RSW INVESTMENTS

Item 1 – Cover Page RSW Investments Holdings, LLC 47 Maple Street, Suite 304 Summit, NJ 07901 (908) 608-9600 www.rswinvestments.com Form ADV Part 2A (“Brochure”) March 2, 2026 This Brochure provides information about the qualifications and business practices of RSW Investments Holdings, LLC (“RSW” or the “Firm”). If you have any questions about the contents of this Brochure, please contact us at(817) 391-6110 or at csears@rswinvestments.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. RSW is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information for you to determine whether to hire or retain the Adviser. Additional information about RSW is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for RSW is 302023. 1  Item 2 – Material Changes This item of the Brochure would discuss any material changes that have been made to the Brochure since the last annual update dated February 26, 2025. We have not made any material changes to our Brochure since the last annual update. ******** 2  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 ............................................................................................................... 7 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 8 Item 7 – Types of Clients ............................................................................................................................. 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 9 Item 9 – Disciplinary Information ............................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 11 Item 11 – Code of Ethics ........................................................................................................................... 12 Item 12 – Brokerage Practices ................................................................................................................. 12 Item 13 – Review of Accounts .................................................................................................................. 16 Item 14 – Client Referrals and Other Compensation .............................................................................. 16 Item 15 – Custody ...................................................................................................................................... 17 Item 16 – Investment Discretion .............................................................................................................. 17 Item 17 – Voting Client Securities ............................................................................................................ 17 Item 18 – Financial Information ............................................................................................................... 17 Brochure Supplements (Please see attached) 3  Item 4 – Advisory Business RSW Investments Holdings, LLC (“RSW” or the “Firm”) is a limited liability company formed in the State of Delaware. RSW Investments Holdings, LLC succeeded to the advisory business of its predecessor, RSW Investments, LLC (CRD#134261/SEC#801- 63947) on April 1, 2019, after entering into an ownership agreement with Resolute Investment Managers, Inc. (“RIM”). The predecessor’s business was founded in 2005. RSW’s advisory services and management personnel remained the same after the change of ownership. The Firm’s principal owners are RIM and Robert S. Waas, while Matthew T. Werner owns a minority interest in RSW. RIM is an indirect wholly-owned subsidiary of Resolute Topco, Inc., which is owned primarily by various institutional investment funds that are managed by financial institutions and other investment advisory firms. As of December 31, 2025, RSW managed $2.3 billion on a discretionary basis. RSW specializes in the management of municipal bond portfolios, as discussed further below. The majority of RSW’s clients are referred by a wrap-fee program sponsor or other financial institution that has selected or recommended RSW to manage the client’s assets. The program sponsor or financial institution acts as a financial intermediary between RSW and the client. A representative of the financial intermediary works with the client to determine the client’s investment objectives, risk tolerance, liquidity requirements, investment restrictions and other relevant suitability factors. Based on this information, the representative may then recommend placing all or a portion of the client's assets with RSW for management. For its services under a wrap-fee program, RSW receives a portion of the fee that the program sponsor collects from the client. Portfolio Management Services RSW's fixed-income investment management philosophy focuses on maximizing clients' after-tax total return while employing prudent and predictable risk through focusing on coupon selection, yield curve targeting and changes in portfolio duration. Through the use of a proactive credit research approach, optimal portfolio structure, and dynamic risk management, RSW attempts to maximize portfolio predictability and dependability. RSW manages municipal fixed income accounts on a discretionary basis only. RSW’s actively-managed strategies fall into three (3) broad categories -- Market Duration Portfolio, Low Duration Portfolio, and Enhanced Intermediate Duration Portfolio -- which 4  are each designed to meet a particular investment goal. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). RSW can create a customized investment strategy consistent with the individual investment objectives and risk tolerances of a client, subject to RSW deeming the account to be large enough to support efficient portfolio management and trading. These separate accounts will be managed versus a customized benchmark. The Market Duration Portfolio has the following characteristics:  It strives to provide the tax-exempt cash flow of a 10-15 year bond while maintaining a level of volatility that is normally associated with shorter maturity investments.  A key determinant in RSW's maturity distribution is the slope of the municipal bond  yield curve. Emphasizes high quality (AA-rated average) premium coupon callable municipal bonds with an approximate average maturity of 10-15 years.  The average call date of each portfolio typically falls within the range of 4 to 6 years.  Benchmark: Bloomberg 5-Year Municipal Bond Index.  Available Mandates: National, State Preference and State Specific: o National Portfolios- comprised of bonds issued in any state without considering the client's state of residence o State Preference Portfolios - target a minimum of 50% state specific issues with the remainder invested in out-of-state securities o State Specific Portfolios - constructed for clients who reside in a variety of states. o RSW's ability to achieve our desired level of investment in a particular state may be impacted by factors such as: high embedded capital gains, the relative value of the target state, and the availability of new issue and/or secondary supply of bonds.  RSW employs a proprietary “sale discipline” during periods of rising interest rates. As market yields rise near the bond’s stated coupon rate, the price will decline towards par. RSW’s strategy targets these “current coupon” bonds for sale as they no longer represent superior income or price stability. RSW then seeks to reinvest the proceeds from the sales in higher coupon callable bonds, thus stabilizing the interest rate sensitivity of the portfolio. . By executing these transactions and realizing a capital loss, an asset is created since the loss may be used to offset capital gains. This advantage may not have existed if a buy and hold strategy was in place. 5  The Low Duration Portfolio exhibits the same characteristics as the Market Duration Portfolio, with the key differences being it can only invest in premium coupon callable bonds with stated maturities that cannot exceed 10 years (as opposed to 10-15 years for the Market Duration Portfolio). Furthermore, the average call date structure of each portfolio is shorter than the Market Duration mandate, and typically falls in the range of 2 to 4 years. The benchmark for the Low Duration Portfolio is the Bloomberg 3-Year Municipal Bond Index. The core discipline of the Enhanced Intermediate Duration Portfolio is founded on the investment characteristics of RSW’s Market Duration Portfolio (targeting high quality premium coupon callable bonds maturing between 10-15 years.) However, the Enhanced Intermediate Duration Portfolio is not held to RSW’s more stringent “sale discipline” and maintains broader levels of flexibility to preserve principal and enhance total rate of return opportunities, such as: Investments in bonds maturing up to 20 years.  Active duration management.   Coupon structure: may target discount, par, and premium coupon bonds.  Short-term tactical US Treasury bond exposure as market conditions warrant. The benchmark for the Enhanced Intermediate Duration Portfolio is the Bloomberg 5-Year Municipal Bond Index. RSW seeks to manage each of these primary strategies in a tax-efficient manner for clients. Deeply embedded within our investment philosophy is an ability to convert a rising interest rate environment into an opportunity to harvest tax losses and increase coupon income. As a result of rising interest rates, certain securities are flagged to be sold as their prices drop to predetermined levels. By executing these transactions and realizing a capital loss, an asset is created since the loss may be used to offset capital gains. This advantage may not have existed if a buy and hold strategy was in place. For all portfolio strategies, RSW will ensure that the following conditions are met and maintained: 1. RSW manages each client's account to the strategy selected by the client and/or the client’s financial advisor, with any reasonable investment restrictions the client may impose. For certain investment programs sponsored by an intermediary, however, the intermediary may not provide clients the opportunity to impose investment restrictions on the RSW strategy available through the intermediary. 6  2. RSW obtains sufficient client information to be able to provide individualized investment advice to the client. At least annually, RSW (or a representative of the applicable financial intermediary) will contact the client to determine whether there have been any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. 3. RSW is reasonably available to consult with the client, either directly or through the client’s financial advisor. 4. Each client retains indicia of ownership of the securities and funds in the account, including the ability to withdraw securities and vote securities, among others. Item 5 – Fees and Compensation RSW is compensated based on a percentage of the market value of each account. For wrap-fee programs, the wrap fee collected by the applicable program sponsor includes RSW's advisory fee, the program sponsor's fee (which may be shared with an independent referring party), the client's portfolio transactions costs (if applicable and subject to any restrictions), and custodial services for the client's assets. RSW’s portion of the wrap fee typically ranges from 10% to 50% of the total fee. The program sponsor may charge certain additional costs. For a complete description of the fee arrangement, including billing practices and account termination provisions, clients should review the applicable wrap- fee program brochure provided to the client by the representative of the program sponsor. RSW’s advisory fee for its portfolio management services for accounts not introduced through a wrap-fee program will be charged as a percentage of assets under management. RSW’s standard annual management fee schedule is as follows: Actively-Managed Strategies 0.30% on the first $500,000, 0.25% on the next $4.5 million and 0.20% over $5 million RSW charges its advisory fees based on the preference of the client’s financial intermediary, which may be in advance (prior to the period for which services are to be performed) or in arrears (after the period for which services were performed). Regardless whether fees are paid in advance or arrears, the annual advisory fees are generally paid in quarterly installments. For clients that are not in a wrap-fee program, RSW may invoice the client or instruct the client’s custodian to deduct RSW’s advisory fees from the client’s account. The custodian 7  will deduct the advisory fees only based upon a written authorization from the client permitting the fees to be paid directly from the account. Clients should receive from their custodian an account statement at least quarterly. Clients who have authorized RSW to deduct its advisory fees from their account should review the deduction of fees reflected on its quarterly statements. RSW typically requires a minimum account size of $250,000 for the Market Duration Portfolio, Low Duration Portfolio and Enhanced Intermediate Duration Portfolio. The minimum can be waived under certain circumstances. A client agreement may be canceled at any time, by either party, for any reason, upon receipt of written notice. Upon termination of any account, RSW will promptly refund the client any prepaid, unearned fees, and any earned, unpaid fees by the client will be due and payable to RSW. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. While it is not anticipated that mutual funds will be included in the clients' portfolios, money- market mutual funds may be used to 'sweep' unused cash balances until they can be appropriately invested. Clients should recognize that all fees paid to RSW for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. Item 6 – Performance-Based Fees and Side-By-Side Management The fee charged is calculated as described above in Item 5 and is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client. RSW does not anticipate charging any advisory fees based on the performance of client accounts. Item 7 – Types of Clients RSW specializes in the professional management of separate account municipal bond portfolios for individual investors. RSW may also provide investment advice to trusts, estates, charitable organizations, and corporations or business entities. 8  As disclosed under Item 5, RSW requires a minimum account size of $250,000 for the Market Duration Portfolio, Low Duration Portfolio, or Enhanced Intermediate Duration Portfolio. However, under certain circumstances these minimums may be waived. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss RSW’s investment philosophy does not solely rely on “calling” the direction of interest rates. Instead, RSW embraces the concept of enhancing wealth by emphasizing three key disciplines: Proactive Research Approach   Optimal Portfolio Structure  Dynamic Risk Management Our “Buy Discipline” stresses research efforts that are concentrated on assessing value among high quality bonds by utilizing yield curve, roll down, embedded call option, and horizon analysis. By applying these research techniques, we believe higher stable and consistent returns can be achieved than by lowering our credit quality standards to attain negligible, incremental returns. RSW utilizes various tools as sources of information such as Bloomberg and Investor Tools. While RSW typically follows a long-term investment strategy, on occasion (dependent on the needs of a specific client) RSW may engage in more active trading (securities bought and sold within 30 days). Because this strategy involves a certain additional degree of risk, it will only be employed when consistent with the client's stated strategy selection. RSW’s security analysis methods include fundamental and technical analysis. The investment strategies used to implement any transactions include long term purchases (securities held at least a year), short term purchases (securities sold within a year), and active trading (securities sold within 30 days). Investing in securities involves risk of loss that clients should be prepared to bear. Risks Specific to Fixed Income Management: Historically, bonds have provided less volatility and less risk of loss of capital than equity investing. However, there are many factors that may affect the risk and return profile of a fixed income portfolio. The two most prominent factors are interest-rate movements and the creditworthiness of the bond issuer. 9  Municipal securities are debt obligations generally issued to obtain funds for various public purposes, including general financing for state and local governments, or financing for a specific project or public facility. Municipal securities may be fully or partially backed by the taxing authority of the local government, by the credit of a private issuer, by the current or anticipated revenues from a specific project or specific assets or by domestic or foreign entities providing credit support, such as letters of credit, guarantees or insurance, and are generally classified into general obligation bonds and special revenue obligations. Municipal securities are subject to credit risk. Bonds issued by the U.S. government have significantly less risk of default than those issued by corporations and incrementally lower risk than municipalities. However, the overall return on government bonds tends to be less than other types of fixed-income securities that carry elevated levels of credit risk. A municipal issuer of a security may default on scheduled interest or principal payments as they become due, although such events have been historically uncommon among investment-grade quality issuers. In addition, a downgrade in the issuer’s or security’s credit rating can reduce the market value of the security. Municipalities can also face severe financial hardship making the possibility of their defaulting on obligations, and/or declaring bankruptcy where allowable, a risk to the value of municipal securities held by clients. Municipal securities are also subject to interest rate risk. A decline in short-term interest rates will lower a bond’s yield, while the market value of previously purchased bonds in general will rise. When interest rates go up, the market values of previously issued bonds generally decline. The prices of fixed income securities are also affected by their duration. Duration is an indicator of the sensitivity of a security’s price to changes in interest rates. Fixed income securities with longer durations generally have greater sensitivity to changes in interest rates. Generally, the price of a security with a positive duration will fall when interest rates rise, and vice versa. Moreover, larger absolute values of duration correspond to larger price changes. A duration of “one year” means that a security’s price would be expected to decrease by approximately 1% with a 1% increase in interest rates. Municipal securities are also subject to call risk. There is a chance that during periods of falling interest rates, issuers of callable bonds may call (redeem) securities with higher coupon rates or interest rates before their maturity dates. The bondholder would then lose any price appreciation above the bond’s call price and could be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in interest income. Prospective and existing clients should consult with a tax advisor regarding federal, state and local taxes that may affect a municipal bond portfolio. 10  Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of their advisory business or the integrity of their management. To the best of its knowledge, RSW does not have any legal or disciplinary events to disclose under this Item. Item 10 – Other Financial Industry Activities and Affiliations Resolute Investment Managers, Inc. RIM is a diversified, multi-affiliate asset management platform comprised of SEC-registered investment advisers and a limited-purpose broker-dealer. RSW receives compliance support and accounting services from its affiliate, American Beacon Advisors, Inc. (“AmBeacon”). Those employees of AmBeacon who have access to RSW’s non-public information regarding clients’ account activity or holdings are subject to RSW’s Code of Ethics and certain other policies and procedures designed to protect clients from potential conflicts of interest. Please see Item 11 for a description of the Code of Ethics. Certain directors of RSW are also directors and/or employees of one or more of its affiliated firms. These directors provide corporate governance and other services to RSW’s affiliates. Neither RIM nor AmBeacon is involved in the management or oversight of RSW’s investment portfolios. RSW has identified no conflicts of interest that may impact clients as a result of its affiliation with RIM. Resolute Investment Distributors, Inc. RSW has an affiliated broker-dealer, Resolute Investment Distributors, Inc. (“RID”), which is a limited purpose broker-dealer registered with the Financial Industry Regulatory Authority. RID limits its activities to distribution and marketing of registered investment companies and private funds to financial intermediaries and institutional investors. RID does not perform any securities execution or clearing services. Therefore, RSW will not use RID as a broker when executing any client transactions. One of RSW’s directors is a registered representative of RID. 11  Solicitation Agreement with an Affiliated Investment Adviser Pursuant to a solicitation agreement, an affiliated investment adviser solicits and refers financial intermediaries and other clients to RSW. RSW is not obligated to pay cash or non- cash compensation to the affiliate for the solicitation services. RSW does not recommend or select the affiliated investment adviser for clients. Please see Item 14 for more information on the solicitation arrangement. Other Financial Industry Activities RSW is not registered as a futures commission merchant, commodity pool operator (CPO) or a commodity trading advisor (CTA), nor are any of its employees. However, certain of the RSW affiliates are registered as a CPO or a CTA and one of RSW’s directors is an associated person of a CPO. Additionally, certain affiliates manage or advise limited partnerships, private funds or limited liability companies as disclosed on their respective Form ADV Part 1, Schedule D. RSW’s employees, parent company or an affiliate may from time to time invest in an RSW strategy. Such investments may be made on a fee-waived basis. Item 11 – Code of Ethics RSW has adopted a Code of Ethics which sets forth high ethical standards of business conduct for RSW employees, and those employees of AmBeacon who have access to non- public information regarding RSW’s client accounts, including compliance with applicable federal securities laws. Our Code of Ethics also 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 RSW's covered persons. Among other things, RSW's Code of Ethics also requires the prior approval of any acquisition of securities in a primary issuance of municipal bonds, a limited offering (e.g., private placement) or an initial public offering. RSW restricts employees from purchasing or selling the same security at the time that RSW is purchasing or selling on behalf of clients. Our Code of Ethics also includes oversight, enforcement, and recordkeeping provisions. A copy of RSW'S Code of Ethics is available to RSW'S advisory clients upon request to the Chief Compliance Officer at (817) 391-6110 or at csears@rswinvestments.com. Item 12 – Brokerage Practices 12  The bond structures sought for purchase by RSW are typically in limited supply, and in many cases, may only be available from one broker/dealer. On the limited occasions when bonds being sought for purchase are offered in the marketplace by more than one broker/dealer, counterparty selection will be based primarily on best price, as well as RSW’s consideration of the full range and quality of a broker/dealer’s services, including execution capability, commission rates (if any), and the value of research (if received from the broker/dealer), among other things. RSW may at times invest client assets in new issue municipal bonds due to favorable pricing opportunities. RSW will execute such purchases through syndicate members of the new issue. While RSW will make every effort to obtain best execution on these transactions, the Firm’s ability to get multiple quotes will be limited. When secondary municipal bond offerings are utilized in client accounts, RSW as a matter of policy will seek the best execution possible taking into account current market conditions and other alternative investment opportunities. With respect to the vast majority of sale transactions, under normal market conditions, a competitive bidding process is utilized for those securities deemed to be liquid by RSW. Execution via a negotiated sale is permitted in other instances. In those instances when the competitive bid is deemed to be below an “acceptable” price, the bonds are offered in the “Street” at a higher price. In the event that two or more brokers competitively bid identical price levels, RSW will go back to each and request a re- bid. If all brokers again return identical new bids, then a broker is selected randomly. RSW does not have any arrangements with broker/dealers for the receipt of research or other products or services in connection with client transactions (i.e., soft dollar benefits). RSW will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple clients’ accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading allows RSW to execute fixed income trades in a more timely, equitable manner and to potentially reduce trading costs for clients. However, as per RSW's Code of Ethics (please refer to disclosure under Item 11), no employee personal trades will ever be included in any client blocks. “Investable Cash” and Portfolio Restructurings Below are the methods that will be employed to allocate bonds for both the investment of “investable cash” and portfolio restructurings. Neither one will have preferential treatment over the other in receiving bonds purchased. 13  Portfolios with “Investable Cash”: Portfolios with the highest level of cash are “flagged” and analyzed to determine whether they will be allotted any new bonds purchased. Additionally, the following risk parameters are also to be considered in RSW making allocation decisions: Issuer exposure • State exposure (dependent on National / Preference account type) • • Underlying credit quality • Yield curve exposure • Sector exposure • Annual realized / unrealized gain and loss amounts • Duration (Option Adjusted Duration/Duration to Call) Each targeted portfolio will receive a full allocation of a “block” or “aggregated” purchase as deemed by RSW based on either the portfolio’s percentage of available cash or the risk parameters above. In the event that a block is too small to accommodate a “full allocation” for all of the selected portfolios, RSW fills client accounts with the highest cash levels, while also making considerations for the risk parameters above and continues allocating bonds until the process is complete. Portfolios “Flagged” for Restructuring: Additionally, portfolios that are fully invested and thus do not have available cash may be targeted to participate in an exchange of part or all of an existing holding(s) for the newly purchased bond. The criteria and order in which portfolios are selected will be determined by factors such as: deviation from the desired level within each of the risk parameters mentioned below (i.e., the portfolios with the greatest deviation are targeted first, etc.): Issuer exposure • State exposure (dependent on National / Preference account type) • • Underlying credit quality • Yield curve exposure • Sector exposure • Annual realized / unrealized gain and loss amounts • Duration (Option Adjusted Duration/Duration to Call) Restructuring trades are entirely dependent on whether RSW can create capacity for a particular bond in accounts where such bond could be a potential fit. Due to market liquidity, RSW cannot always get an acceptable bid (price) on certain existing client holdings, and without an acceptable price, RSW will not sell existing client bonds in order to generate cash in client portfolios for the bonds to be purchased. Therefore, RSW quite 14  often selects a larger group of portfolios and securities to “bid out” than it intends to execute. Only when RSW evaluates the bids received can we determine the most appropriate securities to sell and portfolios to participate in the restructuring. Those portfolios selected will then receive a full allocation of the “block” or “aggregated” purchase consistent with the amount of cash generated and risk parameters mentioned above. In the event that enough bonds were not purchased for a portfolio to receive a “full” allocation, that portfolio will simply receive the final allocation of the balance of the bonds that remain to be allocated. Electronic Trading Platforms RSW executes sale transactions on a regular basis utilizing electronic trading platforms. The electronic platforms allow RSW to submit a bid to purchase a security that RSW is selling “in competition” with the broker/dealer community. RSW may decide to bid on a bond that it is selling from a client account if RSW deems that the bond meets RSW’s investment criteria for one or more other client accounts at the time the bid list is compiled. This process benefits the account selling the bonds by providing additional market participants to enhance best execution, as well as the purchasing account, which has the opportunity to purchase a bond that may be relatively scarce in the marketplace at a market-derived price. Electronic trading platforms charge a brokerage fee for their services, which is deducted from the proceeds of the bond being sold. Portfolio Management Services Through Wrap-Fee Programs RSW requests that it be provided with written authority to determine the securities to be bought or sold and the amounts of securities to be bought or sold in the client's account. Any limitations on this discretionary authority by the client or wrap program sponsor shall be in writing. Clients may change/amend these limitations as permitted by the wrap program sponsor. Such amendments shall be submitted in writing. Clients participating in wrap-fee programs agree to direct brokerage transactions in their program account(s) through the applicable program sponsor. Within each wrap-fee program, RSW has the ability to trade away from the sponsor, which RSW predominately does to access a greater bond inventory than is typically held by the sponsor. (The program sponsor typically charges an additional fee above and beyond the wrap fee for such trade- away transactions, but since RSW trades solely in fixed income bonds that do not charge brokerage commissions, the sponsor does not charge a trade-away fee.) The client should, however, consider that, depending upon the level of the wrap fee charged by the program sponsor, the amount of portfolio activity in the client's account, the value of custodial and other services which are provided under the arrangement, and other 15  factors, the wrap fee may exceed the aggregate cost of such services if they were provided separately. Item 13 – Review of Accounts While the securities within client accounts are continuously monitored, these accounts will be formally reviewed at least monthly by Robert (Rob) Waas, CEO/CIO of RSW. Various reports and filters are used to highlight deviations from the strategy or desired investment parameters. Reviews focus primarily on the levels of cash, duration, maturity profile, and issuer diversification. More frequent reviews may be triggered by material changes in variables such as the client’s individual circumstances, or the market, political, or economic environment. RSW performs the same reviews for any accounts managed within a wrap-fee program. In addition to the at least quarterly statements and confirmations of transactions that clients receive from their broker dealer or custodian, RSW will provide a quarterly general market commentary to clients’ financial advisors. RSW’s clients managed within a wrap-fee program are requested to refer to the applicable program disclosure document for information on the reports they are to receive from their program sponsor. Typically, RSW does not provide any reports directly to wrap-fee program clients. Item 14 – Client Referrals and Other Compensation As disclosed throughout this brochure, RSW acts as investment adviser to clients through various wrap-fee programs sponsored by third-party companies, as well as through other third-party financial intermediaries. For such services, RSW receives a portion of the wrap fee or overall fee charged by the intermediary. RSW has engaged an affiliated investment adviser to solicit and refer financial intermediaries and other clients who desire to utilize the advisory services provided by RSW. RSW is not obligated to pay any cash or non-compensation to the affiliated adviser for the solicitation services, but the affiliated adviser compensates its personnel for client referrals and client servicing activities performed for RSW. 16  Item 15 – Custody RSW does not maintain custody of client funds or securities, but RSW has authority to deduct its advisory fees from client accounts when clients grant such authority. Each client should receive at least quarterly statements from the broker/dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. Upon request, RSW may also provide certain account details to the client. RSW’s records may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion RSW requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold, as well as the broker/dealer to be used and the commission rates to be paid (or markups/markdowns in the case of fixed income investments). However, as discussed under Item 12, clients participating in wrap-fee programs typically agree to direct brokerage transactions in their account(s) through the applicable program sponsor. Within the various programs, RSW has the ability to trade away from the sponsor, which RSW predominantly does to access a greater bond inventory than is typically held by the sponsor. (The program sponsor typically charges an additional fee above and beyond the wrap fee for such trade-away transactions, but since RSW trades solely in fixed income bonds that do not charge brokerage commissions, no sponsor currently charges a trade- away fee.) Item 17 – Voting Client Securities Due to the predominant use of municipal bonds as investment vehicles for client accounts, RSW does not expect to vote any proxies on behalf of clients. RSW will only accept proxy voting authority if required by a wrap program sponsor. Otherwise, clients are responsible for voting their own proxies (as applicable). Item 18 – Financial Information RSW is required in this Item to provide you with certain financial information or disclosures about RSW’s financial condition. RSW has no financial commitment that 17  impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 18  Item 1- Cover Page Robert S. Waas RSW Investments Holdings, LLC 47 Maple Street, Suite 304, Summit, NJ 07901 908-608-9600 March 2, 2026 This Brochure Supplement provides information about Robert Waas that supplements the RSW Investments Holdings, LLC (“RSW”) Brochure. You should have received a copy of that Brochure. Please contact Christina Sears, RSW’s Chief Compliance Officer, if you did not receive RSW’s Brochure or if you have any questions about the contents of this supplement. Additional information about Robert Waas is available on the SEC’s website at www.adviserinfo.sec.gov. 19  Item 2- Educational Background and Business Experience Robert S. Waas, born 1960 Post-Secondary Education:  Graduated from St. John's University in 1982 with a B.S. in Accounting. Recent Business Background:  CEO and CIO of RSW Investments Holdings, LLC 07/2019 to Present; CEO/CIO/CCO of RSW Investments Holdings, LLC from 04/2019 to 06/2019. CEO/CIO/CCO of RSW Investments, LLC, predecessor of RSW Investments Holdings, LLC, from 2005 to 2019. Item 3- Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4- Other Business Activities None. Item 5- Additional Compensation As an owner of RSW, Mr. Waas receives an economic benefit on the success of RSW, including new clients and additional assets. He receives no other additional compensation. Item 6 - Supervision RSW is a small horizontal organization. As such, we do not conduct our business by appointment at predetermined dates and times. Instead, we converse daily as an investment team about matters that affect our client portfolios. The portfolio management team is comprised of Robert Waas, CIO, Matthew Werner, Senior Portfolio Manager, CFA and Randy Fox, Portfolio Manager. All transactions executed by the team members must conform to the agreed upon strategy. Robert Waas solicits opinions from the team members but is ultimately responsible for setting investment policies. The investment team discusses the vast majority of the bonds before they are purchased or sold, with Robert Waas, CEO/CIO, reviewing all trades to ensure the transactions were in line with the agreed upon investment policies. If you need to contact a representative regarding Robert Waas, Christina Sears can be reached at csears@rswinvestments.com or phone number 817-391-6110. 20  Item 1- Cover Page Matthew T. Werner, CFA RSW Investments Holdings, LLC 47 Maple Street, Suite 304, Summit, NJ 07901 908-608-9600 March 2, 2026 This Brochure Supplement provides information about Matthew Werner that supplements the RSW Investments Holdings, LLC (“RSW”) Brochure. You should have received a copy of that Brochure. Please contact Christina Sears, RSW’s Chief Compliance Officer, if you did not receive RSW’s Brochure or if you have any questions about the contents of this supplement. Additional information about Matthew Werner is available on the SEC’s website at www.adviserinfo.sec.gov. 21  Item 2- Educational Background and Business Experience Matthew T. Werner, Born 1979 Post-Secondary Education:  Graduated from University of Delaware in 2001 with a B.S. in Finance, with minors in Management Information Systems and Economics  CFA® charterholder since 2017 Recent Business Background:  Senior Portfolio Manager of RSW Investments Holdings, LLC from 2019 to present. Senior Portfolio Manager of RSW Investments, LLC, predecessor of RSW Investments Holdings, LLC, from 2015 to 2019.  Portfolio Manager of RSW Investments, LLC from 2010 to 2015. CFA - Chartered Financial Analyst Issued by: CFA Institute Prerequisites/Experience Required: Candidate must meet one of the following requirements:  Undergraduate degree and 4 years of professional experience involving investment  decision-making, or 4 years qualified work experience (full time, but not necessarily investment related) Educational Requirements: Self-study program (250 hours of study for each of the 3 levels) Examination Type: 3 course exams Continuing Education/Experience Requirements: None Item 3- Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4- Other Business Activities None. Item 5- Additional Compensation As an owner of RSW, Mr. Werner receives an economic benefit on the success of RSW, including new clients and additional assets. With the exception of compensation received as a result of activities described under Item 4 above, Matthew Werner receives no other additional compensation. 22  Item 6 - Supervision RSW is a small horizontal organization. As such, we do not conduct our business by appointment at predetermined dates and times. Instead, we converse daily as an investment team about matters that affect our client portfolios. The portfolio management team is comprised of Robert Waas, CIO, Matthew Werner, Senior Portfolio Manager, CFA and Randy Fox, Portfolio Manager. All transactions executed by the team members must conform to the agreed upon strategy. Robert S. Waas solicits opinions from the team members but is ultimately responsible for setting investment policies. Matthew Werner has the latitude to execute buy and sale transactions that are aligned with RSW’s investment philosophy, and account mandate guidelines. In practice, however, the investment team discusses the vast majority of the bonds before they are purchased or sold, with Robert Waas, CEO/CIO, reviewing all trades to ensure the transactions were in line with the agreed upon investment policies. If you need to contact a representative regarding Matthew Werner, Robert Waas can be reached at 47 Maple St., Suite 304 Summit, NJ 07901. Phone number 908-608-9600. 23