO designates. RMR's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to fully comply with all applicable industry regulations and the firm’s guiding principles, as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates to abide by all state and federal securities laws and provisions relating to client information confidentiality, insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Associates are required to attest, no less than annually, to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every licensed IAR of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required. Additional details on how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance, supervisory policies and procedures, and Code of Ethics. 39  RMR's Code is available for free review upon request to any client or prospective client. An electronic copy of our Code of Ethics is also available for your review at www.rmrwealth.com. Participation or Interest in Client Transactions RMR and its Supervised Persons may buy or sell the same securities we recommend to clients or hold in client accounts. This practice creates a potential conflict of interest because associated persons could trade in these securities before or after client transactions and receive more favorable pricing. To mitigate this conflict, RMR’s policy prohibits the firm and its personnel from having priority over client accounts. When the same or similar securities are traded, client transactions are executed first, and the firm monitors same‑day trading to ensure that clients receive execution prices equal to or better than those obtained by the advisor. All transactions that may give rise to a conflict are documented and reviewed in accordance with firm procedures. RMR also serves as the sub‑adviser to the publicly traded PeakShares RMR Prime Equity ETF (“PRMR”) and may invest client assets in PRMR when appropriate. Purchases of PRMR by related people are executed through a model account managed by RMR and are subject to the firm’s pre‑clearance procedures, unless a documented exception applies. In addition, RMR prohibits the firm and its Associates from sharing in the profits or losses of any securities transactions executed for client accounts. Personal Trading Practices RMR recognizes that personal investment transactions by its members and Associates require adherence to a high ethical standard and must never compromise a client’s interests. When clients' and the firm's personnel have similar investment objectives, it is reasonable for them to invest in some of the same securities. However, all such activity must occur in a manner that protects clients and complies with RMR’s Code of Ethics. RMR’s Code includes a Personal Securities Transactions & Trading Policy that establishes requirements for personal trading, including pre‑clearance of certain transactions and ongoing reporting designed to monitor compliance. The Code also contains policies and procedures addressing insider‑trading prohibitions, other personal securities transactions, and the safeguards expected of all Associates. Upon employment or affiliation—and annually thereafter—Associates must acknowledge in writing that they have read, understand, and agree to comply with the Code. Associates must also affirm that they will conduct business honestly, ethically, and fairly, avoiding any conduct or circumstances that could impair, or appear to impair, their duty of loyalty to clients. RMR strictly prohibits insider trading and has adopted comprehensive policies and procedures to ensure compliance with federal and state securities laws. Associates receive guidance on the handling of material non‑public information and are prohibited from benefiting from the short‑term market effects of client recommendations. While Associates may buy or sell securities for their personal accounts when consistent with the Code of Ethics, client interests always take precedence, and such transactions may not disadvantage any advisory client. Conflicts of Interest RMR’s policies prohibit the firm, its Associates, and any related persons from engaging in trading activity that is detrimental to clients or inconsistent with the firm’s written supervisory procedures, Code of Ethics, or applicable securities regulations, including all prohibitions on personal and insider trading. Associates must disclose, pre‑clear, and report certain personal securities transactions and maintain all required records to ensure that no Associate receives preferential treatment or otherwise affects the markets to the detriment of clients. To reinforce adherence to these requirements, RMR conducts Access Person trade reviews on a quarterly, annual, and as‑needed basis to verify compliance with the firm’s policies and to confirm that no conflicts of interest have occurred. Potential conflicts and any trades requiring review are documented and monitored in accordance with firm procedures. Additional information regarding RMR’s conflict‑mitigation practices is available in the firm’s comprehensive written compliance supervisory policies and procedures and its Code of Ethics. A copy of the Code is available to any client or prospective client upon request, free of charge. 40  Review of Accounts Initial client Agreements are reviewed and approved by the Director of Compliance & Operations, their Designee, or another firm Principal, as appropriate. Designated Supervisors will also periodically review ongoing client account transactions and oversee IAR annual account review obligations. All portfolio management accounts are monitored annually or more frequently as agreed upon with the client. Client Reports: Content & Frequency Firm Statements & Reports RMR client communications occur at several levels. Client meetings will generally be held annually to review the client’s account and determine the appropriateness of its holdings. Meetings, telephone calls, emails, and letters will provide information from time to time as circumstances warrant. Market commentaries, articles, and newsletters on investment and financial planning topics can also be provided to all clients throughout the year. While the client will not receive additional reviews, statements, and reports outside of those required under Rule 206(4)-2 of the Advisers Act or beyond the services contracted for in the client’s Agreement, additional reporting may be made available on an ad-hoc basis as agreed to between RMR and the client. Custodial Statements & Reports At the time of account inception, client will direct their qualified custodian to send them statements at least quarterly, (1) reflecting all account transactions that occurred during the previous reporting period, the funds, securities, and other property in the account at the end of the period, and (2) provide RMR duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. The client’s qualified custodian will then provide quarterly account statements describing all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the beginning and ending. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. The client may also receive trade confirmation documents from their custodian for each buy or sell transaction in their account. Client statements will be sent to the address provided by the client to RMR or such other address to which the client may request in writing that they be sent. RMR urges the client to promptly review any statements they receive from their custodian upon receipt to ensure the accuracy of account transactions. Clients should also compare their account(s)' investment performance against the appropriate blended benchmark applicable to the type of investments held in the account, and against any periodic report or information they receive from us. The information obtained from RMR may differ from custodial statements due to accounting procedures, reporting dates, or the valuation methodology of particular securities. RMR encourages clients to ask us questions about their assets' custody, safety, or security, or about any statements received. Clients may request a verbal or written report at any time. If a client believes there are any inaccuracies or discrepancies in any reports received, or if they do not understand the information reflected in any document received, they should promptly, and in all cases before the next statement cycle, report their concerns to RMR. Unless the client indicates otherwise, by promptly notifying us in writing of concerns regarding statements received or specific investment restrictions on the account(s), investments made in line with the client’s stated investment objectives, RMR recommends or makes on behalf of a client shall be deemed to conform with the client’s investment objectives. Client Referrals & Other Compensation Preferred Qualified Custodian RMR receives an economic benefit from our preferred qualified custodian through the support products and services available to us and to other independent investment advisers who also recommend that their clients maintain accounts with them. Because of such arrangements, we benefit from referrals, as the cost of these services would otherwise be borne directly by our firm. While clients do not pay more for assets maintained at our preferred qualified custodian, clients should consider these conflicts - the products and services provided by each custodian, their benefits to us, and any related conflicts of interest described herein, when making a custodian selection. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account custodian.) Economic Benefits Provided by Third Parties Custodians and certain mutual funds participate in activities designed to help facilitate the distribution of their products by providing RMR’s Investment Professionals with sales awards and other prizes, instruction about their products, and through 41  marketing activities or instructive programs, including, but not limited to, fund representative conference attendance, one-on- one marketing efforts, and/or due diligence presentations. When RMR participates in these activities, the Adviser receives additional compensation, such as 12b-1 fees disclosed in a fund’s prospectus fee table and expense reimbursements. These payments are generally made from the fund's or a fund affiliate’s assets. Therefore, certain expenses not paid out of fund assets would not appear in a fund’s expense table. No portion of these payments to RMR or an IAR is made using brokerage commissions generated by the fund. It is important to understand that no payments other than 12b-1 fees received by RMR are paid or directed to any IAR recommending these funds. RMR IARs do not receive a higher or lower percentage of the commission on mutual fund sales. You should be aware that different funds charge different commissions. Because RMR IARs receive no direct increase or change in the percent of commissions they are paid for selling shares of one fund over another, we do not believe that they are subject to a conflict of interest based on the percent of commission each IAR receives when recommending one fund’s shares over another’s. However, marketing and educational activities funded by a fund could lead our IARs to focus more on that fund. Promoter Relationships RMR reserves the right to engage compensated solicitors (“Promoters”) to refer prospective clients to the Adviser. When Promoters are used, they act as independent contractors and not as employees, representatives, or agents of RMR. Promoters may receive compensation in the form of either a flat fee or a percentage of the advisory fees earned from the accounts they refer, as outlined in a written agreement between RMR and the Promoter. This compensation creates a material conflict of interest, because Promoters have a financial incentive to recommend RMR’s services. Promoters who work with multiple advisers may also be incentivized to recommend advisers offering more favorable compensation. RMR conducts due diligence to reasonably confirm that any Promoter is not an “ineligible person” under Rule 206(4)-1 and is properly licensed or qualified where required. Unlicensed Promoters are limited to providing impersonal recommendations of RMR’s services and may not make statements regarding specific advice, portfolio construction, or the appropriateness of services for any individual. RMR also oversees its activities in accordance with regulatory requirements. To mitigate these conflicts, RMR requires Promoters to provide referred prospects, at the time of solicitation, with written disclosures that include whether the Promoter is a client or non‑client of RMR, that the Promoter is compensated for the referral, the material conflicts of interest arising from the relationship and compensation structure, and the material terms of the Promoter agreement, including a description of any compensation received. The Promoter will use its best efforts to solicit and refer to RMR those individuals or entities that it believes are in the client's best interests to be introduced to the investment advisory services we provide. Promoter services typically include introducing prospective clients to RMR and providing general information about the Adviser. In certain cases, Promoters may assist with updating client information or facilitating communications. Promoters must maintain the confidentiality of client information and may not disclose such information without proper consent. Promoters have no authority to accept clients on behalf of RMR, and RMR retains sole discretion to accept or decline any prospective client referred by a Promoter. Clients referred by Promoters do not pay higher advisory fees as a result of these arrangements. Required disclosures regarding the Promoter’s compensation, conflicts of interest, and relationship with RMR will be provided to each solicited client at the time of solicitation, consistent with the SEC’s Marketing Rule. As of the date of this brochure, RMR is not actively engaged in any Promoter arrangements. Third‑Party Referral Program RMR may refer clients to the KEEP® Program, sponsored by StoneCastle Cash Management, LLC, and may receive a referral fee from StoneCastle when clients participate. RMR complies with similar requirements as those listed in the Promoter Relationship section when acting as a compensated Promoter for the KEEP® Program sponsored by StoneCastle Cash Management, LLC. (Additional information regarding this program and related conflicts is provided in Item 8: Methods of Analysis, Investment Strategies & Risk of Loss.) Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the Promoter's referral. Additionally, Promoters who refer business to more than one investment adviser may be financially incentivized to recommend advisers with more favorable compensation arrangements; comparable services and/or lower fees may be available from other firms. Accordingly, 42  RMR requires its Promoters to disclose to referred client, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. RMR satisfies similar requirements when serving as a StoneCastle Cash Management, LLC Promoter Sub‑Advisory Services RMR receives economic benefits in connection with its sub‑advisory relationships with registered investment companies, including revenue‑sharing and expense‑sharing arrangements pursuant to its agreements with fund advisers. These benefits are not paid directly by advisory clients. These arrangements create conflicts of interest because RMR may have financial incentives to increase or maintain assets in sponsored funds or in products associated with the adviser. RMR has adopted policies and procedures, including its Code of Ethics and conflict‑management processes, to identify, disclose, and manage these conflicts in a manner consistent with its fiduciary obligations under the Advisers Act. (Please see Form ADV 2A for additional details on this advisory service.) Conflicts of Interest Except for advisory fees paid by clients and the compensation arrangements described in this brochure, RMR does not receive additional economic benefits. Additional information on how we mitigate conflicts of interest can be found in our comprehensive written compliance supervisory policies and procedures and Code of Ethics. A copy of RMR’s Code of Ethics is available to clients and prospective clients for review upon request at no cost. Financial Information Balance Sheet Requirement RMR does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair the Adviser’s Ability to Meet Contractual Commitments Neither RMR nor its management has any financial condition that is reasonably likely to impair the firm’s ability to meet its contractual commitments to clients. RMR has been the subject of an administrative order issued by a state securities regulator, resulting in an administrative penalty exceeding $2,500. The matter did not involve allegations of client harm, misappropriation, or fraud, and the penalty does not impair RMR’s ability to meet its contractual obligations to clients. Other than as disclosed above, RMR and its management have not been the subject of any award or been found liable in an arbitration claim or civil, self‑regulatory organization, or administrative proceeding involving allegations of fraud, false statements or omissions, theft, embezzlement, or other dishonest, unfair, or unethical practices. Bankruptcy Disclosure RMR has no financial impairment that will preclude it from meeting contractual client commitments. Neither RMR nor any of its management persons has been the subject of a bankruptcy petition in the past ten (10) years. Disciplinary Disclosures Certain of RMR's financial professionals have legal or disciplinary histories that require disclosure. Please visit the SEC’s website at www.adviserinfo.sec.gov for a free and simple search tool to research RMR and its IARs, Management Members, Officers, and firm Principals. 43