ROLLINS FINANCIAL ADVISORS, LLC

Item 1 – Cover Page Rollins Financial Advisors, LLC 3343 Peachtree Road NE, Suite 500 Atlanta, Georgia 30326 404-892-7967 www.rollinsfinancial.com July 2025 This Brochure provides information about the qualifications and business practices of Rollins Financial Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at 404-892-7967 or at contact@rollinsfinancial.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Rollins Financial Advisors, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about Rollins Financial Advisors, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Following is a summary of material changes since our last update on March 18, 2025:  Item 4 – Added DOL Fiduciary disclosure language.  Item 12 – Added description of trade error correction process at Fidelity. A current version of our Brochure may be obtained free of charge by contacting Eddie Wilcox at 404-892-7967 or ewilcox@rollinsfinancial.com. ii  Item 3 -Table of Contents Item 1 – Cover Page ............................................................................................................................................... i Item 2 – Material Changes ................................................................................................................................. ii Item 4 – Advisory Business ............................................................................................................................... 1 Item 5 – Fees and Compensation .................................................................................................................... 3 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................... 4 Item 7 – Types of Clients .................................................................................................................................... 4 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 4 Item 9 – Disciplinary Information .................................................................................................................. 7 Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 7 Item 11 – Code of Ethics ..................................................................................................................................... 8 Item 12 – Brokerage Practices ......................................................................................................................... 9 Item 13 – Review of Accounts ....................................................................................................................... 11 Item 14 – Client Referrals and Other Compensation ........................................................................... 11 Item 15 – Custody .............................................................................................................................................. 13 Item 16 – Investment Discretion ................................................................................................................. 13 Item 17 – Voting Client Securities ............................................................................................................... 14 Item 18 – Financial Information ................................................................................................................... 15 iii  Item 4 – Advisory Business Rollins Financial Advisors, LLC (hereinafter, “RF”) seeks to provide investment advice that will meet individual client goals under a fee only system, taking the utmost care to enhance each client’s financial position over the long term. RF acquired the investment advisory business of Rollins Financial, Inc. which was founded in 1990. Focus Financial Partners RF is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, RF is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because RF is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of RF. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. RF is managed by Joseph R. Rollins, Robert E. Schultz III, Danielle Van Lear Schultz, and Edward J. Wilcox (“RF Principals”), pursuant to a management agreement between RF Partners, LLC and RF. The RF Principals serve as leaders and officers of RF and are responsible for the management, supervision, and oversight of RF. Types of Advisory Services RF provides individual investment counseling and supervisory services, along with commentaries on market performance and estimates for future trends. RF initially meets with each client to determine the client’s financial objectives and other relevant factors that should be considered in building the investment portfolio. Taking the information gleaned from the initial meeting, and after further study of the client’s overall circumstances, RF will: analyze existing assets, including allocation among asset classes; develop an asset allocation plan for each client portfolio; and select equity and/or fixed income securities designated to 1  assist the client in reaching his or her stated goals and objectives. Clients can instruct RF to follow client directed investment restrictions or guidelines. RF most often invests client assets in various mutual funds or exchange-traded funds. RF does not currently typically recommend bonds, variable annuities or real estate partnerships, but reviews and advises on existing client holdings in these instruments. If a given situation warrants, RF will invest client funds in individual domestic or foreign common stocks, preferred stocks, or certificates of deposit. Once the portfolio is constructed, RF monitors the investments, their performance, and overall progress toward the stated goals of the client on an ongoing basis. In addition to the foregoing, RF provides general accounting and tax services. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). RF is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. RF is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, RF is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). When Rollins provides investment advice to you regarding your retirement plan account or individual retirement account, Rollins is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Rollins makes money creates some conflicts with your interests, so Rollins operates under a special rule that requires Rollins to act in your best interest and not put our interest ahead of yours. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a 2  wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. As of December 31, 2024, RF manages total discretionary assets of $1,382,588,015. Item 5 – Fees and Compensation For our services, we charge a percentage of a client’s assets under our management, generally determined in accordance with the following annual fee schedule: Assets $0 - $50,000 $50,001 - $100,000 $100,001 - $1,000,000 $1,000,001 - $3,000,000 over $3,000,000 Rate* 1.50% 1.25% 1.00% 0.75% 0.50% *Specified rate applies only to assets in that tier. A minimum portfolio size and minimum annual fees may apply, at the discretion of RF. However, under certain circumstances, portfolio size minimums and fees are negotiable. Unless stated otherwise, it is RF’s policy is to include all related client accounts, specifically the accounts of direct family members sharing the same residence address, for purposes of determining a client’s market value of assets. The specific manner in which fees are charged by RF is established in a client’s written agreement with RF. RF will generally bill its fees on a quarterly basis in arrears each calendar quarter. Clients may also elect to be billed directly for fees or to authorize RF to directly debit fees from client accounts. Management fees shall be calculated based on the average daily balance which aggregates the daily ending market values for a selected quarter and divides that aggregate market value number by the number of days in the quarter. Fees for partial quarters will be prorated. Cash, margined securities, and accrued interest will be included for billing purposes unless we determine otherwise, in our sole discretion. RF’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients will incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, short-term redemption fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such 3  charges, fees, and commissions are exclusive of and in addition to RF’s fee. RF does not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that RF considers in selecting or recommending broker- dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. FRS does not receive any compensation from the Brokers or any other third parties for serving our clients. Additionally, in exchange for allowing certain of the Brokers to offer their services to clients of other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue and no portion of the Platform Fees is attributable to our clients’ use of the Brokers’ services. Further information on this service is available in Item 10 of this Brochure. Item 6 – Performance-Based Fees and Side-By-Side Management RF does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or engage in side-by-side management. Item 7 – Types of Clients RF provides portfolio management services to individuals, high net worth individuals, and corporate pension and profit-sharing plans. RF requires a minimum account size of $250,000 in order for you to open/maintain an account or establish a relationship. However, we may reduce our minimum relationship size based upon certain criteria (i.e. additional assets, anticipated future earning capacity, related accounts, or negotiations with the client). Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss To achieve the specific goals of each client account, RF directs client assets to be invested in stock funds, fixed income (bond) funds, individual stocks, individual bonds, individual cash 4  equivalent securities, commodity funds, real estate funds and alternative asset funds. RF directs investments towards domestic investments, or international investments, depending on market conditions. RF will also make judgments with regard to allocations towards large, medium, and small-cap securities. In addition, analysis will be made regarding the types of fixed-income investments that are appropriate given market conditions with regard to each client’s situation. Investing in securities involves risk of loss that clients should be prepared to bear. The likelihood of loss may be greater if you invest for a shorter time period. Principal risks include the following: market and selection risk, investment style risk, small and mid-cap risk, credit risk, foreign investment risk, commodity risk, interest rate risk, derivatives risk, cybersecurity risk, and COVID-19 Outbreak and Other Public Health Risks. Market and Selection Risk. Market risk is the risk that markets will go down in value. These changes may be sharp and unpredictable. The financial problems in global economies over the past several years may continue to cause high volatility in global financial markets, including in the U.S. Selection risk is the risk that the investments that our portfolio managers select will underperform the market or strategies managed by other investment managers with similar investment objectives and investment strategies. Investment Style Risk. The risk that returns from a particular investment style (e.g., growth stocks vs. value stocks) will trail returns from the overall stock market. Small and Mid-Cap Risk. Small and mid-cap companies are generally more vulnerable to adverse business or economic developments than larger companies. They may also be less liquid and more volatile than securities of larger companies or the market averages in general. Credit Risk. The risk that the issuer of a security, or the counterparty to a contract, will default or otherwise become unable to honor a financial obligation. Credit risk is generally higher for non-investment grade securities. The price of a security can be adversely affected prior to actual default as its credit status deteriorates and the probability of default rises. Foreign Investment Risk. Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. One or more of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. 5  Commodity Risk. Exposure to the commodities markets may subject commodity portfolios to greater volatility than investments in traditional securities, particularly if the investments involve leverage. Interest Rate Risk. The risk that debt prices overall will decline over short or even long periods due to rising interest rates. A rise in rates typically causes a fall in bond values, while a fall in rates typically causes a rise in bond values. Derivatives Risk. The risk of investing in derivatives include liquidity, interest rate, market, credit, and management risks, mispricing or improper valuation. Changes in the value of a derivative may not correlate with the underlying asset, rate, or index, and you could lose more than the principal amount invested. Cybersecurity Risk. The computer systems, networks, and devices used by RF and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. Clients could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. 6  Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of RF or the integrity of RF’s management. RF has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Focus Financial Partners As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because RF is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of RF. Focus Risk Solutions We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC (“Focus”). FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. Neither we nor FRS receives any compensation from the Brokers or any other third parties for providing insurance solutions to our clients. For services provided by FRS to clients of other Focus firms, FRS receives a percentage of the upfront commission or a percentage of the ongoing premiums for policies successfully placed with insurance carriers on behalf of referred clients. Additionally, in exchange for allowing certain of the Brokers to offer their services to clients of other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue and no portion of the Platform Fees is attributable to our clients’ use of the Brokers’ services. Such compensation to FRS, including the Platform Fees, is also revenue for our common parent company, Focus. However, this compensation to FRS does not come from insurance solutions provided to any of our clients. The volume generated by our clients’ transactions does benefit FRS and Focus in attracting, retaining, and negotiating with the Brokers and insurance carriers. We mitigate this conflict by: (1) fully and fairly 7  disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any portion of the Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries that provide services to our clients. The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy. The final rate may be higher or lower than the prevailing market rate. We can offer no assurances that the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace. Item 11 – Code of Ethics RF has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at RF must acknowledge the terms of the Code of Ethics annually, or as amended. RF anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which RF has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which RF, its affiliates and/or clients, directly or indirectly, have a position of interest. RF’s employees and persons associated with RF are required to follow RF’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees of RF and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for RF’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of RF will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of RF’s clients. The Code requires employees to pre-clear transactions in private placements, IPOs and securities of issuers where clients are insiders, and restricts trading in close proximity to client trading activity. 8  Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between RF and its clients. All trading activities of officers and employees are reviewed by RF on a quarterly basis to monitor compliance with the Code of Ethics. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with RF’s obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. RF will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. RF’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Eddie Wilcox. It is RF’s policy that the firm will not effect any principal or agency cross securities transactions for client accounts. RF will also not cross trades between client accounts. Trade errors are generally corrected through using a “trade error” account, or similar account, at the client’s custodian. Gains and losses resulting from trade errors settled in the error account at Fidelity are netted and reset at the end of each quarter. RF is responsible for covering any losses in the error account, while gains are “donated” and not kept by RF. Conflicts of interest in maintaining a trade correction account are mitigated by RF’s procedures designed to identify and resolve trade errors promptly, and the requirement that Fidelity approve the trade error correction. Item 12 – Brokerage Practices RF considers the following factors in selecting or recommending brokerage firms for your transactions and in determining the reasonableness of the compensation or other remuneration paid to the brokerage forms: quality of services provided, implementation costs, value of research and other information provided, confidentiality of trading intentions, investment styles (compatibility between RF and the brokerage firm), trade error resolution process, ability to execute difficult trades. 9  RF has established a Best Execution committee which periodically reviews our brokerage practices and the reasonableness of compensation or other remuneration paid to brokerage firms and monitors our efforts to seek best execution of client transactions. Most investments made on behalf of client accounts are mutual funds; therefore, RF does not have the ability to select the broker to execute the transaction. When individual securities are selected for client accounts, the account custodian will generally execute the transaction. All clients will have the opportunity to select the custodian and/or broker dealer of choice; however, clients in need of custodial services will generally have Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Investments, Inc. (“Fidelity”) recommended to them. If clients select a custodian other than Schwab or Fidelity, RF may not have the opportunity to negotiate commissions paid by the client, and RF’s ability to obtain best execution may be impaired. RF participates in the Institutional programs of Charles Schwab & Co., Inc. and Fidelity Investments, Inc., both FINRA members and registered broker-dealers. These service programs are offered to independent investment advisers by the broker/dealers. As a participant in the programs, RF receives some benefits. RF does receive some benefits by its participation in the institutional programs of Charles Schwab & Co. and Fidelity Investments, although there is no direct link between the investment advice given and participation in the program. These benefits usually include: receipt of duplicate client confirmations and bundled duplicate statements; access to market and economic research reports; access to a service team and trading desk serving adviser participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; access to an electronic communications network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. The benefits received through participation in the program do not depend upon the proportion of transactions directed to these broker-dealers (e.g., they are not “soft dollars”). When given discretion to do so, RF will endeavor to select those brokers or dealers which provide the best services at the lowest commission rates possible. The reasonableness of commission is based on the broker’s ability to provide professional services, competitive commission rates, research, and other services which will help RF in providing investment advisory services to clients. RF may recommend (or use) the use of a broker-dealer who provides useful research and securities transaction services even though a lower commission may be charged by a different broker-dealer, who offers no research services and minimal securities transaction assistance. Research services are useful in servicing all of 10  RF’s clients, but not all such research may be useful for the account for which the particular transaction was effected. Item 13 – Review of Accounts All accounts are reviewed in detail at least quarterly by RF, but interim reviews are triggered by a number of factors. These factors include but are not limited to the following: change in general circumstances, change in personal expense levels, changes in marital status, retirement, economic developments, political changes, market conditions, etc. In addition, RF evaluates the investment philosophy of the firm on an ongoing basis and performs economic analysis for all accounts. The reviewers include Joseph R. Rollins, President/CEO, Robert E. Schultz, III, Chief Operations Officer and Edward J. Wilcox, Chief Compliance Officer. Account custodians are responsible for providing monthly or quarterly account statements which reflect the positions (and current pricing) in each account as well as transactions in each account, including fees paid from an account. Account custodians also provide prompt confirmations of all trading activity, and year-end tax statements, such as 1099 forms. In addition, RF provides a quarterly report for each client. This report includes a summary of portfolio holdings, gains, and losses for the period, interest, and dividends earned, contributions and withdrawals for the period, investment management fees charged, and a performance review. Additional reports are available upon request. Item 14 – Client Referrals and Other Compensation RF has arrangements in place with certain third parties, called promoters, under which such promoters refer clients to us in exchange for a percentage of the advisory fees we collect from such referred clients. Such compensation creates an incentive for the promoters to refer clients to us, which is a conflict of interest for the promoters. Rule 206(4)-1 of the Advisers Act addresses this conflict of interest by, among other things, requiring disclosure of whether the promoter is a client or a non-client and a description of the material conflicts of interest and material terms of the compensation arrangement with the promoter. Accordingly, we require promoters to disclose to referred clients, in writing: whether the promoter is a client or a non-client; that the promoter will be compensated for the referral; the material conflicts of interest arising from the relationship and/or compensation arrangement; and the material terms of the compensation arrangement, including a description of the compensation to be provided for the referral. 11  In addition, RF compensates its employees, including our portfolio managers, who refer potential clients to us for our services. Thus, the employee will have a financial interest in the selection of RF by the client for investment management services. RF’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus holds partnership meetings and other industry and best practices conferences, which typically include RF, other Focus Partners, and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus Partners, including RF. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus Partners, including RF. Although the participation of Focus Partner personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause RF to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including RF. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2024 to February 1, 2025: • Advent Software, Inc. (includes SS&C) • BlackRock, Inc. • Blackstone Administrative Services Partnership L.P. • Capital Integration Systems LLC (CAIS) • Charles Schwab & Co., Inc. • Confluence Technologies Inc. • Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) • Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity Institutional Asset Management and FIAM) • Flourish Financial LLC • Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) • K&L Gates LLP • Nuveen Securities, LLC • Orion Advisor Technology, LLC • Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions) • Practifi, Inc. • • Salus GRC, LLC Stone Ridge Asset Management LLC 12  • The Vanguard Group, Inc. • TriState Capital Bank • UPTIQ, Inc. You can access a more recently updated list of recent conference sponsors on Focus’ website through the following link: https://focusfinancialpartners.com/conference-sponsors/ Item 15 – Custody Pursuant to Rule 206(4)-2 of the Advisers Act, RF is deemed to have custody of certain client funds because the Firm has the authority and ability to debit its fees directly from clients’ accounts. To mitigate any potential conflicts of interests, all RF client account assets will be maintained with an independent qualified custodian. RF currently recommends that its investment management clients use Schwab and Fidelity for custodial services. In addition, pursuant to that Rule, RF is deemed to have custody of certain client funds in those situations where a client provides RF with authority pursuant to a third party standing letter of authorization (“SLOA”). Any SLOA is implemented pursuant to the instruction of the client, the procedures of the independent qualified custodian and applicable regulatory requirements – including the seven conditions which must be met under the Custody Rule in order for RF to not be subject to the surprise custody asset examination. Clients should receive at least quarterly statements from the broker-dealer, bank, or other qualified custodian that holds and maintains client’s investment assets. RF urges you to carefully review such statements and compare such official custodial records to the account statements that we provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion RF usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, RF observes the investment policies, limitations and restrictions of the clients for which it advises. For registered investment companies, RF’s authority to trade securities may also be limited by certain federal securities 13  and tax laws that require diversification of investments and favor the holding of investments once made. Investment guidelines and restrictions must be provided to RF in writing. Item 17 – Voting Client Securities Rollins Financial has adopted policies and procedures that require it to evaluate and vote proxy issues in the best interests of its clients. RF has determined that it is in the best interests of its clients to vote proxies in a manner that furthers the economic interest of its clients with the objective of maximizing the ultimate economic value of the investment. RF’s policy requires that the firm vote proxies on behalf of all of its discretionary clients in a prudent manner considering the prevailing circumstances. Rollins Financial has engaged a third-party, independent proxy voting service (the “Proxy Voter”), as its independent proxy voting service to provide RF with proxy voting recommendations, as well as to handle the administrative mechanics of proxy voting. RF has directed the Proxy Voter to utilize its proxy voting guidelines in making recommendations to vote. Rollins Financial has adopted specific procedures that address proxy voting responsibilities, material conflicts of interest, if any, record keeping and disclosure requirements. RF will generally vote proxies in accordance with the following guidelines: (i) when RF’s view of the issuer’s management is favorable, RF will generally support current management initiatives, subject to the exceptions noted below; and (ii) When RF’s view is that changes to the management structure would probably decrease shareholder value, RF will generally not support management initiatives. Where there is a clear conflict between management and shareholder interests, RF may ele ct to vote against management. In general, RF opposes proposals that in its view act to entrench management. In some instances, even though RF may support management, there are some corporate governance issues that, in spite of management objections, RF believes should be subject to shareholder approval. Furthermore, as part of RF’s policy, the firm may abstain from voting a proxy when it is determined that the cost of voting the proxy exceeds the expected benefit to the client. There may be occasions where the voting of proxies may present an actual or perceived conflict of interest between RF and its clients. RF will not vote proxies contrary to the best interest of its clients due to business or personal relationships with an issuer’s management, participants in proxy contests, corporate directors or candidates for corporate directorships, or where RF or an employee may have a personal interest in the outcome of a particular matter before shareholders. When there exists an actual or potential conflict of 14  interest, RF addresses these conflicts or appearances of conflicts by ensuring that proxies are voted in accordance with the recommendations made by the Proxy Voter. In addition, clients may authorize RF to appoint the various independent managers to vote proxies for securities held in the client's account with such manager. RF will vote proxies in accordance with the instructions of the investment manager(s) for securities held in the client's account with the manager or under such manager’s model, provided that the instructions are timely received by RF. If the manager’s instructions are not timely received, RF shall vote the proxies for these securities, as well as proxies for any other securities held in the client’s account, in accordance with the recommendations provided by the Proxy Voter. All investment managers selected by RF have adopted and implemented written policies and procedures. RF will obtain and make available to the client the voting record of each investment manager with respect to the client’s account upon receipt of a written request from such client. In addition, clients may obtain information on how proxies were voted for such client and request a copy of RF’s proxy voting policies and procedures by contacting our offices at (404) 892-7967. Item 18 – Financial Information We are required in this Item to provide you certain financial information or disclosures about RF’s financial condition. RF does not solicit fees of more than $1,200 per client, six months or more in advance. RF has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy petition. 15