Rothschild Investment

Item 1: Cover Page Part 2A of Form ADV Firm Brochure March 31, 2026 Rothschild Investment LLC SEC File No. 807-7395 311 S. Wacker Drive Suite 5900 Chicago, IL 60606 312-983-8900 info@rothschildwealth.com www.rothschildwealth.com This brochure provides information about the qualifications and business practices of Rothschild Investment LLC. If you have any questions about the contents of this brochure, please contact us at info@rothschildwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Rothschild is also available on the SEC website: www.adviserinfo/sec.gov  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. The following material changes have occurred since the Firm’s last annual update: • Adoption of Updated Advisory Agreement. The Firm adopted an updated form of investment advisory agreement for use with new clients and on a going-forward basis. The updated agreement clarifies contractual terms, including the scope of advisory services, fiduciary duties owed to clients, client responsibilities, and fee billing mechanics (including the ability to charge advisory fees in advance or in arrears, as specified in the applicable agreement). These updates did not result in a material change to the Firm’s advisory services or standard fee schedules. • Clarification of Fiduciary Duties and Standard of Care. The Firm enhanced its disclosures regarding the fiduciary duties it owes to advisory clients, including duties of care, loyalty, good faith, and obedience, consistent with its obligations under the Investment Advisers Act of 1940. • Fee Billing and Valuation Clarifications. The Firm clarified disclosures regarding advisory fee calculation and billing practices, including proration, advance versus arrears billing, and the valuation of assets for billing purposes. These clarifications reflect existing practices and are governed by the applicable advisory agreement. • Private Investments and Affiliated Private Funds. The Firm clarified disclosures relating to private alternative investments and affiliated private investment vehicles, including the Firm’s role, limitations on authority, valuation practices, and related conflicts of interest, where applicable. • Use of Multiple Advisory Agreement Forms. The Firm clarified that different versions of its advisory agreement may be in effect for different clients during transition periods, with the terms governing each client relationship set forth in the advisory agreement applicable to that client. Existing clients are not required to execute new advisory agreements solely as a result of these updates. Clients will receive notice of these material changes in accordance with applicable regulatory requirements. `  Item 3: Table of Contents Item 3: Table of Contents Item 1: Cover Page ...................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................................... 3 Item 4: Advisory Business ......................................................................................................................................... 4 Item 5: Fees and Compensation .......................................................................................................................... 10 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 14 Item 7: Types of Clients ........................................................................................................................................... 15 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 16 Item 9: Disciplinary Information ........................................................................................................................... 28 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 28 Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ... 31 Item 12: Brokerage Practices ................................................................................................................................... 33 Item 13: Review of Accounts ................................................................................................................................... 39 Item 14: Client Referrals and Other Compensation ........................................................................................ 40 Item 15: Custody .......................................................................................................................................................... 41 Item 16: Investment Discretion ............................................................................................................................... 42 Item 17: Voting Client Securities ............................................................................................................................ 43 Item 18: Financial Information ................................................................................................................................ 44  Item 4: Advisory Business Item 4: Advisory Business A. Ownership/Advisory History We are proud of our Firm’s unique position in the investment industry. Established in 1908, Rothschild is the oldest Chicago-based investment firm that remains a separate entity under the guidance of its founding family. We are uniquely structured to assist clients in the management of their personal and corporate finances. The professional staff averages 20 years’ experience in working with professionals, business owners, and their retirement funds. In fact, the Firm caters to the corporate needs of the closely held business and the personal needs of its owners. Rothschild has made a long-term commitment to working with entrepreneurs and their special investment requirements. The longevity of the Firm is testimony to our commitment to service and the implementation of a successful long-term investment philosophy. Rothschild Investment LLC (“Rothschild Investment” or the “firm”) is a Delaware limited liability company principally owned by Tin Goose Holdings LLC. The Managing Member of Rothschild Investment is Rothschild Holdings, LLC. Rothschild Investment has been providing investment advisory and financial planning services since 1908. Rothschild Investment LLC is also registered as a broker-dealer and a member of FINRA. Certain of the firm’s investment adviser representatives are also registered representatives of the broker-dealer. In such dual capacities, these individuals may recommend securities transactions through the broker-dealer and receive transaction-based compensation, including commissions and other fees, in addition to advisory fees. Clients are not obligated to effect transactions through Rothschild Investment LLC in its broker-dealer capacity. B. Advisory Services Offered Rothschild Investment is an independent investment advisory and financial planning firm offering a variety of financial services to individuals and high-net-worth individuals, corporate executive groups, trusts, corporations, partnerships, pension and profit sharing plans, institutional retirement (both ERISA and non-ERISA) plans, tax exempt, and other legal entities. Advisory services may include financial planning, investment strategy, portfolio management, tax preparation, tax and estate planning, as well as recommendation of third-party sub-advisers. Discretionary Asset Management Services For its discretionary asset management services, Rothschild Investment receives a limited power of attorney to effect securities transactions on behalf of its clients. Clients may grant Rothschild Investment limited discretionary authority with respect to advisory client assets, including discretion to select third-party sub-advisers on behalf of such Rothschild Investment advisory clients. Investment advisory services are provided on either a discretionary or non-discretionary basis, depending on the agreement between the client and Rothschild Investment. Rothschild Investment recommends securities transactions to its clients that include securities and strategies as described in Item 8 of this Brochure. In preparing the asset allocation, Rothschild Investment will analyze each client’s current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance. Rothschild Investment’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk and other personal and financial circumstances, and make appropriate asset allocation recommendations and implementation decisions. Rothschild Investment may engage third-party service providers to assist with the tax and estate planning portion of the services provided to clients. In addition, Rothschild Investment may utilize  Item 4: Advisory Business third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Rothschild Investment will monitor those portfolios and make additional recommendations from time to time to rebalance and/or reallocate each client’s investments. Rothschild Investment’s investment advisory services to clients are based on asset allocation models that, as noted above, take into account a client’s personal financial circumstances, investment objectives, and tolerance for risk (e.g., cash-flow, tax, and estate). Rothschild Investment’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the clients current investment portfolio against the client’s personal and financial circumstances as disclosed to Rothschild Investment in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Rothschild Investment. ▪ Analyzing the client’s financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending mutual funds, exchange-traded funds, and individual equity and fixed income securities, each matched to the asset categories in the client’s targeted asset allocation for consideration by the client. ▪ Reporting to the client on a quarterly basis or at some other interval agreed to with the client, information on contributions and withdrawals in the client’s investment portfolio. ▪ Proposing changes in the client’s targeted asset allocation in consideration of changes in the client’s personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client’s investments, and/or the performance of any fund or manager retained by the client. Clients have the right to provide the firm with any reasonable investment restrictions on the management of their portfolio, which must be in writing and sent to the firm. Clients should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Rothschild Investment will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Rothschild Investment will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Rollovers – Conflicts and Added Fees. Plan participants may be paying little or nothing for the plan’s investment services. As such, investment management costs are likely to be higher when engaging an investment adviser for professional investment management. Alternative courses of action are available to the plan participant: (i) Assuming it is permitted by the Plan, you can leave your money in your current Plan. (ii) If you have changed employers, you can roll your assets into the new employer’s Plan, if permissible by your new employer. (iii) You can establish an IRA R/O and place into a commission-based account at a broker-dealer. (iv) You can establish an IRA R/O and place into a fee-based advisory account. (v) You can withdraw your retirement money and pay the taxes and any applicable penalties. Your decision to roll assets from a qualified plan to a financial professional should be determined by your need for a desired level of investment services, the associated costs, and access to a diverse range of investment products that meet your personal risk tolerance and investment objective.  Item 4: Advisory Business Institutional Investment Consulting Rothschild Investment also provides investment consulting and investment advisory services to institutional ERISA (see detailed explanatory note under B.4. below) and non-ERISA retirement plans, trusts, foundations, estates, charitable organizations, corporations, or other business entities. Institutional investment management services typically include portfolio design, asset allocation modeling, preparation of investment policy statements, screening and selection of investment managers, and performance monitoring. Depending on the client’s unique circumstances, Rothschild Investment may provide discretionary or non-discretionary investment consulting services for institutions. Selection of Other Advisers (Sub-Advisers) As part of its portfolio management services, Rothschild Investment may recommend one or more third-party sub-advisers to manage all or a portion of the client's investment portfolio. Factors taken into consideration when making recommendations include, but are not limited to, the sub-adviser’s performance, investment strategies, methods of analysis, advisory and other fees, assets under management, and the client's financial objectives and risk tolerance. Rothschild Investment would generally retain authority to hire/fire the sub-adviser and regularly monitors the performance of the sub-adviser to ensure its management and investment style remain aligned with the client's objectives and risk tolerance. Rothschild Investment has sub-advisory agreements with unaffiliated registered investment advisers and platform providers. Rothschild Investment accesses various investment strategies made available through the sub-advisers’ investment platforms. Rothschild Investment determines which strategies the client assets are to be invested in, and thereafter the sub-adviser implements all trades necessary to cause such assets to be invested in the strategies. Rothschild Investment continuously manages any sub-adviser relationship and regularly monitors the client's account(s) for performance metrics and adherence to the client's investment objectives. Each sub-adviser maintains a separate disclosure document that Rothschild Investment will provide to the client. The client should carefully review the sub-adviser's disclosure document for information regarding fees, risks and investment strategies, and conflicts of interest. The sub-adviser’s fee will be in addition to the advisory fees charged by Rothschild Investment. Financial Planning Services Clients will receive a written or oral report (depending on the client’s preference) providing them with a detailed financial plan designed to help achieve their stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a recommended asset allocation that serves to diversify the client’s portfolio among different categories of investments, such as small, medium and large capitalization securities; corporate and government fixed income (short-, intermediate- and long-term maturities); emerging market securities (i.e., foreign issuers); and such other asset categories that are suitable in light of the client’s investment goals, objectives, and risk tolerance. ▪ Preparation of an investment policy statement setting forth the investment plan of the client with specific direction in terms of diversification requirements, tax issues, estate planning issues, risk tolerance, retirement, and other identified objectives of the client, including a targeted rate-of-return objective.  Item 4: Advisory Business ▪ Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client’s financial circumstances and risk tolerance. ▪ Preparation of cash flow projections to ensure that the client can meet daily living expenses and obligations. ▪ An insurance plan to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ Preparation of an estate plan to ensure that wealth transition, tax, and related issues are met in accordance with the client’s wishes. In many instances, an outside attorney will need to be hired to handle specific legal issues that arise in the formation and implementation of an estate plan. Rothschild Investment, as a matter of policy, does not provide tax advice. ▪ A business exit/continuity plan, taking into account the business and personal goals and objectives of the client, client’s family, employees, and other affected parties. ▪ Coordination of all planning into a single cohesive plan. Rothschild Investment gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client’s current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. 401(k) Portfolio Management Services Rothschild Investment will provide non-discretionary portfolio management services to 401(k) plan participants. The advice will consist of recommending suitable asset allocation based on the plan participant’s tolerance for risk, and investment objectives accounting for the available investment alternatives available to the plan participant. To the extent the client has a self-directed account, Rothschild Investment may recommend a model portfolio of diversified exchange-traded funds. Once the plan participant has engaged Rothschild Investment for this service, Rothschild Investment will provide its recommendations through an automated email notification to the client, advising the client when the portfolio requires rebalancing. As a courtesy, Rothschild Investment will send applicable clients a follow-up reminder within a reasonable period of time after the first email notification to rebalance the portfolio. Any transactions required to effect the recommended rebalancing of the model portfolio will be the sole responsibility of the client. Institutional Retirement Investment Advisory Services Employees in qualified retirement plans are protected by the Employee Retirement Income Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan administrators to put employees’ interests first when managing retirement savings plans. Public retirement systems are governed by similar state laws and often incorporate the protections of ERISA. In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are certain steps that the fiduciary must take. Rothschild Investment is committed to helping fiduciaries understand their roles and to assist them in implementing a process that allows them to fulfill their duties and responsibilities. Rothschild Investment offers government retirement systems, sponsors of employee benefit plans (defined contribution and defined benefit) qualified under the Internal Revenue Code (“IRC”), and other retirement plans  Item 4: Advisory Business not qualified under the IRC (including Taft-Hartley organizations and “church” plans), a range of discretionary and non-discretionary services, including the selection of registered investment companies or other pooled investment funds to be offered under the plan. Rothschild Investment will assist plan fiduciaries in the following: ▪ Investment Selection and Monitoring • Creating an investment policy statement • Modeling asset allocations • Selecting investment managers • Determining QDIA investment alternatives • Monitoring the investment options against well-defined risk and return criteria Rothschild Investment’s investment professionals work in partnership with clients to create sound solutions to investment challenges, including: • Maximizing long-term return while not assuming unnecessary risk • Creating an optimal portfolio that includes a diverse array of investment options that span the risk/return spectrum • Keeping plan sponsors current on manager performance and the events that may affect performance ▪ Vendor Search and Selection and Plan Implementation Rothschild Investment also assists its retirement plan clients in selecting trustees, custodians, accountants, actuaries, record keepers, and other service providers. This process involves: • Generating criteria to identify appropriate service providers • Developing or responding to requests for proposals • Evaluating highly rated service provider candidates Once a service provider is selected, Rothschild Investment will assist a client in implementing the client’s retirement plan program. In implementing the program, Rothschild Investment will, among other things, review the plan design, develop performance standards, and review the service provider’s contract. Rothschild Investment also provides assistance with strategic employee education and communications in connection with client retirement plan programs. Private Fund Portfolio Management The firm serves as the investment manager to an affiliate private fund and continuously manages the fund’s assets based on the investment goals and objectives as outlined in the fund’s offering documents. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of the account— for example, restricting the type or amount of security to be purchased in the portfolio.  Item 4: Advisory Business D. Wrap Fee Programs Rothschild Investment does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2025, Rothschild Investment had $ 2,790,556,289discretionary assets under management and $2,792,196,229 in in assets under advisement.  Item 6: Performance-Based Fees and Side-by-Side Management Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Investment Advisory Services Rothschild Investment LLC (“Rothschild”) provides investment advisory services for a fee based on a percentage of assets under management. Fees are negotiable and are generally based on the size and complexity of the client relationship. The standard annual fee schedule is as follows: 1.25% on the first $3,000,000 1.00% on the next $4,000,000 0.75% on the next $8,000,000 0.50% on assets over $15,000,000 Advisory fees are typically billed monthly or quarterly, in advance, as outlined in the client’s investment advisory agreement. Fees are generally calculated based on the market value of assets in the account at the end of the prior billing period, unless otherwise agreed. Rothschild may, in its discretion, group related client accounts for purposes of determining fee breakpoints (“householding”). Fees may be higher or lower than the standard schedule based on client-specific factors, including anticipated future assets, related relationships, portfolio complexity, and services provided. Financial Planning Services Rothschild offers financial planning services on a standalone basis. Fees for these services are typically charged on an hourly basis and generally range from $400 to $500 per hour, depending on the complexity of the engagement and the level of expertise required. Clients will receive an estimate of total costs prior to the engagement. Fees may be billed in advance or upon completion of services, as agreed. Financial planning services do not include ongoing investment management unless a separate advisory agreement is entered into. Retirement Plan Consulting Services Rothschild provides retirement plan consulting services for plan sponsors. Fees may be structured as: An asset-based fee ranging from 0.10% to 1.25% of plan assets; A fixed fee; An hourly fee (generally ranging from $300 to $1,200 per hour); or A combination of the above. Fees are negotiable and depend on the scope of services and size of the plan. Asset-based fees are typically billed monthly or quarterly, in advance, as agreed in the applicable services agreement.  Item 6: Performance-Based Fees and Side-by-Side Management Assets Under Management Annual Fee 1.25% • Under $1,000,000 1.00% • $1,000,000 to $5,000,000 0.75% • $5,000,001 to $10,000,000 0.50% • $10,000,001 to $25,000,000 Negotiable • Over $25,000,000 For certain Retirement Plan Consulting Services clients, Rothschild will be designated as the broker of record for the relevant plan(s) and will receive brokerage-based compensation (including without limitation brokerage commissions, 12b-1 fees and other distribution fees) for the trades executed on behalf of the relevant plan(s) rather than receiving an asset-based fee as illustrated in the table above. In those circumstances, personnel of Rothschild who provide services to the relevant plan(s) and are registered representatives of Rothschild will receive a portion of the brokerage compensation paid to Rothschild by such plan(s). In such cases, Rothschild provides full disclosure to plan sponsors regarding such commissions and fees. B. Billing and Payment of Fees Clients may authorize Rothschild to deduct advisory fees directly from their accounts held with a qualified custodian. In such cases: The client provides written authorization for fee deduction; and The custodian provides account statements at least quarterly reflecting all fee deductions. Alternatively, clients may elect to be invoiced directly. If fees are billed in advance, any unearned portion of prepaid fees will be refunded promptly upon termination of the advisory relationship. If fees are billed in arrears, any earned, unpaid fees will be due upon termination. Clients may terminate their advisory agreement in accordance with the terms outlined in the agreement. C. Additional Fees and Expenses In addition to Rothschild’s advisory fees, clients may incur other fees and expenses, including but not limited to: Custodial fees Brokerage commissions and transaction charges Mutual fund and ETF expenses (including management fees and operating expenses) Sub-adviser or platform fees, where applicable These fees are separate from and in addition to the fees charged by Rothschild. Clients should review all relevant disclosure documents, including fund prospectuses and sub-adviser brochures, for a complete description of these costs.  Item 6: Performance-Based Fees and Side-by-Side Management D. Compensation Related to Brokerage and Other Activities Certain of Rothschild’s investment adviser representatives are also registered representatives of Rothschild in its capacity as a broker-dealer and/or are licensed to sell insurance products. In these capacities, such individuals may receive transaction-based compensation, including commissions, 12b-1 fees, or other distribution-related payments. This creates a conflict of interest, as such individuals have an incentive to recommend securities or products that result in additional compensation. Clients are not obligated to implement recommendations through Rothschild in its broker-dealer capacity and may choose another broker-dealer or insurance provider. To mitigate these conflicts: • Rothschild does not require clients to effect brokerage transactions through the firm; • Clients are free to select any broker-dealer or insurance provider; and • Rothschild seeks to avoid the receipt of duplicative compensation for the same services; however, different fee structures may apply depending on whether services are provided in an advisory or brokerage capacity. In some cases, a Rothschild representative may refer a client to another Rothschild representative for portfolio management services. In such instances, the referring representative may receive a portion of brokerage compensation, and the portfolio manager may receive a portion of advisory fees. This creates a conflict of interest, as there is an incentive to make such referrals. Clients are not obligated to utilize Rothschild for both brokerage and advisory services. E. ERISA Considerations When providing services to retirement plans or individual retirement accounts, Rothschild acts as a fiduciary under the Employee Retirement Income Security Act of 1974 (“ERISA”), where applicable. As such, Rothschild is subject to specific duties and obligations, including restrictions on certain forms of compensation and conflicts of interest. Rothschild seeks to comply with applicable prohibited transaction exemptions when acting in both advisory and brokerage capacities. Where Rothschild provides both investment advisory and brokerage services to a retirement plan, this dual role creates a conflict of interest. Plan sponsors are informed of this arrangement and may be required to acknowledge and approve such relationships. F. Important Disclosure – Custodian Investment Programs Please be advised that certain of the firm’s investment adviser representatives are registered with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker-dealer. Under these arrangements, we can access certain investment programs offered through the broker-dealer that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. As such, the investment adviser representative and/or the firm may have an economic incentive to recommend the purchase of 12b-1 or revenue share class mutual funds offered through the broker-dealer platform rather than from the investment adviser platform. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for our advisory clients’ portfolios. There  Item 6: Performance-Based Fees and Side-by-Side Management are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances (i) where our adviser representative is also licensed as a registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue sharing fees as compensation – such compensation creates an incentive for the investment adviser representative to use programs which utilize funds that pay such additional compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm’s clients.  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management Rothschild Investment may charge performance-based fees to qualified clients investing in the private fund who meet certain criteria as described below. Clients are advised that performance-based fees involve a sharing of any portfolio gains between the investor and the investment manager. Such performance-based fees create an economic incentive for the investment manager to take additional risks in the management of a client portfolio that may be in conflict with the client’s current investment objectives and tolerance for risk. The investment manager is also incentivized to allocate more time to the management of performance-based portfolios and to preference investment allocations and investment ideas of performance-based clients. Performance-based fees are described in the fund’s offering documents. Performance-based fees may only be offered to clients who meet one of the following criteria: ▪ A natural person who or a company that immediately after entering into the contract has at least $1,100,000 under the management of the investment adviser; ▪ A natural person or a company that the investment adviser entering into the contract (and any person acting on his behalf) reasonably believes, immediately prior to entering into the contract, either: • Has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 at the time the contract is entered into, exclusive of the value of their primary residence; or • Is a qualified purchaser as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 (15U.S.C. 80a-2(51)(A)) at the time the contract is entered into; or • A natural person who immediately prior to entering into the contract is: ▪ An executive officer, director, trustee, general partner, or person serving in similar capacity of the investment adviser; or ▪ An employee of the investment adviser (other than an employee performing solely clerical, secretarial, or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar functions or duties for or on behalf of another company for at least 12 months.  Item 7: Types of Clients Item 7: Types of Clients Rothschild provides advisory services to the following types of clients: • • • • • Individuals, families, trusts, and estates High net worth individuals Pension and profit-sharing plans, IRAs Charitable organizations and foundations Corporations or other businesses not listed above Rothschild does not require a minimum dollar value of assets or other conditions for opening or maintaining an account for these types of clients. In addition to the types of clients described above, Rothschild acts as investment manager to certain private pooled investment vehicles serving as conduit vehicles (each, a “Conduit Fund”). Each Conduit Fund is a special purpose entity (typically a limited partnership, limited liability company, or offshore company) formed by Rothschild for the sole purpose of aggregating investor assets to a single entity and investing such assets in a designated underlying fund, which is typically a private fund managed by an unaffiliated third-party (the “Third- Party Managers”). These Third-Party Managers employ a variety of investment techniques and strategies, including, but not limited to venture, private equity, and hedge fund strategies. Conduit Funds managed by Rothschild are managed in accordance with each vehicle's investment guidelines and restrictions and are generally not tailored to the individual needs of any particular investor. In its capacity as investment manager, Rothschild’s principal services consist of providing investment advice regarding the investment of the assets of each Fund among professionally selected investment vehicles or accounts that are managed by the Third-Party Managers, which are selected through a due diligence process. With respect to Conduit Funds managed by Rothschild, the general requirements to invest in private funds (qualifications, minimum investment, etc.), as well as the applicable fees and expenses, are set forth in the relevant offering or governing documents (or in certain cases, in separate fee agreements between Rothschild and the private fund’s investors)  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Rothschild Investment uses a variety of sources of data to conduct its economic, investment and market analysis, such as financial newspapers and magazines, economic and market research materials prepared by others, conference calls hosted by mutual funds, corporate rating services, annual reports, prospectuses, and company press releases. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. Rothschild Investment and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as price and volume statistics, performance data, standard deviation, and related risk metrics, how the security performs relative to the overall stock market, earnings data, price to earnings ratios, and related data. ▪ Technical analysis involves charting price and volume data as reported by the exchange where the security is traded to look for price trends. ▪ Computer models may be used to attempt the future value of a security based on assumptions of various data categories such as earnings, cash flow, profit margins, sales, and a variety of other company specific metrics. In addition, Rothschild Investment reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. Rothschild Investment may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. Mutual Funds, Exchange-Traded Funds, Third-Party Sub-Advisers, Individual Equity and Fixed Income Securities, and Pooled Investment Vehicles Rothschild Investment may utilize ”institutional share class” mutual funds, exchange-traded funds (“ETFs”), and individual securities (including fixed income instruments), and pooled investment vehicles. Rothschild Investment may also assist the client in selecting one or more appropriate sub-advisers for all or a portion of the client’s portfolio. Such sub-advisers will typically manage assets for clients who commit to the manager a minimum amount of assets established by that sub-adviser—a factor that Rothschild Investment will take into account when recommending sub-advisers to clients. Rothschild Investment’s selection process cannot ensure that sub-advisers will perform as desired, and Rothschild Investment will have no control over the day- to-day operations of any of its selected sub-advisers. Rothschild Investment would not necessarily be aware of certain activities at the underlying sub-adviser’s level, including without limitation a sub-adviser’s engaging in unreported risks, investment “style drift,” or even regulatory breaches or fraud.  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A description of the criteria to be used in formulating an investment recommendation for mutual funds, exchange-traded funds, individual securities (including fixed-income securities), sub-advisers, and pooled investment vehicles is set forth below. Rothschild Investment has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks Rothschild Investment may utilize additional independent third parties to assist it in recommending and monitoring individual securities, funds, sub-advisers, and pooled investment vehicles to clients as appropriate under the circumstances. Rothschild Investment reviews certain quantitative and qualitative criteria related to funds and sub-advisers and to formulate investment recommendations to its clients. Quantitative criteria may include: ▪ performance history of a fund or sub-adviser evaluated against that of its peers and other benchmarks ▪ analysis of risk-adjusted returns ▪ analysis of the contribution to the investment return (e.g., manager’s alpha), standard deviation of returns over specific time periods, sector, and style analysis ▪ fund or sub-adviser’s fee structure ▪ relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending funds or sub-advisers include the investment objectives and/or management style and philosophy of a fund or sub-adviser; a mutual fund or sub-adviser’s consistency of investment style; and employee turnover and efficiency and capacity. Quantitative and qualitative criteria related to funds and sub-advisers are reviewed by Rothschild Investment on a quarterly basis or such other interval as appropriate under the circumstances. In addition, funds or sub-advisers are reviewed to determine the extent to which their investments reflect any of the following: efforts to time the market, engage in portfolio pumping, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the fund or sub-adviser by Rothschild Investment (all negative factors in implementing an asset allocation structure). Rothschild Investment may negotiate reduced account minimum balances and reduced fees with sub-advisers under various circumstances (e.g., for clients with minimum level of assets committed to the manager for specific periods of time, etc.). There can be no assurance that clients will receive any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the funds or sub-advisers utilized. Rothschild Investment will endeavor to obtain equal treatment for its clients with funds or sub-advisers, but cannot assure equal treatment. Rothschild Investment will regularly review the activities of funds and sub-advisers utilized for the client. Clients that engage sub-advisers or invest in funds should first review and understand the disclosure documents of those  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss sub-advisers or funds, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees, and conflicts of interest. Similarly, clients qualified to invest in pooled investment vehicles should review the private placement memoranda or other disclosure materials relating to such vehicles before making a decision to invest. Material Risks of Investment Instruments Rothschild Investment typically invests in equity securities, corporate debt instruments, municipal fixed income instruments, government securities including asset-backed securities, and options on securities as detailed below: ▪ Equity securities ▪ Warrants and rights ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Corporate debt securities, commercial paper, and certificates of deposit ▪ Municipal securities ▪ U.S. government securities ▪ Private placements ▪ Pooled investment vehicles ▪ Structured products ▪ Exchange-traded notes ▪ Option contracts on securities ▪ Government and agency mortgage-backed securities ▪ Corporate debt obligations ▪ Mortgage-backed securities ▪ Collateralized obligations Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Warrants and Rights Warrants are securities, typically issued with preferred stock or bonds, that give the holder the right to purchase a given number of shares of common stock at a specified price and time. The price of the warrant usually represents a premium over the applicable market value of the common stock at the time of the warrant’s  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss issuance. Warrants have no voting rights with respect to the common stock, receive no dividends, and have no rights with respect to the assets of the issuer. Investments in warrants and rights involve certain risks, including the possible lack of a liquid market for the resale of the warrants and rights, potential price fluctuations due to adverse market conditions or other factors, and failure of the price of the common stock to rise. If the warrant is not exercised within the specified time period, it becomes worthless. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”), iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employ the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Corporate Debt, Commercial Paper, and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity.  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax free at the federal level but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. U.S. Government Securities U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Private Placements Private placements carry significant risk in that companies using the private placement market conduct securities offerings that are exempt from registration under the federal securities laws, which means that investors do not have access to public information and such investors are not provided with the same amount of information that they would receive if the securities offering was a public offering. Moreover, many companies using private placements do so to raise equity capital in the start-up phase of their business or require additional capital to complete another phase in their growth objective. In addition, the securities issued in connection with private placements are restricted securities, which means that they are not traded on a secondary market, such as a stock exchange, and they are thus illiquid and cannot be readily converted to cash. Pooled Investment Vehicles A pooled investment vehicle, such as a commodity pool or investment company, is generally offered only to investors who meet specified suitability, net worth and annual income criteria. Pooled investment vehicles sell securities through private placements and thus are illiquid and subject to a variety of risks that are disclosed in each pooled investment vehicle’s confidential private placement memorandum or disclosure document. Investors should read these documents carefully and consult with their professional advisors prior to committing investment dollars. Because many of the securities involved in pooled investment vehicles do not have transparent trading markets from which accurate and current pricing information can be derived, or in the case of private equity investments where portfolio security companies are privately held with no publicly traded market, the firm will be unable to monitor or verify the accuracy of such performance information. Structured Products Structured notes are fixed income securities that are issued by financial institutions with returns that are linked to or based on, among other things, equity indices, a single equity security, a basket of equity securities, interest rates, commodities, debt securities, exchange traded funds, and/or foreign currencies (a “Structured Note”). The security, asset, or index on which a Structured Note is based is often called the “Reference Instrument.” Structured Notes have a fixed maturity date and include two components – a bond component and an embedded derivative. While some Structured Notes offer substantial protection of invested principal, others offer limited or no principal protection. 
 The embedded derivatives within Structured Notes adjust the note's risk/return profile by including additional modifying structures that can increase potential returns. The return performance of a Structured Note typically tracks the return profile of the underlying debt obligation and the derivative that is embedded within it. Instead of simply paying straight fixed or floating interest, Structured Notes can offer interest payments that are  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss tailored to specific indices and/or rates. The derivative securities that are embedded in the Structured Note can also positively or negatively affect the redemption value and final maturity of the security. Depending on complexity, risk profile, and numerous other factors, Structured Notes often pay interest or coupon rates that are above the prevailing market rate. Many Structured Notes cap or limit the amount of upside participation in the Reference Instrument or underlying asset, particularly in cases where the Structured Note offers principal protection or pays interest that is above-market. Structured Notes are typically issued by investment banks or their affiliates and feature a fixed maturity date. Structured Notes are not suitable for everyone. All investors assume full credit risk of the security’s issuer and/or guarantor. This means that the investor may lose all the monies invested, including all initial amounts invested as principal protection may not apply, if the issuer and/or the guarantor become insolvent or fail in any way. Each Structured Note involves varying degrees of risk and unique suitability issues that investors must consider before investing in such securities. Structured Notes involve important legal and tax consequences and investment risks, which each investor should discuss with qualified financial, accounting, and tax advisors regarding the suitability of the specific Structured Note in light of each investor’s particular circumstances. 
Understanding the Risk Factors. Before investing in any Structured Note security, it is important that you read the pricing supplement, accompanying prospectus, and prospectus supplements to ensure that you understand the risks associated with the specific Structured Note that you are purchasing. Payment terms vary significantly for each Structured Note depending on the structure and component of the specific security. While some Structured Notes may pay interest prior to liquidation, others may include payments only upon maturity. Additionally, rates of return vary based on many factors, including the performance of the underlying securities, assets, indices, and/or commodities. 
 Unless a Structured Note is specifically stated to be 100% principal protected or FDIC insured, some or all of your invested principal may be at risk. The return of your principal is guaranteed only to the extent specified in the specific offering terms for the Structured Note security you are purchasing and is specifically subject to the credit and creditworthiness of the issuer and the underwriter. If there is a negative return on the underlying security or Reference Instrument, then you may receive an amount that is less than your invested principal at maturity and you could lose up to the percentage indicated in your initial investment terms. In some cases, you may end up owning the underlying security at a price that is lower than the original purchase price. As discussed in the risk factor explanation below, you are also advised that, in cases where the return on the underlying securities is positive, payment may be limited if the structure includes a cap on the percentage return for the underlying security or depending on how the percentage increase for the underlying security is calculated as of the determination date. You are also advised that it may be difficult to sell or liquidate the Structured Note or underlying security as there may be little or no secondary market for such securities, and independent market pricing may be limited, or unavailable and market values may vary based on a variety of factors affecting the underlying securities or assets. Such factors may include, among other things: time to maturity; appreciation or depreciation of underlying securities; market volatility; interest rate fluctuations; and myriad other events that may positively or negatively affect the value of underlying securities, indices, or assets. Issuance price and note value. The price you will pay for a Structured Note at the time of issuance will often be higher than the fair market value of the Structured Note on the date of issuance. The cover page of the offering prospectus discloses the issuer’s estimated value of the Structured Note in order to enable you to note the difference between the issuance price and the issuer’s estimated value of the note. The issuance price of the  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss note is typically higher than the estimated market value of the note because issuers include in the initial price the costs for selling, structuring, and/or hedging their exposure on the note. Additionally, Structured Notes often may not be resold on a daily basis, which makes it difficult to value them, particularly given their complexity as compared to other financial products. Liquidity. With the exception of Exchange Traded Notes (“ETNs”), Structured Notes are typically not listed on any national securities exchange and can be difficult to sell, trade, or liquidate, especially in any large quantity or within any limited period of time. Although some Structured Notes are listed on national securities exchanges, such securities are often thinly traded and difficult to sell, trade, or liquidate. As a result, the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the note may be the only potential buyers for your Structured Note, and many issuers often specifically disclaim their intention to repurchase or make markets in the notes that they issue. If you choose to invest in a Structured Note, you must be prepared to hold the note until it reaches the maturity date or bear the risk of selling the note at a discount to its value at the time of sale. Payoff structure. Structured Notes often have complicated payoff structures that make it difficult to accurately assess their value, risk, and growth potential over the term of the note. It can be complex to determine each note’s performance, as the payoff structures and features vary considerably among different notes. For example, payoff structures may be leveraged, inverse, or inverse-leveraged, which can result in larger returns or losses for the investor. You should review the prospectus and pricing supplements carefully for each Structured Note to ensure that you thoroughly understand how the payoff on each note will be calculated. For example, the payoff on Structured Notes can depend on: Participation rates. Many Structured Notes provide a minimum payoff of the invested principal plus an additional payoff amount to the investor. This is calculated by multiplying the increase in the Reference Instrument by a fixed percentage, which is often called the “participation rate.” The participation rate determines how much of the increase in the Reference Instrument will be paid to you a purchaser of the Structured Note. Capped maximum returns. Some Structured Notes provide payments that are linked to a Reference Instrument with a leveraged or enhanced participation rate, but the payoff amount is capped at a pre-set maximum payoff amount. This means that the investor does not participate in any increase in the Reference Instrument above the maximum payoff level. Knock-in feature. Structured Notes often include a pre-specified threshold for the Reference Instrument that is called a knock-in feature (also known as a barrier or trigger) that affects the payout return on the note. If the Reference Instrument falls below a pre-specified level during the term of the note, you could lose some or all of your principal investment at maturity. You could also lose the coupon payments scheduled throughout the term of the note. Credit Rating. While many Structured Notes, Reference Instruments, and underlying securities may be assigned a credit rating from a national rating organization, many Structured Notes and underlying securities have no credit rating. To the extent that a particular credit rating may pertain to the creditworthiness of the issuer, it is not necessarily indicative of the risk associated with a specific Structured Note or Reference Instrument, index, or asset. The presentation of a credit rating in relation to any Structured Note or underlying security may not indicate or reflect the safety of the principal invested or the potential investment returns associated with the investment. Such credit ratings may not affect or enhance the likely performance of the Structured Note investment.
  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Tax
. The Structured Note investment may be treated as a “contingent payment debt instrument” for U.S. federal income tax purposes. Consequently, even in cases where any accrued interest is not payable until maturity, investors may be required to accrue such interest as ordinary income based on the “comparable yield” of the underlying securities as determined by the underwriter. Rothschild Investment strongly recommends that you consult your tax advisor regarding such tax treatment and implications prior to purchasing any Structured Note security. Exchange-Traded Notes (“ETNs”) ETNs are structured debt securities. ETN liabilities are unsecured general obligations of the issuer. Most ETNs are designed to track a particular market segment or index. ETNs have expenses associated with their operation. When a fund invests in an ETN, in addition to directly bearing expenses associated with its own operations, it will bear its pro rata portion of the ETN’s expenses. The risks of owning an ETN generally reflect the risks of owning the underlying securities the ETN is designed to track, although lack of liquidity in an ETN could result in it being more volatile than the underlying portfolio of securities. In addition, because of ETN expenses, compared to owning the underlying securities directly it may be more costly to own an ETN. The value of an ETN security should also be expected to fluctuate with the credit rating of the issuer. Options on Securities A call option is a contract under which the purchaser of the call option, in return for a premium paid, has the right to buy the security (or index) underlying the option at a specified price at any time during the term of the option. The writer of the call option, who receives the premium, has the obligation upon exercise of the option to deliver the underlying security against payment of the exercise price. A put option gives its purchaser, in return for a premium, the right to sell the underlying security at a specified price during the term of the option. The writer of the put, who receives the premium, has the obligation to buy, upon exercise of the option, the underlying security (or a cash amount equal to the value of the index) at the exercise price. The amount of a premium received or paid for an option is based upon certain factors, including the market price of the underlying security, the relationship of the exercise price to the market price, the historical price volatility of the underlying security, the option period, and interest rates. Government and Agency Mortgage-Backed Securities The principal issuers or guarantors of mortgage-backed securities are the Government National Mortgage Association (“GNMA”), Fannie Mae (“FNMA”), and the Federal Home Loan Mortgage Corporation (“FHLMC”). GNMA, a wholly owned U.S. government corporation within the Department of Housing and Urban Development (“HUD”), creates pass-through securities from pools of government-guaranteed (Farmers’ Home Administration, Federal Housing Authority or Veterans Administration) mortgages. The principal and interest on GNMA pass-through securities are backed by the full faith and credit of the U.S. government. FNMA, which is a U.S. government-sponsored corporation owned entirely by private stockholders that is subject to regulation by the secretary of HUD, and FHLMC, a corporate instrumentality of the U.S. government, issue pass-through securities from pools of conventional and federally insured and/or guaranteed residential mortgages. FNMA guarantees full and timely payment of all interest and principal, and FHMLC guarantees timely payment of interest and ultimate collection of principal of its pass-through securities. Mortgage-backed securities from FNMA and FHLMC are not backed by the full faith and credit of the U.S. government.  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper, and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, Rothschild Investment may invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Mortgage-Backed Securities Mortgage-backed securities represent interests in a pool of mortgage loans originated by lenders such as commercial banks, savings associations, and mortgage bankers and brokers. Mortgage-backed securities may be issued by governmental or government-related entities, or by non-governmental entities such as special- purpose trusts created by commercial lenders. Pools of mortgages consist of whole mortgage loans or participations in mortgage loans. The majority of these loans are made to purchasers of between one and four family homes. The terms and characteristics of the mortgage instruments are generally uniform within a pool but may vary among pools. For example, in addition to fixed-rate, fixed-term mortgages, Rothschild Investment may purchase pools of adjustable-rate mortgages, growing equity mortgages, graduated payment mortgages and other types. Mortgage poolers apply qualification standards to lending institutions, which originate mortgages for the pools as well as credit standards and underwriting criteria for individual mortgages included in the pools. In addition, many mortgages included in pools are insured through private mortgage insurance companies. Mortgage-backed securities differ from other forms of fixed income securities, which normally provide for periodic payment of interest in fixed amounts with principal payments at maturity or on specified call dates. Most mortgage-backed securities, however, are pass-through securities, which means that investors receive payments consisting of a pro rata share of both principal and interest (less servicing and other fees), as well as unscheduled prepayments as loans in the underlying mortgage pool are paid off by the borrowers. Additional prepayments to holders of these securities are caused by prepayments resulting from the sale or foreclosure of the underlying property or refinancing of the underlying loans. As prepayment rates of individual pools of mortgage loans vary widely, it is not possible to accurately predict the average life of a particular mortgage- backed security. Although mortgage-backed securities are issued with stated maturities of up to 40 years, unscheduled or early payments of principal and interest on the mortgages may shorten considerably the securities’ effective maturities. Collateralized Obligations Collateralized mortgage obligations (“CMOs”) are collateralized by mortgage-backed securities issued by GNMA, FHLMC or FNMA (“mortgage assets”). CMOs are multiple-class debt obligations. Payments of principal and interest on the mortgage assets are passed through to the holders of the CMOs as they are received, although certain classes (often referred to as “tranches”) of CMOs have priority over other classes with respect to the receipt of mortgage prepayments. Each tranche is issued at a specific or floating coupon rate and has a stated maturity or final distribution date. Interest is paid or accrues in all tranches on a monthly, quarterly, or semi-annual basis. Payments of principal and interest on mortgage assets are commonly applied to the tranches in the order of their respective maturities or final distribution dates, so that generally no payment of  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss principal will be made on any tranche until all other tranches with earlier stated maturity or distribution dates have been paid in full. Collateralized debt obligations (“CDOs”) include collateralized bond obligations (“CBOs”), collateralized loan obligations (“CLOs”), and other similarly structured securities. CBOs and CLOs are types of asset-backed securities. A CBO is a trust that is backed by a diversified pool of high-risk, below-investment-grade fixed income securities. A CLO is a trust typically collateralized by a pool of loans, which may include, among others, domestic and foreign senior secured loans, senior unsecured loans, and subordinate corporate loans, including loans that may be rated below investment grade or equivalent unrated loans. B. Investment Strategy and Method of Analysis Material Risks Leverage Although Rothschild Investment, as a general business practice, does not utilize leverage, there may be instances in which exchange-traded funds, other separate account managers and, in very limited circumstances, Rothschild Investment will utilize leverage. In this regard, please review the following: The use of leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So, if the price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. The use of leverage entails borrowing which results in additional interest costs to the investor. Broker-dealers who carry customer accounts have a minimum equity requirement when clients utilize leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. Short-Term Trading Although Rothschild Investment, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. Option Strategies Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Each contract is worth 100 shares of the underlying security. Options entail greater risk but allow an investor to have market exposure to a particular security or group of securities without  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss the capital commitment required to purchase the underlying security or groups of securities. In addition, options allow investors to hedge security positions held in the portfolio. For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. Rothschild Investment as part of its investment strategy may employ the following strategies: ▪ Covered call writing ▪ Long call options purchases ▪ Long put options purchases ▪ Option spreading ▪ Short call option strategy ▪ Short put option strategy ▪ Equity collars ▪ Long straddles Covered Call Writing Covered call writing is the sale of in-, at-, or out-of-the money call option against a long security position held in the client portfolio. This type of transaction is used to generate income. It also serves to create downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced to the extent it is necessary to buy back the option position prior to its expiration. This strategy may involve a degree of trading velocity, transaction costs, and significant losses if the underlying security has volatile price movement. Covered call strategies are generally suited for companies with little price volatility. Long Call Option Purchases Long call option purchases allow the option holder to be exposed to the general market characteristics of a security without the outlay of capital necessary to own the security. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Long Put Option Purchases Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long put option increases. In this way long puts are often used to hedge a long stock position. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Option Spreading Option spreading usually involves the purchase of a call option and the sale of a call option at a higher contract strike price, both having the same expiration month. The purpose of this type of transaction is to allow the holder to be exposed to the general market characteristics of a security without the outlay of capital to own the security, and to offset the cost by selling the call option with a higher contract strike price. In this type of transaction, the spread holder “locks in” a maximum profit, defined as the difference in contract prices reduced by the net cost of implementing the spread. There are many variations of option spreading strategies; please  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss contact the Options Clearing Corporation for a current Options Risk Disclosure Statement that discusses each of these strategies. Short Call Option Strategy Short call option strategy is highly speculative and has theoretical potential for unlimited loss. The seller (writer) of the call option receives proceeds (premium) from the sale of the option. The expectation is that the value of the underlying security will remain below the contract strike price and the option will expire worthless, allowing the option writer to keep the entire amount of the sale proceeds (premium). Should the value of the underlying security increase above the contract strike price, then the option writer can either purchase the call option at a loss, or through a process of exercise and assignment be forced to sell the stock at the contract strike price. If this happens, the option writer will have to go in the open market and buy an equivalent amount of stock to cover the sale at prices that can be materially higher than the amount received from the sale. Short Put Option Strategy Short put option strategy is highly speculative and has theoretical potential for significant loss. The seller (writer) of the put option receives proceeds (premium) from the sale of the option. The expectation is that the value of the underlying security will remain above the contract strike price and the option will expire worthless, allowing the option writer to keep the entire amount of the sale proceeds (premium). Should the value of the underlying security decrease below the contract strike price, the option writer can either purchase the put option at a loss, or through a process of exercise and assignment be forced to buy the stock at the contract strike price. If this happens, the option writer will be purchasing the underlying security at a price potentially well above its then-current market value, exposing the investor to potential loss. Equity Collar A collar combines both a cap and a floor. A cap gives the purchaser of the cap the right (for a premium payment), but not the obligation, to receive the difference in the cost on some amount when a specified index rises above the specified “cap rate.” A floor is the opposite of a cap—it gives the purchaser of the floor the right (for a premium payment), but not the obligation, to receive the difference in interest payable on an amount when a specified index falls below the specified “floor rate.” A collar involving stock is called an “equity collar.” In a collar transaction, the buyer of the collar purchases a cap while selling a floor indexed to the same rate or asset. A zero-cost collar results when the premium earned by selling a floor exactly offsets the cap premium. Long Straddle A long straddle is the purchase of a long call and a long put with the same underlying security, expiration date, and strike price. This is a speculative trade that may be profitable when volatility is high and will result in a loss when prices of the underlying security are relatively stable. C. Concentration Risk There is an inherent risk for clients whose investment portfolios lack diversification—that is, they have their investment portfolios heavily weighted in a specific investment style, security, industry or industry sector, geographic location, investment manager, type of investment instrument (equities versus fixed income). Clients, who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain but also offer the potential for significant loss.  Item 10: Other Financial Industry Activities and Affiliations Item 9: Disciplinary Information There are no current or pending disclosure items to report on behalf of Rothschild Investment. A. Criminal or Civil Actions There is nothing to report for this item. B. Administrative Enforcement Proceedings There is nothing to report for this item. C. Self-Regulatory Organization Enforcement Proceedings On September 13, 2021, Rothschild entered into a settlement (the “Order”) with the Securities and Exchange Commission (the “SEC”) relating to recommendations of mutual fund shares to its clients. Without admitting or denying the SEC’s findings, Rothschild consented to the entry of the Order which states that, as a result of the conduct described below, Rothschild violated Section 206(2) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which makes it unlawful for an investment adviser, directly or indirectly, to “engage in any transaction, practice or course of business which operates as a fraud or deceit upon any client or prospective client.” and Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, which require a registered investment adviser to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder. The SEC alleged that Rothschild breached its fiduciary duty to advisory clients by failing to disclose two types of compensation it received based on its advisory clients' investments and that Rothschild received fees as a result of client investments in certain mutual fund shares - specifically 12b-1 fees and revenue sharing payments from an unaffiliated clearing broker as a result of sweeping Rothschild's advisory clients' cash into certain money market mutual funds. The SEC alleged that various investments that resulted in 12b-1 fees or revenue sharing payments were generally more expensive than lower cost options available to clients, and made related allegations of failure to seek best execution related to same and failure to consider alternative funds with similar strategies that might have been less costly. Additionally, the SEC alleged that Rothschild failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund and cash sweep money market fund selection practices and its disclosure of the associated conflicts of interest. The Order requires Rothschild to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder; censures Rothschild; requires Rothschild to pay disgorgement of $1,885,360.59 and prejudgment interest of $186,306.41 to compensate advisory clients who were affected by certain conduct detailed in the Order; and requires Rothschild to pay a civil monetary penalty in the amount of $400,000. Additional information regarding Rothschild or its IARs is available on the SEC’s website at www.advisorinfo.sec.gov or www.finra.org/brokercheck. Rothschild’s CRD number is 728.  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Rothschild Investment is dually-registered as a broker-dealer. Most Rothschild Investment professionals are registered representatives of RI. As a result, such professionals are subject to the oversight of RI and the Financial Industry Regulatory Authority, Inc. (“FINRA”). As such, clients of Rothschild Investment should understand that their personal and account information is available to FINRA and RI personnel in the fulfillment of their oversight obligations and duties. Rothschild Investment professionals who effect transactions for advisory clients may receive transaction or commission compensation from RI. The recommendation of securities transactions for commission creates a conflict of interest in that Rothschild Investment is economically incented to effect securities transactions for clients. Although Rothschild Investment strives to put its clients’ interests first, such recommendations may be viewed as being in the best interests of Rothschild Investment rather than in the client’s best interest. Rothschild Investment advisory clients are not compelled to effect securities transactions through RI. B. Futures or Commodity Registration Neither Rothschild Investment nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator, or commodity trading adviser and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Broker-Dealer Activities Please see Item 10.A. above. Dual Registration as Registered Representatives Most Rothschild Investment professionals are dually registered as broker-dealer registered representatives. As a result, such professionals are economically incented to recommend the adviser platform that yields the highest economic benefit to themselves. Please discuss with your financial advisor whether the services can be provided through the platform that is more financially advantageous to the client. Rothschild Investment, LLC and Rothschild Wealth, LLC are affiliates and collectively referred to as Rothschild Wealth Partners. Rothschild Wealth, LLC is an SEC registered investment advisor and is under common control with Rothschild Investment, LLC. Sentinus Insurance Services Sentinus Insurance Services (“SIS”) is an affiliate that is utilized for the sales of insurance products. Certain managers, members, and registered employees of Rothschild Investment are agents for certain insurance carriers. With respect to the provision of financial planning services, Rothschild Investment professionals may recommend insurance products offered by such carriers for whom they function as agents and receive a commission for doing so. These insurance sales are placed through SIS. Clients are advised that there is a conflict of interest in that there is an economic incentive to recommend insurance and other investment products of such carriers. Clients are also advised that Rothschild Investment professionals strive to put their clients’ interests first and foremost. Other than for insurance products that require a securities license, such as variable insurance products, clients  Item 10: Other Financial Industry Activities and Affiliations are not required to utilize SIS for insurance products and may utilize any insurance carrier or insurance agency they desire. Proprietary Private Fund Rothschild Investment is the investment manager for an affiliate private fund. Investment advisory clients of Rothschild Investment may be solicited to invest in the fund. A conflict of interest arises in that there is an economic incentive for Rothschild Investment to solicit clients to invest directly in the fund versus a separately managed account. Rothschild Investment receives a performance fee allocation as disclosed in the Fund’s offering documents. Performance-based fees may (i) create an incentive for the investment manager to incur trading and strategy risks that may conflict with an investor's risk tolerance and investment objectives, (ii) create an incentive to allocate more time to the management of the Fund, and (iii) create an incentive to allocate favorable investment allocations to the Fund. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest Rothschild Investment may engage sub-advisers to manage all or a portion of the client's assets. Rothschild Investment’s fees are in addition to the sub-advisers it utilizes. Rothschild Investment will always act in the best interests of the client, including when determining which sub-advisers to recommend and/or utilize for clients. Clients are under no obligation to use any third-party provider recommended by Rothschild Investment and may use the provider of their choice. The firm may enter into arrangements with promoters who will promote the advisory firm for compensation. The receipt of such compensation creates a conflict of interest in that the promoter is economically incented to promote our firm. See Item 14 of this Brochure for additional disclosure.  Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, Rothschild Investment has adopted policies and procedures designed to detect and prevent insider trading. In addition, Rothschild Investment has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of Rothschild Investment’s advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the Chief Compliance Officer of Rothschild Investment. Rothschild Investment will send clients a copy of its Code of Ethics upon written request. Rothschild Investment has policies and procedures in place to ensure that the interests of its clients are given preference over those of Rothschild Investment, its affiliates, and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Rothschild Investment recommends, provides advice on, and manages a proprietary investment product. Rothschild Investment does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Rothschild Investment, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may purchase the same securities as are purchased for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which Rothschild Investment specifically prohibits. Rothschild Investment has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest, ▪ prohibit front-running, and ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow Rothschild Investment’s procedures when purchasing or selling the same securities purchased or sold for the client.  Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Rothschild Investment, its affiliates, employees, and related persons may buy or sell securities for their own accounts that are also recommended to or purchased or sold for clients. This creates a conflict of interest, as such persons may have an incentive to trade for their own accounts ahead of client transactions or receive more favorable execution. Rothschild Investment has adopted policies and procedures designed to ensure that client transactions are given priority over transactions for affiliated, employee, or related accounts. In general, trades for client accounts are executed in a manner intended to be fair and equitable over time. When trades are executed on the same day, transactions may be subject to an average pricing allocation. It is the policy of Rothschild Investment to place client interests ahead of its own and those of its employees. Rothschild may, at times, effect agency cross-transactions for advisory clients, provided that such transactions are consistent with the firm’s fiduciary duty and comply with Rule 206(3)-2 under the Investment Advisers Act of 1940. An agency cross-transaction occurs when Rothschild, or an affiliated person, acts as broker for both the advisory client and another party to the transaction. Clients will receive appropriate disclosures and consents, as required, prior to the execution of such transactions.  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations Rothschild Investment does not maintain custody of client assets that we manage, although we may be deemed to have custody of your assets if the client gives us authority to withdraw assets from the client’s account (see Item 15: Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Pershing LLC, Charles Schwab & Co., Inc., or SEI (hereinafter collectively referred to as “custodian”), FINRA-registered broker-dealers, members SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with the custodian. The custodian will hold client assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that clients use one of the above-named custodians, the client will decide whether to do so and will open their account with the custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14: Client Referrals and Other Compensation. Clients should consider these conflicts of interest when selecting their custodian. We do not open the account for the client, although we may assist in doing so. Even though your account is maintained at the custodian, and we anticipate that most trades will be executed through the custodian, we can still use other brokers to execute trades for the client’s account as described below (see "Your Brokerage and Custody Costs"). Soft Dollar Arrangements Rothschild Investment does not utilize soft dollar arrangements. Rothschild Investment does not direct brokerage transactions to executing brokers for research and brokerage services. How We Select Brokers/Custodians We recommend the above-mentioned custodians to hold client assets and execute transactions. When considering whether the terms that the custodian provides are, overall, most advantageous to the client when compared with other available providers and their services, we take into account a wide range of factors, including: ▪ Combination of transaction execution services and asset custody services (generally without a separate fee for custody) ▪ Capability to execute, clear, and settle trades (buy and sell securities for your account) ▪ Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ▪ Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) ▪ Availability of investment research and tools that assist us in making investment decisions ▪ Quality of services  Item 12: Brokerage Practices ▪ Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices ▪ Reputation, financial strength, security, and stability ▪ Prior service to us and our clients ▪ Services delivered or paid for by the custodian ▪ Availability of other products and services that benefit us, as discussed below (see "Products and Services Available to Us from Custodian") Your Brokerage and Custody Costs For our clients' accounts that the custodian maintains, the custodian generally does not charge the client separately for custody services but is compensated by charging the client either transaction fees or custodian asset-based fees on trades that it executes or that settle into the client’s custodial account. Certain trades (for example, mutual funds and ETFs) do not incur custodian commissions or transaction fees. The custodian may also be compensated by earning interest on the uninvested cash in client accounts. The custodian’s commission rates and asset-based fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a certain minimum amount of client assets at the custodian. This commitment benefits the client because the overall commission rates you pay are lower than would be otherwise. In addition to commissions or asset-based fees, the custodian 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 clients’ custodial accounts. These fees are in addition to the commissions or other compensation clients pay the executing broker-dealer. Because of this, in order to minimize client trading costs, we have the custodian execute most trades for client accounts. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian, we have determined that having the custodian execute most trades is consistent with our duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How we select brokers/custodians"). By using another broker or dealer, clients may pay lower transaction costs. Products and Services Available to Us from the Custodian The custodian provides us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to the custodian’s retail customers. However, certain retail investors may be able to get institutional brokerage services from the custodian without going through us. The custodian also makes available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. Schwab's support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed description of the custodian’s support services: Services that benefit you. The 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 the custodian include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The custodian’s services described in this paragraph generally benefit our clients and their accounts.  Item 12: Brokerage Practices Services that do not directly benefit you. The custodian also makes available to us other products and services that benefit us but do not directly benefit our clients or their accounts. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. We use this research to service all or a substantial number of our clients' accounts, including accounts not maintained at the custodian. In addition to investment research, the custodian may also make available software and other technology that: ▪ Provide access to client account data (such as duplicate trade confirmations and account statements) ▪ Facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ Provide pricing and other market data ▪ Facilitate payment of our fees from our clients' accounts ▪ Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. The custodian also offers other services intended to help us manage and further develop our business enterprise. These services may include: ▪ Educational conferences and events ▪ Consulting on technology and business needs ▪ Consulting on legal and compliance related 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 The custodian may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. The custodian also discounts or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian may also pay for business consulting and professional services received by Rothschild Investment’s related persons, and may pay or reimburse expenses (including client transition expenses, travel, lodging, meals and entertainment expenses for Rothschild Investment personnel to attend conferences). If you did not maintain your account with Schwab, we would be required to pay for those services from our own resources. Our Interest in the Custodian’s Services The availability of these services from the custodian benefits us because we do not have to produce or purchase them. We don't have to pay for the custodian’s services. The custodian has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients' assets in accounts at the custodian reaches certain thresholds. The fact that we receive these benefits from the custodian is an incentive for us to recommend the use of the custodian rather than making such a decision based exclusively on our clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of the custodian as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of the custodian’s services (see "How we select brokers/ custodians") and not the custodian's services that benefit only us.  Item 12: Brokerage Practices Brokerage for Client Referrals Rothschild Investment does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage Rothschild Investment Recommendations Rothschild Investment typically recommends Pershing, Schwab, or Fidelity as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. Client-Directed Brokerage Occasionally, clients may direct Rothschild Investment to use a particular broker-dealer to execute portfolio transactions for their accounts or request that certain types of securities not be purchased for their accounts. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage Rothschild Investment derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. Rothschild Investment loses the ability to aggregate trades with other Rothschild Investment advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts Best Execution Rothschild Investment may recommend that clients establish brokerage accounts with its primary custodians to maintain custody of clients’ assets and to effect trades for their accounts. Such accounts will be prime broker eligible so that if and when the need arises to effect securities transactions at broker-dealers ("executing brokers") other than with the client’s current custodian, such custodian will accept delivery or deliver the applicable security from/to the executing broker. Custodians charge a “trade away” fee which is charged against the client account for each trade away occurrence. Other custodians have their own policies concerning prime broker accounts and trade away fees. Clients are directed to consult their current custodian for their policies and fees. Rothschild Investment, pursuant to the terms of its investment advisory agreement with clients, may have discretionary authority to determine which securities are to be bought and sold the amount of such securities, the executing broker, and the commission rates to be paid to effect such transactions.. Rothschild Investment recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. Rothschild Investment will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation, and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance, and settlement  Item 12: Brokerage Practices ▪ Block trading and positioning capabilities ▪ Performance measurement ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, Rothschild Investment seeks to ensure that clients receive best execution with respect to the clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of Rothschild Investment’s knowledge, these custodians provide high-quality execution, and Rothschild Investment’s clients do not pay higher transaction costs in return for such execution. Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, Rothschild Investment believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Security Allocation Since Rothschild Investment may be managing accounts with similar investment objectives, the firm may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by Rothschild Investment in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. Rothschild Investment’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account the clients’ best interests. Rothschild Investment will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. Rothschild Investment’s advice to certain clients and entities and the actions of Rothschild Investment for those and other clients are frequently premised not only on the merits of a particular investment but also on the suitability of that investment for the particular client in light of his or her applicable investment objectives, guidelines, and circumstances. Thus, any action of Rothschild Investment with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice, or actions of Rothschild Investment to or on behalf of other clients. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended duration exposure. All clients participating in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions.  Item 12: Brokerage Practices To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if Rothschild Investment believes that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the order, taking into account all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs, and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” Rothschild Investment acts in accordance with its duty to seek best price and execution and will not continue any arrangements if it determines that such arrangements are no longer in the best interests of its clients.  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved The review of accounts of high-net-worth and affluent clients, including corporations, partnerships and trusts, are conducted in the first instance by the investment adviser representative servicing the client relationship on at least an annual basis. Such professionals are subject to the general authority of Rothschild Investment’s Managing Member. The Managing Member or his designee(s) must review and approve the opening of each new advisory relationship and oversee reviews of client accounts. The Managing Member or his designee(s) is also responsible for ensuring that any significant change in a client's investment strategy or in the concentration of a client's assets is appropriate for and has been reviewed with the client. The fund is managed in accordance with the terms of the fund’s offering documents. B. Review of Client Accounts on Non-Periodic Basis Rothschild Investment’s investment adviser representatives may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how Rothschild Investment formulates investment advice. For fund clients, Rothschild Investment’s portfolio manager may perform ad hoc reviews on an as-needed basis if there have been material changes in the fund’s investment objectives or investment strategies, economic or market outlook. C. Content of Client-Provided Reports and Frequency Rothschild Investment reports to the client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). For investment advisory clients, the client’s independent custodian provides account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by Rothschild Investment. Financial planning clients receive written reports pursuant to the terms of their financial planning agreement. For the private fund, please refer to the offering documents for more information.  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Economic Benefits Received from Custodians We receive an economic benefit from the custodian in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at the custodian. In addition, the custodian has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients' assets in accounts at the custodian reaches a certain size. Clients do not pay more for assets maintained at the custodian as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. Clients should consider these conflicts of interest when selecting a custodian. The products and services provided by the custodian, how they benefit us, and the related conflicts of interest are described above (see Item 12: Brokerage Practices). Referral Fees for Recommending Investment Managers Rothschild Investment may refer clients to certain investment management firms in return for an ongoing portion of the advisory fee received by such investment manager. All such arrangements are in compliance with Investment Advisers Act rule 206(4)-3. Generally, these requirements require the solicitor, Rothschild Investment, to have a written agreement with the investment management firm. Rothschild Investment must provide the client with a disclosure document describing the fees it receives from the investment management firm, whether those fees represent an increase in fees that the investment management firm would otherwise charge the client, and whether an affiliation exists between Rothschild Investment and the investment management firm. B. Advisory Firm Payments for Client Referrals Rothschild Investment may enter into arrangements with promoters, endorsers, solicitors, or with clients for testimonials (herein collectively referred to as “promoter”) who will promote the advisory firm for compensation. Agreements are required when compensation to the promoter is equal to or greater than $1,000. The receipt of such compensation creates a conflict of interest in that the promoter is economically incented to promote our firm. Please be advised that the firm’s payment of compensation to the promoter does not increase the client’s advisory fee paid to the firm.  Item 15: Custody Item 15: Custody Rothschild Investment is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. The custodian maintains actual custody of clients’ assets. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first- party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ▪ The firm or its affiliate is a managing member or general partner to a private fund vehicle. An independent public accountant performs a surprise custody exam for pooled investment vehicles because the pooled investment vehicle maintains its securities with a qualified custodian, and does not obtain an annual financial audit. . Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. Clients are urged to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account.  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to Rothschild Investment with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In such cases, Rothschild Investment will exercise full discretion as to the nature and type of securities to be purchased and sold, the amount of securities for such transactions, the executing broker to be used, and the amount of commissions to be paid. Investment limitations may be designated by the client as outlined in the investment advisory agreement. In addition, subject to the terms of its investment advisory agreement, Rothschild Investment may be granted discretionary authority for the retention of independent third-party sub-advisers. Please see the applicable third-party sub-adviser’s disclosure brochure for detailed information relating to discretionary authority. With respect to its proprietary fund, Rothschild Investment has full discretionary authority as to the management of the fund.  Item 17: Voting Client Securities Item 17: Voting Client Securities Rothschild Investment does not take discretion with respect to voting proxies on behalf of its clients. Rothschild Investment will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election, or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of Rothschild Investment supervised and/or managed assets. In no event will Rothschild Investment take discretion with respect to voting proxies on behalf of its clients. Except as required by applicable law, Rothschild Investment will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Rothschild Investment has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. Rothschild Investment also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Rothschild Investment has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Rothschild Investment receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner.  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet Rothschild Investment does not require the prepayment of fees of $1,200 or more, six months or more in advance, and as such it is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Rothschild Investment does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report for this item.