ROTHSCHILD INVESTMENT LLC

Form ADV Part 2A Firm Brochure  Cover Page Item 1: Cover Page Form ADV Part 2A Firm Brochure Rothschild Investment LLC September 11, 2025 SEC File No. 8 0 1 - 7 3 9 5 3 1 1 S. W a cke r Drive Suite 5 9 0 0 Chica g o, Illinois 6 0 6 0 6 P hone: 3 1 2.9 8 3.8900 info@roths child w e a lth.com w w w .roths child w e a lth.com This b roch ure p rovid e s in form a tion a b out th e q ua lifica tions a nd b us ine s s p ra ctice s of Roths child Inve s tm e n t LLC (“Roths child ”). If you ha ve a n y q ue s tion s a b out th e con te nts of this b rochure , p le a s e con ta ct Curtis Elle rg od t, Chie f Fin a ncia l Office r a nd Chie f Com p lia nce Office r, a t 3 1 2 - 9 8 3 - 8 90 0 or ce lle rg od t@roth s child w e a lth.com . Th e inform a tion in this b rochure ha s n ot b e e n a p p rove d or ve rifie d b y th e Unite d Sta te s Se curitie s a nd Excha ng e Com m is s ion (“SEC”) or b y a ny s ta te s e curitie s a uth ority. Ad d itiona l in form a tion a b out Roths child is a ls o a va ila b le on th e SEC’s w e b s ite a t w w w .a d vis e rinfo.s e c.g ov. You ca n s e a rch the s ite b y firm n a m e or b y our Firm ’s CRD num b e r: 7 2 8 .  Material Changes Item 2: Material Changes This section provides an overview of material changes to Rothschild Investment, (“RI”) brochure listed below. The last annual update was made 3/31/2025 with an other - than - annual update made on 4/28/2025. We will ensure that clients receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. Furthermore, we will provide clients with other interim disclosures about material changes as necessary. The list below summarizes the material changes made on 3/31/2025 and 4/28/2025,. • The firm ha s a n a ffilia te re g is tered inves tm ent a d vis or, Roths child W ea lth, LLC (“RW ”) Certa in Roth s child Inves tm net p rofes s iona ls a re d ua lly reg is tered w ith RW . Plea s e s e e Item s 5 a nd 1 0 of this b rochure for m ore inform a tion a nd rela ted conflicts of interes t. • The firm s ells Ins ura nce p rod ucts a nd ha s a n a ffilia te ins ura nce a g ency, Sentin us Ins ura nce Services , LLC • Roth s child Inves tm ent Corp ora tion cha ng ed the leg a l na m e to Roths child Inves tm ent, LLC • Roth s child Inves tm ent d oe s not cha rg e p e rform a nce - b a s ed fees . Plea s e s ee Ite m s 4 a nd 6 of this b rochure for m ore inform a tion. Item 1 3 ha s b een correcte d to reflect Mr. Curtis Ellerg od t a s the Chief Com p lia nce Office r. • Ad d itiona lly, a lthoug h not m a teria l, certa in d is clos ures w ere cla rified or m od ified throug h out this b rochure in a ccord a nce w ith evolving ind us try a nd firm p ra ctices .  Table of Contents Item 3. Table of Contents Item 1. Cover Page ………………………………………………………………………………… 2 Item 2. Material Changes………………………………………………………………………… Item 3. Table of Contents ……………………………………………………………………… 4 Item 4 . Ad vis ory Bus ine s s ....................................................................................................... 5 Item 5 . Fees & Com p ens a tion ................................................................................................ 8 Item 6 . Perform a nce- Ba s e d Fees a nd Sid e- b y- Sid e Ma na g em ent ..................... 1 1 Item 7 . Typ es of Clients ......................................................................................................... 1 3 Item 8 . Method s of Ana yls is , Stra teg ie s & Ris k of Los s ............................................ 1 3 Item 9 . Dis cip lina ry Inform a tion......................................................................................... 1 3 Item 1 0 . Other Fina ncia l Ind us try Activities & Affilia tions ....................................... 1 7 Item 1 1 . Cod e of Ethics , P a rticip a tion, or Interes t In Client Tra ns a ction s & Pers ona l Tra d ing ..................................................................................................................... 1 9 Item 1 2 . Brokera g e P ra ctices ............................................................................................. 2 1 Item 1 3 . Revie w of Accounts .............................................................................................. 2 4 Item 1 4 . Client Referra ls & Other Com p ens a tion ........................................................ 2 5 Item 1 5 . Cus tod y ..................................................................................................................... 2 6 Item 1 6 . Inves tm ent Dis cre tion .......................................................................................... 2 7 Item 1 7 . Voting Client Securities ....................................................................................... 2 8 Item 1 8 . Fina ncia l Inform a tion ........................................................................................... 2 9  Advisory Business Item 4. Advisory Business - term commitment to working with entrepreneurs and their ommitment to service and the act. Registration with the SEC or any state securities authority does not - ority, Inc. (“FINRA”) in that capacity. 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 cate rs to the corporate needs of the closely held business and the personal needs of its owners. Rothschild has made a long special investment requirements. The longevity of the Firm is testimony to our c implementation of a successful long - term investment philosophy. Rothschild specializes in providing highly personalized asset management services for clients. Each account is individually structured and ongoing advice is provided. Rothschild is a registered investment adviser with the Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940 as amended (the “Advisers Act”). As a fiduciary, it adheres to and is bound by the terms and provisions of that imply a certain level of skill or training. Rothschild is also registered with the SEC and various states as a broker dealer and is a member of the Financial Industry Regulatory Auth Listed below are the Firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of the company): Rothschild Holdings LLC - income investments and to suggest suitable risk Our Philosophy Recognizing that investment goals and requirements may vary widely, we stress the importance of establishing meaningful long - term investment objectives for each of our clients. A thorough understanding of overall assets, contribution, and payout projections, in addition to client temperament, enables us to evaluate the relative importance of current income versus the potential for capital gains. We are then in a position to recommend an appropriate balance between equity and fixed parameters for portfolio investments. Our long - term objective is to establish a pattern of positive total return for our clients. We strive to achieve a combined rate of return sufficient to enhance, as well as protect, the real (inflation - adjusted) value of our clients’ assets. - of- return objectives. This requires both prudence and flexibility. General Approach A successful approach to investment management must ensure compliance with fiduciary standards while retaining the potential for meeting rate while maintaining meaningful quality standards for Prudence involves ongoing supervision of assets investment and diversification of investment risks. Changing market environments necessitates the ability to be flexibl e. Equity Selection iate and long - term economic trends and a reasonable iteria used in our We rely primarily on basic fundamental analysis in selecting equity investments. We actively seek new investment candidates that meet our quality and liquidity requirements. Effective equity selection depends largely upon thorough analysis of both intermed assessment of the relative attractiveness of various equity alternatives. An evaluation of future earnings, relative price - earnings ratios, and the consistency of historical results are examples of the cr selection process. Because over- diversification often leads to mediocre results, we concentrate our investments in the industry and market sectors we believe are most likely to benefit from anticipated economic developments. - riding concern in structuring a bond - Fixed Income Selection In today’s environment of frequent and sometimes dramatic changes in the level and direction of interest rates, some traditional fixed - income strategies are no longer effective. Our over portfolio is protection of princ ipal. Therefore, we will normally construct portfolios comprised of laddered, short term to intermediate - term investment grade fixed income securities to protect against interest rate risk and credit risk.  Advisory Business s. We develop the client’s personal investment policy and create and - gathering process, we determine the client’s iate, we also review and - discretionary basis. Account supervision is Investment Advisory Services Our Firm provides ongoing advice to clients regarding the investment of their funds based on their individual needs. Through personal discussions with the client, investment goals and objectives are established based on the client’s particular circumstance manage a portfolio based on that policy. During our data individual objectives, time horizons, risk tolerance, and liquidity needs. As appropr discuss the client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non guided by the client’s stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations. - Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker dealer (or insurance company, if applicable) and will generally include advice regarding the following securities: • Excha ng e- lis ted s ecuritie s • Securities tra d ed over- the - counter • Foreig n is s uers • W a rra nts • Corp ora te d eb t s ecurities (other tha n com m ercia l p a p er) • Com m e rcia l p a p er • Certifica te s of d ep os it • Municip a l s ecuritie s • Va ria b le a nnuities (if a p p lica b le) • Mutua l fund s ha res • United Sta tes g overnm enta l s ecurities • Op tions contra cts on s e curities typ e s of inves tm ents involve certa in a d d itiona l d eg rees of Beca us e s om e ris k, Roth s child w ill im p lem ent/recom m end th em only w hen cons is tent w ith the client’s level of s op his tica tion a s w ell a s s ta ted inves tm ent ob jectives , tole ra nce for ris k, liq uid ity, a nd s uita b ility. Retirement Plan Consulting Services W e ca n a ls o p rovid e Retirem ent Pla n Cons ulting Se rvices a s s ta nd - a lone s ervices or a long s id e our tra d itiona l a d vis ory s e rvice s . Retirem ent Cons ulting Services a re com p ris ed of four d is tin ct s e rvice s . Clients m a y ch oos e to us e a ny or a ll of thes e s ervice s . Investment Policy Statement Preparation (hereinafter referred to as ‘‘IPS’’): W e g enera lly m eet w ith the client to help d e term ine a n a p p rop ria te inves tm ent s tra teg y tha t refle cts th e p la n s p ons or’s s ta ted inves tm ent ob jectives for m a na g em en t of the overa ll p la n. Our Firm a s s is ts w ith the p rep a ra tion of a w ritten IPS d eta iling thos e ne ed s a nd g oa ls . The IPS a ls o m a y lis t the criteria for s ele ction of inve s tm ent vehicles a s w ell a s the p roced ures a nd tim ing interva l tha t a s s is t the client in m onitoring inves tm ent p erform a nce of the p la n. Selection of Investment Options: W e g enera lly a s s is t p la n s p ons ors in cons tructing a n a p p rop ria te inves tm ent m ix. W e w ill then help re view va rious m utua l fund s (b oth ind ex a nd m a na g ed ) to help the client d ete rm ine w hich inves tm ents a re a p p rop ria te to im p lem ent, cons is tent w ith the client’s IPS. The client d eterm ines the num b er of inve s tm ent op tions to offe r ins id e a p la n. Monitoring of Investment Performance: W e g enera lly a s s is t the client in m on itoring the p la n’s inve s tm ents . Althoug h our Firm is not involved in the p urcha s e or s a le of thes e inves tm ents , w e typ ica lly help the client s up ervis e the p la n a nd m a ke recom m end a tions to th e client a s m a rket fa ctors a nd the client’s need s d icta te . .  Advisory Business account ( self- directed plans’’), we will upon request also in ERISA Employee Communications: For pension, profit sharing and 401(k) plan clients where individual plan participants exercise control over assets in their own provide quarterly educational support and investment seminars designed for the plan participants. Rothschild and the client determine the nature of the topics to be covered under the guidelines established Section 404(c). Amount of Managed Assets As of 12/31/ 2024 , we were actively managing $ 2,280,060,353 of clients’ assets on a discretionary basis plus $30,855,228 of clients’ assets on a non - discretionary basis.  Fees & Compensation Item 5. Fees & Compensation Our fees for Investment Advisory Services and Retirement Plan Consulting Services are presented separately below. Investment Advisory Services Our annual fees for Investment Advisory Services are based upon a percentage of assets under management and range from 0.25% to 1.50% per annum. Management fees are generally charged monthly or quarterly in advance, as outlined in the Investment Advisory S ervices Agreement. Clients direct whether management fees are to be debited directly from their accounts or billed separately. Fees may vary based upon account circumstances. Our standard Investment Advisory Fee Schedule is shown below: $ 3 ,0 0 0 ,0 0 0 $ 4 ,0 0 0 ,0 0 0 • 1 .2 5 % p er a nnum on the firs t • 1 % p er a nnum on the next • 3 /4 of 1 % p er a nnum on the next $ 8 ,0 0 0 ,0 0 0 • 1 /2 of 1 % p er a nnum on a nything over $ 1 5 ,0 0 0 ,0 0 0 • Lim ited Neg otia b ility of Ad vis ory Fees : Althoug h Roths child ha s es ta b lis hed the s ta nd a rd fee s ched ule reflected a b ove, w e reta in the d is cretion to neg otia te a lterna tive fees (b oth hig her a nd low er) on a client- b y- client b a s is . W e con s id er client fa cts , circum s ta n ce s , a nd need s in d ete rm ining the a p p lica b le fee s tructure. Thes e fa ctors includ e the com p lexity of the client a s s ets p la ced und er m a na g em ent, a nticip a ted future a d d itiona l a s s ets , rela ted a ccounts , p ortfolio s tyle, a nd a ccount com p os ition, a m ong others . The s p ecific a nnua l fee s ched ule is a g reed to in the contra ct b etw e en Roths child a nd ea ch client. W e m a y g roup certa in rela ted client a ccounts for th e p urp os es of a chieving a ccount s ize tiers for d eterm ining the a nnua lized fee (com m only ca lled “hous eh old ing ”). Perform a nce- Ba s ed Fees (includ es Conting ency- Ba s ed Fees ): Roths child d oes not cha rg e p erform a nce- b a s ed fees (s ee Item 6 ). Retirem ent Pla n Cons ultin g Service s Roth s child offers s evera l fee op tion s for Retirem ent Pla n Cons ulting Services . Roth s child m a y b e com p e ns a ted b a s ed on a n a nnua l p ercenta g e of p la n a s s ets for s ervices involving ong oing review s (s e e our fee s ch e d ule b elow ), or w e m a y b e com p ens a ted b y a n hourly fee or fixed fee (hourly fe e s ra ng e from $ 3 0 0 - $ 1 ,2 0 0 p er hour). Alterna tively, the s e d ifferent typ es of fee s m a y a ls o b e com b ined a s a p p rop ria te for the d ifferent typ es of s ervices req ue s ted b y the client. W here w e cha rg e a n a nn ua l a s s et- b a s ed fe e for Retirem ent Pla n Cons ulting Service s , the fee ra ng es from 0 .1 0 % to 1 .2 5 % of p la n a s s ets , d ep end ing on the s ervices req ues ted a nd the s ize of the p la n. Retirem ent Pla n Cons ulting Services fees a re cha rg ed m onthly or q ua rterly, in a d va nce, a s a g re ed to in the a p p rop ria te s e rvices a g reem ent. Fees m a y va ry b a s ed up on a ccount circum s ta nces . Our s ta nd a rd fe e s ched ule for Retire m ent Pla n Cons ulting Services is s how n b elow : Assets Under Management Annual Fee 0.75% 0.50% • under $1,000,000 1.25% • $1,000,000 to $5,000,000 1.00% • $5,000,001 to $10,000,000 • $10,000,001 to $25,000,000 • Over $25,000,000 Negotiable  Fees & Compensation 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 gistered representatives of Rothschild will Rothschild who provide services to the relevant plan(s) and are re 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. General Information Regarding Fees and Compensation Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days’ prior written notice. As disclosed above, advisory fees are paid in advance of the services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the relevant billing period. could invest in a mutual fund directly, - 1 or other distribution - related payments fo r a limited period of time Mutual Fund Fees: All fees paid to Rothschild for investment advisory services are charged in addition to the fees and expenses charged by mutual funds, ETFs, or other investment vehicles to their shareholders. These fees and expenses are described in the relevant prospectus or other disclosure document. These fees generally include management fees, operating expenses, and, in some cases, a distribution fee. If a fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client without our services. In that case, the client would not receive the services provided by our Firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appr opriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the underlying investment vehicles and our fees to fully understand the total amount of fees to be paid by the client, and to thereb y evaluate the advisory services being provided. In some limited circumstances (such as where a client brings an existing mutual fund position to a new advisory relationship), the Firm will receive and retain 12b (Rothschild will generally then either convert to a non - 12b - 1 share class, liquidate and reallocate the proceeds or exclude such assets from the advisory fee base). - dealers including, but not limited to, any representative effects Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses that may be charged by custodians and imposed by broker transaction charges imposed by a broke r- dealer through which an investment adviser transactions for the client’s account(s). Please refer to the “Brokerage Practices” section (Item 12) of this Form ADV for additional information. on to Rothschild when considering implementation of advisory - dealer with which to Certain members of our management personnel as well as certain investment adviser representatives and other related persons of our Firm are registered representatives of Rothschild in its capacity as a broker - dealer and /or and some may also be insurance licensed.. In these other capacities, these individuals can implement - based compensation (i.e., commissions, 12b - investment recommendations for advisory clients for transaction 1 fees, or other sales- related forms of compensation). This presents a conflict of interest to the extent that these individuals recommend that a client invest in a security that results in a commission being paid to Rothschild. Clients are not under any obligati recommendations. The implementation of any or all recommendations and the broker execute such recommendations is solely at the discretion of the client. - dealer (a portion of which is - ons for executing the relevant trades, but the Our clients ordinarily choose to pay for the services of their representative through either (i) advisory fees paid to us in our capacity as an investment adviser (a portion of which is paid to the representative), or (ii) transaction - based compensation pa id to us in our capacity as a registered broker paid to the representative). If a client that is subject to an advisory fee elects to use Rothschild as its broker dealer, Rothschild will receive its ordinary brokerage commissi client’s representative will not receive any portion of such brokerage compensation.  Fees & Compensation ve will receive a portion of the brokerage fees paid by such client and the In some cases, a Rothschild representative will refer a client that elects to use Rothschild as both the client’s broker and investment adviser to another Rothschild representative for portfolio management services in which event the referring representati portfolio manager will receive a portion of the advisory fees paid by such client. However, clients are under no obligation to use Rothschild as both broker and investment adviser. on payouts to investment adviser representatives acting as portfolio performance, and we make every effort to In order to minimize the potential conflict of interest between the Firm and its clients, Rothschild limits its broker - dealer activity to brokering trades and does not inventory securities for resale to clients. Furthermore, the Firm does not make commissi managers for security transactions conducted for advisory accounts that they are responsible for managing. We recognize that commission costs adversely affect investment keep these costs at a minimum. Revenue Code of 1986 (the “Code”), respectively. As such, our o avoid engaging in ERISA Accounts: Rothschild acts as a fiduciary to advisory clients that sponsor employee benefit plans or hold individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Firm is subject to specific duties and obligations under ERISA and the Code that include, among other things, restrictions concerning certain forms of compensation and business relationships. T prohibited transactions, Rothschild generally relies on one or more exemptions from the prohibited transaction rules. Therefore, all benefit plan clients that - affirm Because Rothschild is both a registered investment adviser and broker - dealer, a conflict exists where Rothschild acts as both investment adviser providing Investment Advisory Services and broker providing trade execution services for a benefit plan client. retain Rothschild to provide Investment Advisory Services and brokerage services are required to re annually their desire to have Rothschild act in both capacities. Advisory Fees in General: Clients should note that similar advisory services may be available from other investment advisers for similar or lower fees.  Performance-Based Fees and Side-by-Side Management Item 6. Performance-Based Fees and Side-by-Side Management Rothschild does not charge performance - based fees.  Types of Clients Item 7. Type of Clients Rothschild provides advisory services to the following types of clients: Ind ivid ua ls , fa m ilies , trus ts a nd es ta tes • • Hig h net w orth ind ivid ua ls • Pens ion a nd p rofit - s ha rin g p la ns , IRAs • Cha rita b le org a niza tions a nd found a tions • Corp ora tions or other b us ines s e s not lis ted a b ove Roth s child d oes n ot req uire a m inim um d olla r va lue of a s s ets or other cond ition s for op ening or m a inta ining a n a ccount for thes e typ e s of clients . In a d d ition to the typ es of clients d es crib ed a b ove, Roth s child a cts a s inves tm ent m a na g er to certa in p riva te p ooled inve s tm ent vehicle s s erving a s cond uit vehicles (ea ch, a “Cond uit Fund ”). Ea ch Cond uit Fund is a sp ecia l p urp os e entity (typ ica lly a lim ited p a rtners hip , limited lia b ility com p a ny or offs h ore com p a ny) form e d b y Roth s child for the s ole p urp os e of a g g reg a ting inves tor a s s ets to a s ing le entity a nd inves ting s uch a s s ets in a d es ig na ted und erlying fund , w hich is typ ica lly a priva te fund m a na g ed by a n una ffilia ted third - p a rty (the “Third - Pa rty Ma na g e rs ”). Thes e Third - Pa rty Ma na g ers em p loy a va riety of inves tm ent techniq ues a nd s tra te g ies , includ ing , b ut not lim ited to venture, p riva te eq uity, a nd hed g e fund s tra te g ies . Cond uit Fund s m a na g ed b y Roths child a re m a na g ed in a ccord a nce w ith ea ch vehicle's inves tm ent g uid e lines a nd res trictions a nd a re g enera lly not ta ilored to the ind ivid ua l need s of a ny pa rticula r inves tor. In its ca p a city a s inves tm ent m a na g er, Roth s child ’s p rincip a l s ervices con s is t of p rovid ing inves tm ent a d vice reg a rd ing the inves tm ent of the a s s ets of ea ch Fund a m ong p rofes s iona lly s elected inves tm e nt vehicles or a ccounts tha t a re m a na g ed b y the Third - Pa rty Ma na g ers , w hich a re s e lected throug h a d ue d ilig ence p roces s . W ith res p ect to Cond uit Fund s m a na g ed b y Roths child , the g enera l req uirem ents to inves t in p riva te fund s (q ua lifica tions , m inim um inves tm ent, etc.), a s w ell a s the a p p lica b le fees a n d exp ens es , a re s et forth in the releva nt offe ring or g overn ing d ocum ents (or in certa in ca s es , in s ep a ra te fe e a g reem ents b etw e en Roths child a nd the p riva te fund ’s inve s tors )  Methods of Analysis Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss We may use all or a combination of the following methods of analysis in formulating our investment advice and/or managing client assets: We attempt to measure the intrinsic value of a security by looking at economic and rpriced (indicating it may be a good Fundamental Analysis: financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is unde time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. to identify when the market (or security) is Technical Analysis : By analyzing past market movements and applying that analysis to the present, we attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. We may review charts of market and security activity in an attempt moving up or down and to predict how long the trend may last and when that trend might reverse. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. share and predict changes Quantitative Analysis : We may use mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. We evaluate non - quantifiable factors such as quality of management, labor relations, Qualitative Analysis: and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. We look at the experience and track record of the manager of the mutual Mutual Fund and/or ETF Analysis: fund or ETF to determine if that manager has demonstrated an ability to invest over a period of time and n a mutual fund or ETF to through different economic conditions. We also look at the underlying assets i determine if there is a significant overlap in the underlying investments held in other fund(s) in the client’s portfolio. We also monitor the funds or ETFs to determine if they are continuing to fo llow their stated investment strategy. The risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the investments in a fund or ETF, managers of different future. In addition, as we do not control the underlying funds held by the client may purchase the same security, increasing the risk to the client if that security were  Methods of Analysis to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. : Our securities analysis methods rely on the assumption that the companies curate and unbiased data. While we Risks for all forms of analysis whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing ac are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategy Our investment strategy employs a three - pronged approach: asset allocation, theme selection, and individual security selection. As mentioned previously, establishing meaningful long - term investment objectives for our clients is paramount to our investment strategy. Risk of Loss Securities investments are not guaranteed, and clients may lose money on their investments. We work with clients in helping them understand their tolerance for risk. There can be no guarantee that any particular client’s investment strategy will be successful or that clients will not suffer losses .  Disciplinary Information Item 9. Disciplinary Information , directly or indirectly, to - 7 thereunder, which require a 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 “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) registe red investment adviser to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder. received fees as a - specifically 12b - 1 fees and revenue sharing 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 result of client investments in certain mutual fund shares payments from an unaffiliated clearing broker as a result of sweeping Rothschild's advisory clients' cash into certain money market mutual funds. - 1 fees or revenue sharing payments were The SEC alleged that various investments that resulted in 12b generally more expensive than lower cost options available to clients, and made related allegations of failure failure to consider alternative funds with similar strategies that to seek best execution related to same and 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. - 7 promulgated thereunder; 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) censures Rothschild; requires Rothschild to pa y 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.  Other Financial Industry Activities & Affiliations O Item 10. Other Financial Industry Activities & Affiliations , our Firm is registered Firm Registrations : In addition to Rothschild being a n SEC registered investment adviser as a broker - dealer , member FINRA and SIPC. Registration with the Securities and Exchange Commission or any State or regulatory authority does not imply a certain level of skill or expertise. ly choose to pay for the services of their - dealer. However, as not ed Personnel Dual Registrations: Certain members of our management personnel as well as certain investment adviser representatives and other related persons of our Firm are licensed as registered representatives of Rothschild in their capacity as a broker dealer . Several of our employees are also insurance licensed . These individuals, in these other capacities, can effect securities and other financial services transactions for which they will receive transaction - based compensation. Our clients ordinari representative through either (i) advisory fees paid to us in our capacity as an investment adviser, or (ii) transaction - based compensation paid to us in our capacity as a registered broker above, in some cases a Rothschild representative will refer a client that elects to use Rothschild as both the client’s broker and investment adviser to another Rothschild representative for portfolio management services in which event the referring rep resentative will receive a portion of the brokerage fees paid by such client and the portfolio manager will receive a portion of the advisory fees paid by such client. Clients are under no obligation to use Rothschild as both broker and investment adviser. interest and may affect the judgment of these individuals when making - party administrators (“TPAs”) cular, to plan - party While Rothschild and these individuals endeavor at all times to put the interest of Third Party Administrators: the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of recommendatio ns. Management personnel of Rothschild work with various third who provide back - office support services to the sponsors of qualified retirement plans for a fee. In parti TPAs provide account recordkeeping services and a trading platform (via internet and telephone) by which plan participants may direct the investment of assets in their qualified plan accounts. TPAs may refer sponsors in need of advisory services to our Firm. Conversely, we may refer clients in need of third administrative services to various TPAs. All fee arrangements are disclosed to the plan sponsors. stees of pension, profit - sharing, 401(k), IRA or other ion provisions of the Code are solely Third - party administrative services provided by the TPA are separate and distinct from the advisory services we provide and are provided for separate and typical compensation. No advisory client is obligated to use a - party administrative services, and no client of any TPA is TPA recommended by Rothschild for any third obligated to utilize our advisory services. Sponsors or tru client accounts subject to the provisions of ERISA or the prohibited transact responsible for determining whether or not to engage the services of a particular TPA. Affiliations: 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. utilized for the sales of insurance products. Certain are agents for certain insurance carriers. With respect to the professionals strive to put their clients ' interest first and foremost . Clients Sentinus Insurance Services ("SIS") is an affiliate that is managers, members and registered employees 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. Insurance sales may be placed through SIS or other carriers. Clients are advised tha t 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 may utilize any insurance carrier or agency they desire.  Other Financial Industry Activities & Affiliations O Rothschild endeavors at all times to put the interests of its clients first as Clients should be aware that the receipt of additional compensation by Rothschild and its management persons or employees creates a conflict of interest that may impair the objectivity of our Firm and these individuals when making advisory recommendations. part of our fiduciary duty as a registered investment adviser. We take the following steps to address this conflict: • W e d is clos e to clients the exis tence of a ll m a teria l conflicts of interes t, includ ing w hen our Firm a nd our em p loyees ea rn a d d itiona l com p ens a tion from a d vis ory clients in a d d ition to our Firm ’s a d vis ory fee s • W e d is clos e to clients tha t they a re not ob lig a ted to follow our inves tm ent recom m end a tions , utilize our b roker- d ea ler s ervices or utilize our ins ura nce s ervice s • W e req uire tha t our em p loyees s e ek p rior a p p rova l of a ny outs id e b us ines s a ctivity s o tha t w e m a y ens ure tha t a ny conflicts of intere s t in s uch a ctivities a re p rop erly a d d res s ed • W e p eriod ica lly review a ll outs id e b us ines s a ctivities for our em p loye es to verify tha t a ny conflicts of interes t continue to b e p rop erly a d d res s ed b y our Firm ; a nd • W e ed uca te our em p loye es re g a rd ing the res p ons ib ilities of a fid ucia ry, includ ing the need for ha ving a rea s ona b le a nd ind ep end ent b a s is for the inve s tm e nt a d vice p rovid ed to clien t  Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading O Item 11. Code of Ethics, Participation, or Interest In Client Transactions & Personal Trading Our Firm has adopted a Code of Ethics which sets forth the high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. fairness, and good faith towards our clients, and have an Rothschild and our personnel owe a duty of loyalty, obligation to adhere not only to the specific provisions of the Code of Ethics but also to the general principles that guide the Code of Ethics. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the Firm’s access persons. Among other things, our Code of E thics also requires access persons to get the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our Code of Ethics also provides for oversight, enforcement, and recordkeeping prov isions. - public - public information, all Rothschild’s Code of Ethics further includes the Firm’s policy prohibiting the use of material non information. While we do not believe that we have any particular access to non employees are reminded that such information ma y not be used in a personal or professional capacity. - 983 - 8900, or by A copy of our Code of Ethics is available to our advisory clients and prospective clients, and may be requested by contacting Curtis Ellergodt, Chief Financial Officer and Chief Compliance Officer, at 312 email sent to cellergodt@rothschildinv.com . y client and for another person on - transaction for an advisory client, provided that the Rothschild may, at times, effect an agency cross transaction is consistent with our Firm’s fiduciary duty to the client and that all requirements outlined in SEC Rule 206(3) - 2 adopted under the Advisers Act are met. An agency cross - transaction is a transaction where our Firm acts as an investment adviser in relation to a transaction in which Rothschild, or any person controlled by or under common control with our Firm, acts as broker for both the advisor the other side of the transaction. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our Firm and/or individuals associated with our Firm may buy or sell securities for their personal accounts identical to or different from those recommended to our clients. In addition, related persons may have an interest or position in a certain security (ies) which may also be recommended to a client. It is the expressed policy of our Firm that no employee may purchase or sell any security prior to a transaction(s) being implemented for an advisory account (so - called frontrunning”), thereby preventing such employee(s) from benefiting from transactions p laced on behalf of advisory accounts.  Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading O -rata - may be included in the pro - rata However, we will aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients and employees will receive an average share price, and transaction costs (excluding commissions) will be shared on a pro basis. In the instances where there is a partial fill of an aggregated order, we will allocate all purchases pro rata, with each account paying the average price. Our employee accounts allocation. Rothschild personnel may invest in certain Conduit Funds if they meet the suitability requirements of the particular fund. To the extent that Rothschild personnel invest in a Conduit Fund, Rothschild may have an incentive to favor such fund over other Cond uit Funds in which Rothschild personnel are not invested. However, Rothschild believes that this risk is largely mitigated by the fact that Rothschild’s ability to influence the behavior of the underlying funds is limited to non - existent. vides our clients and potential clients with full and fair disclosure of such As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our Firm’s Code of Ethics to ensure our Firm complies with its regulatory obligations and pro conflicts of interest: • No p rincip a l or em p loye e of our Firm m a y p ut his or her ow n interes t a b ove the interes t of a n a d vis ory client. • • No p rincip a l or em p loyee of our Firm m a y b uy or s ell s ecuritie s for their p e rs ona l p ortfolio(s ) w here their d ecis ion is a res ult of inform a tion received a s a res ult of his or he r em p loym ent unle s s the inform a tion is a ls o a va ila b le to the inves ting p ub lic. It is the exp res s ed p olicy of our Firm tha t no em p loye e m a y p urcha s e or s ell a ny s ecurity p rior to a tra ns a ction (s ) b eing im p lem ented for a n a d vis ory a ccount (s o- ca lled frontrunning ”). This p revents s uch em p loyees from b en efiting from tra ns a ctions p la ced on b eha lf of a d vis ory a ccounts . • Our Firm req uires p rior a p p rova l for the p urcha s e of a ny IPO or p riva te p la cem ent inves tm ents b y a cces s p ers ons of th e Firm . • W e m a inta in a lis t of a ll rep orta b le s ecurities tra ns a ctions a nd hold ing s for our Firm a nd a nyone a s s ocia ted w ith this a d vis ory p ra ctice tha t ha s a cces s to a d vis ory recom m end a tions (“a cces s p ers on”). Thes e hold ing s a re revie w ed on a re g ula r b a s is b y our Firm ’s Chief Com p lia nce Officer or his /her d es ig nee. • W e ha ve e s ta b lis hed p roced ures for the m a intena nce of a ll req uired b ooks a nd record s . • All clients a re fully inform ed tha t rela ted p ers ons w ill receive s ep a ra te com m is s ion com p en s a tion • w hen effecting tra ns a ctions d uring the im p lem enta tion p roce s s . Clients ca n d ecline to im p lem ent a ny a d vice rend ered , excep t in s itua tions w here our Firm is m a na g ing a n a ccount on a b a s is . • All of our p rincip a ls a nd e m p loye es m us t a ct in a ccord a nce w ith a ll a p p lica b le Fed era l a nd Sta te s ta tute s a nd reg ula tions g overning reg is te red inves tm ent a d vis ers . • W e req uire d elive ry a nd a cknow led g em ent of the Cod e of Ethics b y ea ch s up ervis ed p ers on of our Firm . • W e ha ve es ta b lis h ed p olicies req uiring the rep orting of s us p ected or ob s erved Cod e of Ethics viola tions to our s enior m a na g em ent. • Any p rincip a l or em p loyee w ho viola tes a ny of th e a b ove res trictions is s ub je ct to d is cip line, up to a nd includ ing term ina tion of em p loym ent. As d is clos ed in the p reced ing s ection of this Broch ure (Item 1 0 ), certa in rela ted p ers ons of our Firm m a y b e s ep a ra tely reg is tered a s s ecurities rep re s enta tives a nd /or licens ed a s ins ura nce rep re s enta tives . Plea s e refer to Item 1 0 for im p orta nt conflict of interes t d is clos ures .  Brokerage Practices O Item 12. Brokerage Practices Custodians are selected for reasons such as client preference, ease of safekeeping of securities, inability to easily transfer assets, ease of processing trades, etc. Rothschild recommends the clearing and custody services of Pershing LLC. However, clients are free to choose custody arrangements with other brokerage firms (such as Charles Schwab and Fidelity), banks, and mutual fund companies. Rothschild is independently owned and has no affiliation with Pershing or any other custodian. require Rothschild receiving the benefits of Pershing’s clearing and custody services is not contingent upon Rothschild or its clients committing any specific amount of business (assets in custody or trading commissions) to Pershing. It is typical that custodial s ervices include the execution of securities transactions, custody, research, and access to mutual funds and other investments that may be generally available only to institutional investors or a significantly higher minimum initial investment. Clients may or may not directly benefit from products and services offered to us by Pershing. Products and services that assist Rothschild in managing and administering client accounts include, but are not limited to, software and other technology that: Provid e a cces s to client a ccount d a ta , s uch a s tra d e confirm a tions a nd a ccoun t s ta tem ents Fa cilita te tra d e execution a nd a lloca te a g g re g a ted tra d e ord ers for m ultip le client a ccounts Provid e res ea rch, p ricing , a nd other m a rket d a ta Fa cilita te p a ym ent of our fees from clients ’ a ccounts • • • • • As s is t w ith b a ck- office functions , record keep ing , a nd client rep orting Ad d itiona lly, Pers hing offers othe r s ervices intend ed to help us m a na g e a nd further d evelop our b us ines s enterp ris e. Thes e s ervices includ e w ithout lim ita tion: Com p lia nce, leg a l a nd b us ines s cons ulting ; a nd Pub lica tions a nd conferen ces on p ra ctice m a na g em ent a nd b us ines s s ucces s ion. • • Pers hing m a ke s a va ila b le , a rra ng es a nd /or p a ys third - p a rty vend ors for s om e of th e s ervices offere d to Roth s child . Pers hing a ls o d is counts or w a ives fees it w ould otherw is e cha rg e for s om e of the s e s ervices or p a ys a ll or a p a rt of the fees of a third p a rty p rovid ing thes e s ervices to our Firm . Pers hing a ls o p rovid es other b en efits s uch a s ed uca tiona l even ts a nd occa s iona l b us ine s s enterta inm ent of our p e rs onnel. Roth s child ’s re ceip t of thes e a d d itiona l s ervices d oes not d im inis h our d uty to a ct in the b es t interes ts of our clients , includ ing s e eking b es t e xecution of tra d es for client a ccounts . For clients tha t elect to cus tod y their a ccounts w ith Pers hing , P ers hing a llow s Roth s child to m a rkup certa in of the a d m inis tra tive fee s cha rg ed b y Pers hing to client a ccounts . Ra th er tha n d irectly cha rg e a d m inis tra tive fees its elf, Roths child ha s im p lem ented a n a d d itiona l $ 3 .5 0 s ervice cha rg e p e r tra d e confirm a tion fee (Pers hing cha rg es its ow n tra d e confirm a tion fe e for ha rd cop y confirm a tions ) tha t is p a id b y the client to P ers hing w hich then p a s s es tha t full a m ount to Roths child .  Brokerage Practices O In addition, Rothschild receives agent fees on certain purchases of ADR securities (ADRs are U.S. bank instruments that represents investments in foreign securities) that is collected by Pershing and paid to Rothschild. For clients that elect to custody their accounts with Pershing, see the Firm’s Broker Dealer Disclosure Document for additional information regarding 12b - 1 fees and other revenue sharing payments. In situations where a client selects a different custodian, the client must provide a trading authorization and in most cases log - in information to Rothschild for access to their accounts. This authorization is limited to trading the assets of the account, and Rothschild is not authorized to move assets into or out of the account. There is generally no additional cost for Rothschild’s services to clients who select a custodian other than Pershing, but it rs of the situation. Some clients may be charged an is on a case - by- case basis depending on the particula additional fee for certain arrangements. services but - related or asset - based stody) facilities generally do charge a separate custodial fee. In most parate custody fee arrangement with Brokerage custodians and mutual fund custodians generally do not charge separately for custody instead are compensated by account holders through commissions and other transaction fees for securities trades that are executed through the custodian or that settle into the custodian’s account. However, bank custody (and trust cu instances involving a bank (or trust) custodian, clients will enter into a se that custodian. Research and Other Soft Dollar Benefits : Research services obtained through the use of soft dollars may be offered by brokers to whom brokerage is directed or by third parties that are compensated by such brokers. Rothschild does not attempt to put a specific dollar value on the research services rendered or to allocate the relative costs or benefits of those research services among clients, believing that the research we receive will help us to fulfill our overall duty to our clients. Some clients will pay brokerage commissions that are used, in part, to purchase research services that are not - dealers we select may be paid commissions for effecting transactions used to benefit that specific client. Broker for our clients that exceed the amounts other broker - dealers would have charged for effecting these transactions if we determine in good faith that such amounts are reasonable in relation to the value of the brokerage and/or research services provided by those broker - dealers. Section 28(e) of the Securities Exchange Act of 1934, as amended, establishes that certain uses of client commission dollars (so - called “soft dollars”) will not result in a breach of fiduciary duty on the part of an investment adviser. The enumerated uses are for research and trading services. To the extent that Rothschild uses a service from a broker - dealer that encompass both 28(e) eligible and non - eligible soft dollar uses, we will make a good faith determination of the relative portions of each and wil l limit the use of soft dollars benefits to that portion of the service that is 28(e) eligible and Rothschild will pay the remaining portion out - of- pocket. When Rothschild uses client brokerage commissions to obtain research or brokerage services, we receive a benefit to the extent that we do not have to produce such products internally or compensate third parties with our own money for the delivery of such s ervices. Therefore, such use of client brokerage commissions may result in a conflict of interest, because we may have an incentive to direct client brokerage to those brokers who provide the best price or commission rates for our research and services we utilize, even if these brokers do not offer clients. We believe that, based on the quality of the research and the thoroughness of the service, clients pay equitable commissions.  Brokerage Practices O - dealers used to execute trades for our clients. Brokerage for Client Referrals: Rothschild does not ordinarily receive client referrals from broker However, if any referrals fees are paid, such arrangements are disclosed to the client, and the impact of any referral fee is borne by Roths child or other broker/dealer rather than by the client. Directed Brokerage: There are other brokerage firms that have lower commission rates than Rothschild. Commissions paid through Rothschild may vary based upon account circumstances. We retain the discretion to negotiate alternative commission rates on a client - by- client basis. Clients may elect to direct brokerage to a specific broker(s) for trade execution. Clients are informed that if they elect to direct brokerage transactions through other brokerage firms, Rothschild may not be able to obtain best execution for them because we are unable to negotiate on their behalf. As a result, clients who direct brokerage transactions may pay higher commission rates or may receive less favorable prices. them to be advantageous to clients. In these situations, clients will - rata basis. No particular group or sults in a “partial fill” (meaning cution costs Aggregate Orders: We aggregate client orders when we believe receive an average share price and execution costs will be shared on a pro client(s) will be favored over others. In situations where an aggregate order re Rothschild is not able to fill the entire aggregate order), Rothschild will allocate the executed portion of the trade among participating accounts in an equitable manner. The goal is for clients to benefit from lower exe and better prices.  Review of Accounts Item 13. Review of Accounts Investment Advisory Services Reviews: Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in the client’s individual circumstances. Account reviews may also be triggered by market, politi cal, or economic developments. Reviews are conducted by the manager(s) assigned to the relationship. Managers are supervised by James A. Franke, Managing Director, and Curtis Ellergodt, Chief Compliance Officer. Reports : In addition to the monthly statements and confirmations of transactions that clients receive from their custodian, we provide monthly or quarterly (as provided in the relevant client agreement) reports summarizing account performance, balances, and holdings. Clients are encouraged to carefully review the statements provided by their custodian. Retirement Plan Consulting Services - These accounts are reviewed by the manager(s) assigned to the Reviews: Rothschild will review the client’s IPS whenever the client advises us of a change in circumstances regarding the needs of the plan. We will also review the investment options of the plan according to the agreed upon time intervals established in the IPS. account. Managers are supervised by James A. Franke, Managing Director, and Curtis Ellergodt, Chief Compliance Officer relationship . Reports: These client accounts will receive reports as contracted for at the inception of the advisory  ion Client Referrals & Other Compensat Item 14. Client Referrals & Other Compensation Client Referrals: Rothschild may pay referral fees to independent persons or firms (“Solicitors”) for introducing clients to us. Whenever we pay a referral fee, we require that the prospective client be provided with and acknowledge receipt of a copy of this document (our F irm Brochure) and a separate disclosure statement that includes the following information: • The Solicitor’s na m e a nd rela tions hip w ith our Firm . • The fa ct tha t the Solicitor is b eing p a id a referra l fee. • The a m ount of the fee; a n d • W hether the fe e p a id to us b y the client w ill b e a b ove our norm a l fee s in ord e r to com p ens a te the Solicitor. • The im p a ct of a ny re ferra l fee is b orn e b y Roths child , ra ther tha n b y the client. Other Compensation : Our Firm a nd /or our officers a nd rep res enta tives a re e lig ib le to receive com p ens a tion (includ ing b onus es ) for referring clients interna lly a nd for certa in typ e s of inves tm ent s ervices tha t w e m a na g e interna lly. As noted a b ove, in s om e ca s es a Roths child rep res enta tive w ill refer a client tha t elects to us e Roth s child a s b oth the clie nt’s b roke r a nd inves tm ent a d vis er to a n other Roths child rep res enta tive for p ortfolio m a na g em ent s ervices in w hich event the referring rep re s enta tive w ill receive a p ortion of the b rokera g e fees p a id b y s uch client a nd th e p ortfolio m a na g er w ill receive a p ortion of the a d vis ory fee s p a id b y s uch client. How ever, clients a re und e r no ob lig a tion to us e Roth s child a s b oth b roke r a nd inves tm ent a d vis er.  Custody Item 15. Custody We previously disclosed in Item 5 of this Brochure that some of our clients direct us to directly debit our advisory fees from their accounts. As part of this billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions withi n the account during the reporting period. Because the custodian does not calculate the amount of the fee deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they be lieve that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians (electronically or by mail), we also send account statements directly to our clients on a monthly/quarterly basis. We urge our clients to carefully compare the infor mation provided on these statements to ensure that all account transactions, holdings, and values are correct and current. Because we may be deemed to have custody of those client assets invested in Conduit Funds, Rothschild is subject to an annual surprise exam under the custody rules applicable to registered investment advisers  Investment Discretion Item 16. Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we are authorized to place trades in a client’s account without contacting the client prior to each trade to obtain the client’s consent. Our discretionary authority includes the ability to do the following without contacting the client: Determ ine the s ecurity to b uy or s ell; a nd /or Determ ine the a m ount of the s ecurity to b uy or s ell. • • Clients g ive us d is cretiona ry a uthority w hen they s ig n a d is cretiona ry a g ree m e nt w ith our Firm a nd m a y lim it this a uthority b y g iving us w ritten ins tructions . Clients m a y a ls o cha ng e/a m end s uch lim ita tions b y once a g a in p rovid ing us w ith w ritten ins tructions .  Voting Client Securities Item 17. Voting Client Securities stment assets. Clients are responsible for instructing each As a matter of Firm policy, we do not vote proxies on behalf of clients. Therefore, although our Firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted; and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s inve custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We may provide clients with assistance regarding proxy issues if they contact us with questions at our principal place of business.  Financial Information Item 18. Financial Information require or solicit payment of fees in excess of $1,200 per client more than six Rothschild Investment does not months in advance of services rendered. Like all registered investment advisers, we are also required to disclose any financial condition that is likely to impair our ability to meet our contractual obligations. Rothschild has no additional financial circumstances to report. Rothschild has not been the subject of a bankruptcy petition at any time .