Rossjohnson & Associates, LLC

Form ADV Part 2A – Firm Brochure This brochure provides information about the qualifications and business practices of ROSS\JOHNSON & Associates, LLC. If you have any questions about the contents of this brochure, please contact us at (763) 560-2127 or by email at: RJAInfo@rossjohnsonweb.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. ROSS\JOHNSON & Associates, LLC is registered as an Investment Adviser with the Securities and Exchange Commission. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about ROSS\JOHNSON & Associates, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ROSS\JOHNSON & Associates, LLC’s CRD number is: 297583. 3380 Annapolis Ln N Ste. B-100 Plymouth, MN 55447 (763) 560-2127 RJAInfo@rossjohnsonweb.com www.rossjohnsonweb.com Version Date: 3/31/2026 i  Item 2: Material Changes The last annual update of the Form ADV Part 2A – Firm Brochure for ROSS\JOHNSON & Associates, LLC was on 1/31/2025. Material changes discussed here relate to the policies, practices, or to the conflicts of interests of ROSS\JOHNSON & Associates, LLC that have been revised since the last annual update of our Firm Brochure. This update includes the following material changes: • The Firm has added Tax Preparation Services (“TPS”) for certain clients under a separate engagement letter and fee arrangement. TPS is a non-investment advisory service and is not included in the Firm’s investment advisory fee. • The Firm Brochure has been updated to describe TPS, including service scope, fees, limitations, conflicts of interest, and privacy and cybersecurity practices applicable to tax- related information. Additional non-material updates have been made: (i) Item 4 to clarify our use of SEI’s wrap fee program and our non-sponsorship status; (ii) Item 10 and 14 to enhance the disclosures of conflicts related to insurance sales and tax preparation; (iii) Item 15 to clarify that RJA is deemed to have custody solely due to its authority to deduct its fee from client custodial accounts and, where applicable, the use of standing letters of authorization (SLOAs) by its clients. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................... ii Item 3: Table of Contents ......................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................... 1 Item 5: Fees and Compensation ............................................................................................................... 3 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................... 5 Item 7: Types of Clients ............................................................................................................................. 5 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................. 6 Item 9: Disciplinary Information ............................................................................................................. 9 Item 10: Other Financial Industry Activities and Affiliations ............................................................. 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 10 Item 12: Brokerage Practices ................................................................................................................... 11 Item 13: Review of Accounts .................................................................................................................. 12 Item 14: Client Referrals and Other Compensation ............................................................................ 12 Item 15: Custody ...................................................................................................................................... 13 Item 16: Investment Discretion .............................................................................................................. 13 Item 17: Voting Client Securities (Proxy Voting) ................................................................................ 13 Item 18: Financial Information ............................................................................................................... 14 iii  Item 4: Advisory Business A. Description of the Advisory Firm ROSS\JOHNSON & Associates, LLC (hereinafter “RJA”) is a Limited Liability Company organized in the State of Minnesota. The firm was formed in June 1998, and the principal owner is Patrick Ross. RJA is registered as an Investment Adviser with the Securities and Exchange Commission. RJA filed its initial application to become registered as an investment adviser in July 2018. B. Services Offered Portfolio Management Services RJA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RJA creates an investment policy statement for each client, which outlines the client’s current situation (income, tax, and risk tolerance) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Asset allocation • Risk tolerance • Personal investment policy • Asset selection • Regular portfolio monitoring RJA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. In most cases, RJA will request discretionary authority from clients. When discretionary authority is provided by clients RJA can select securities and process transactions without additional permission from the client prior to each specific transaction. RJA takes steps to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RJA’s economic, investment or other financial interests. To meet its fiduciary obligations, RJA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RJA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RJA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments RJA generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs, U.S. Treasury Inflation Protected/Inflation Linked Bonds and non-U.S. securities. RJA may use other securities as well to help diversify a portfolio when applicable. 1  Optional Non-Advisory Services: In addition to investment advisory services described above, RJA offers certain non-advisory services. Advisory clients are under no obligation to use these non-advisory services. The non- advisory services of RJA include: Insurance Services In order to ensure that client income and assets are adequately protected and preserved RJA consults with clients regarding their needs for insurance coverage with policies including life insurance, disability insurance, and annuities (but not property and casualty insurance). When appropriate, RJA will, through appropriately licensed insurance agents of the Firm, recommend relevant insurance products and assist clients with obtaining policies through insurance carriers. Tax Preparation Services RJA offers Tax Preparation Services (“TPS”) to certain clients. TPS is a non-investment advisory service provided under a separate engagement letter and fee arrangement. TPS primarily consists of preparing and filing individual federal and state income tax returns (Form 1040 and related schedules) and providing tax return preparation support, such as organizing client-provided tax documents, preparing required tax filings, and providing return copies and filing confirmations. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under the provisions of this special rule, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions RJA provides personalized, comprehensive financial planning and investment management for individuals, trusts, estates, and small businesses. RJA specializes in efficient Accumulation, Distribution and Conservation of client wealth. This includes risk assessment, cash flow 2  management, and tax planning. The process starts with detailed fact-finding which allows for verification of a client’s Present Plan. The information provided will be used to build the client’s PS&G (Protection, Savings & Growth) Model which is utilized to verify the client’s present financial position. The goal is to identify and implement comprehensive strategies to ensure that the client’s financial position is optimally coordinated and integrated to accomplish the objectives. Periodic reviews are established to address future client needs as well as any changing circumstance. RJA will continue to assess and communicate specific courses of action that need to be taken moving forward. On more than an occasional basis, RJA furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning. RJA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. D. Wrap Fee Programs RJA does not sponsor a wrap program but may recommend/enroll clients into SEI’s wrap fee program. The SEI Managed Account Program is a wrap fee program provided by SEI, which charges a bundled fee that includes advisory, brokerage, and custody services. E. Assets Under Management RJA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $205,339,465 $6,276,448 December 2025 Item 5: Fees and Compensation A. Fee Schedule The Advisory Fee is calculated and typically payable monthly in arrears, on the month-end balance of the Account. 3  Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.00% $500,001 - $3,000,000 0.75% $3,000,001 - AND UP 0.50% RJA uses the value of the account as of the last business day of the billing period, after considering deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of RJA's fees within five business days of signing the Investment Advisory Agreement. Thereafter, clients may terminate the Investment Advisory Agreement immediately upon written notice under the terms and conditions contained therein. Fees for Optional Non-Advisory Services: Insurance Services RJA does not change any fees related to its insurance services. When RJA licensed insurance agents submit applications for insurance products, and policies are issued through insurance carriers, RJA will receive a commission. Tax Preparation Services TPS is offered as under a separate engagement letter and is billed separately from RJA’s investment advisory fee. TPS clients are generally charged a flat fee based on return complexity and the time and effort required. TPS fees are not based on assets under management and are not charged as a percentage of investment assets. RJA will communicate the applicable TPS fee to the client before beginning work, and the client may decline TPS at any time before preparation is begun (after which RJA may be entitled to a prorated fee). TPS fees are due upon invoicing. Factors that may affect TPS fees include, for example, the number of tax forms and schedules required, the number of states, investment activity, itemized deductions, self-employment or rental income, and other complexities. Conflict Of Interest: Because TPS is a separate paid service, RJA has a financial incentive to offer TPS and to encourage clients to use TPS rather than engage a different tax preparer. RJA addresses this conflict by (i) disclosing the availability of TPS and related fees, (ii) limiting TPS to the scope described in this brochure and the client executed TPS engagement letter, and (iii) ensuring that clients understand that they may choose to engage any other tax preparer (with 4  which RJA will coordinate and cooperate with as needed) or (iv) clients can prepare their tax returns on their own. B. Payment of Fees Payment of Portfolio Management Fees Typically, asset-based portfolio management fees are withdrawn directly from the client's custodial account(s), with the client’s written authorization, on a monthly basis. Fees are paid in arrears. C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by RJA. Please see Item 12: Brokerage Practices of this brochure for information regarding custodial arrangements. D. Prepayment of Fees RJA collects its fees in arrears. It does not collect fees in advance. Further, RJA does not accept, charge, require or solicit prepayment of advisory fees of more than $500 per client, six months or more in advance. E. Outside Compensation for the Sale of Securities to Clients RJA does not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management RJA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients RJA generally provides advisory services to the following types of clients: Individuals • • High-Net-Worth Individuals 5  There is no account minimum for any of RJA’s services. Availability of Non-Advisory Service: Tax Preparation Services TPS may be offered only to certain advisory clients based on RJA capacity, staffing, and scheduling constraints. RJA may limit TPS availability and may not be able to accept all requests for TPS. Clients who do not receive TPS from RJA may continue to use any independent tax professional of their choosing and RJA will reasonably coordinate and cooperate with that professional as directed by the client. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis RJA’s methods of analysis include Fundamental analysis, Modern portfolio theory and Quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize the portfolios expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies RJA primarily uses a long-term investment approach, meaning we generally purchase securities with the expectation they will be held for several years. Trading occurs infrequently and is typically triggered by changes in client circumstances, valuation concerns, or portfolio rebalancing needs. This approach may result in lower portfolio turnover, reduced trading fees, and less volatility, but may also cause clients to miss shorter-term market opportunities. B. Material Risks Involved Risks Associated with Different Methods of Analysis 6  Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Risks Associated with our Investment Strategies RJA’s long term investment approach is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (except, notably, U.S. Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known 7  type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on U.S. Treasury Inflation Protected/Inflation Linked Bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (NAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another, and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular or similar material, which should be considered carefully when making investment decisions. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 8  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither RJA nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither RJA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Patrick Ross, Corey Ross, and Eric Marquardt are licensed insurance agents. They will offer clients advice about insurance and, when appropriate, recommend specific insurance products, including, life insurance, disability insurance, and annuities. Clients should be aware that these services pay a commission and therefore involve a possible conflict of interest, as commissionable products can create financial incentives for the Firm. RJA always acts in the best interest of the client, including in the sale of commissionable products to advisory clients. Clients are in no way required to implement any recommendations to purchase insurance through any representative of RJA in their capacity as a licensed insurance agent. 9  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections RJA may recommend that client assets be managed by an independent third-party investment adviser, SEI Investments Management Corp. (“SEI IMC”). In these arrangements, SEI IMC provides day-to-day discretionary portfolio management pursuant to a separate advisory agreement between the client and SEI IMC. Clients using SEI IMC pay an advisory fee to RJA and a separate advisory fee to SEI IMC, in addition to any custodial or transaction-related costs. As a result, clients generally pay higher overall advisory fees than if assets were managed solely by RJA. This creates a conflict of interest because RJA receives advisory compensation regardless of whether assets are managed by RJA or a third-party manager. RJA does not receive compensation from SEI IMC for recommending SEI IMC. Clients are not required to use SEI IMC and may select a different investment adviser or decline the use of a third-party manager. RJA evaluates and periodically reviews third-party managers based on factors such as investment approach, performance, fees, and regulatory history; however, RJA does not control the specific investment decisions made by SEI IMC. Clients should understand that use of a third-party manager involves additional risks, including layered fees and reliance on the manager’s investment decisions. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all our dealings. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide of copy of its Code of Ethics to any client or prospective client upon request. B. Recommendations Involving Material Financial Interests RJA does not recommend that clients buy or sell any security in which a related person to RJA or RJA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of RJA may buy or sell securities for themselves that they also recommend to clients. The CCO will always document any transactions that could be construed as conflicts of interest and RJA will always transact client business before its own when similar securities are being bought or sold. 10  D. Trading Securities at or Around the Same Time as Clients’ Securities From time to time, representatives of RJA may buy or sell securities for themselves that they also recommend to clients. The CCO will always document any transactions that could be construed as conflicts of interest and RJA will always transact client business before its own when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers RJA does not have any affiliation with Broker-Dealers. Specific custodian selections are made with clients based upon their needs. We recommend SEI based on our due diligence, their reputation, and services they provide. 1. Research and Other Soft-Dollar Benefits RJA currently has no formal soft dollar program in which soft dollars are used to pay for third party services. RJA may receive research, products, or other services from custodians in connection with client securities transactions (“soft dollar benefits”). RJA may choose to enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and RJA does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. If RJA benefits by not having to produce or pay for the research, products or services, RJA may have an incentive to recommend a custodian based on receiving research or services. 2. Brokerage for Client Referrals RJA does not receive referrals from any third party in exchange for using that third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use RJA requires its investment advisory clients to use a specific custodian, SEI Investment Company (or its subsidiaries such as SEI Trust Company and SEI Private Trust), to execute transactions. Exceptions to this requirement may be made at RJA’s sole discretion; not all advisers require clients to use a particular custodian. B. Aggregating (Block) Trading for Multiple Client Accounts 11  RJA does not aggregate or bunch securities to be purchased or sold for multiple clients. All client trades are processed individually. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for which RJA provides advisory services on an ongoing basis are reviewed at least annually by Patrick Ross, Owner & CCO of RJA, with regard to clients’ respective investment policy statements and risk tolerance levels. All accounts managed by RJA are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Other than annual reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of RJA's advisory services provided on an ongoing basis will receive at a minimum a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the client’s custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) RJA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to RJA's clients. RJA may receive complementary travel and lodging to attend conferences to learn about industry-wide trends, provider specific changes, or other learning opportunities. B. Compensation to Non – Advisory Personnel for Client Referrals RJA does not directly or indirectly compensate any person who is not supervised by RJA for client referrals. 12  Item 15: Custody RJA does not maintain custody of client funds or securities. Client assets are held with qualified custodians, typically SEI. RJA does not serve as a qualified custodian and, except as described in this Item 15, does not otherwise have access to client funds or securities. Pursuant to SEC rules, RJA is deemed to have custody of client assets solely as a result of its authority to deduct advisory fees directly from client accounts and, in certain circumstances, because it may receive checks made payable to third parties on behalf of clients. Any such checks are made payable only to the client’s qualified custodian or to a third party designated by the client and are promptly forwarded to the appropriate custodian or third party for processing. RJA does not accept checks made payable to itself or to cash. In addition, clients may establish standing letters of authorization (“SLOAs”) directly with their qualified custodian that permit RJA, as the client’s agent, to instruct the custodian to transfer funds to a third party designated by the client. These arrangements are subject to the custodian’s controls, including written client authorization, client revocation rights, and transaction confirmations. RJA does not have authority to change the designated third-party recipient, the amount, or the timing of any transfers beyond the parameters authorized by the client and accepted by the custodian. RJA maintains policies and procedures designed to safeguard client assets, including logging and monitoring the receipt and forwarding of third-party checks, periodic review of custodial agreements and SLOAs, and other controls designed to prevent the Firm from obtaining custody of client assets. Clients receive account statements directly from their qualified custodian at least quarterly, and RJA urges clients to carefully review those statements and compare them with any reports or information provided by RJA. Item 16: Investment Discretion RJA provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Agreement established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, RJA generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, RJA’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment policy statements, objectives, or client instructions otherwise provided to RJA). Item 17: Voting Client Securities (Proxy Voting) 13  RJA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or their custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet RJA neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither RJA nor its management has any financial condition that is likely to reasonably impair RJA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years RJA has not been the subject of a bankruptcy petition in the last ten years. 14