Overview

Assets Under Management: $586 million
Headquarters: NEWPORT BEACH, CA
High-Net-Worth Clients: 155
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (RSCRUM_ADV_PART_2A_INCLUDING_2B_APRIL 2025)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $5,000,000 0.75%
$5,000,001 $10,000,000 0.50%
$10,000,001 and above 0.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $40,000 0.80%
$10 million $65,000 0.65%
$50 million $165,000 0.33%
$100 million $290,000 0.29%

Clients

Number of High-Net-Worth Clients: 155
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 88.62
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 938
Discretionary Accounts: 905
Non-Discretionary Accounts: 33

Regulatory Filings

CRD Number: 158621
Last Filing Date: 2024-03-20 00:00:00
Website: HTTP://WWW.RSCRUM.COM

Form ADV Documents

Primary Brochure: RSCRUM_ADV_PART_2A_INCLUDING_2B_APRIL 2025 (2025-03-27)

View Document Text
RS Crum, Inc. Form ADV Part 2A Brochure ADV PART 2 Financial Advice and Representation 1 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Item 1 – Cover Page R. S. Crum, Inc. 4 Upper Newport Plaza Drive Suite 201 Newport Beach, CA 92660 (949) 428-9696 www.rscrum.com This Brochure provides information about the qualifications and business practices of R. S. Dated: March 27, 2025 Crum, Inc. If you have any questions about the contents of this Brochure, please contact us at (949) 428-9696 or by email at rscrum@rscrum.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. R. S. Crum, Inc. 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 provides you with information, which you may use to determine to hire or retain an Adviser. Additional information about R. S. Crum, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. 2 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Item 2 – Material Changes The purpose of this page is to inform you of any material changes to this brochure. If you are receiving this brochure for the first time, this section may not be relevant to you. RS Crum, Inc. reviews and updates our brochure at least annually to confirm that it remains current. Since the previous annual update to our brochure, dated March 20, 2024, we have made the following material changes: Item 5 Fees and Compensation - RS Crum, Inc. has updated information on our standard tiered fee schedule. While some legacy clients may still be assessed fees under a previous tiered fee schedule as agreed upon within the clients’ investment management agreements, the updated schedule is relevant for new clients. If you wish to receive a complete copy of our Form ADV Part 2A brochure, please send a written request to our office. 3 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................... 2 Item 2 – Material Changes ......................................................................................................................... 3 Item 3 – Table of Contents ......................................................................................................................... 4 Item 4 – Advisory Business ........................................................................................................................ 6 Types of Advisory Services ...................................................................................................................... 6 Services that are Limited in Duration ....................................................................................................... 6 Continuous (On-Going) Advisory Services .............................................................................................. 7 New Clients (Limited Duration and Continuous Advisory Clients) ......................................................... 7 Investment Management ........................................................................................................................... 8 Non-managed Accounts ............................................................................................................................ 9 Financial Planning .................................................................................................................................... 9 Retirement Investment Advice .................................................................................................................. 9 Assets Under Management ..................................................................................................................... 10 Item 5 – Fees and Compensation ............................................................................................................. 10 Cancellation of Services (Limited Duration or Continuous) .................................................................. 11 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 11 Item 7 – Types of Clients .......................................................................................................................... 12 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 12 Methods of Analysis ............................................................................................................................... 12 Investment Strategies .............................................................................................................................. 12 Investing Involves Risk ........................................................................................................................... 13 General Risks of Owning Securities ....................................................................................................... 13 Specific Security Risks ........................................................................................................................... 13 Other Business Risks .............................................................................................................................. 14 Item 9 – Disciplinary Information ........................................................................................................... 15 Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 15 Item 11 – Code of Ethics ........................................................................................................................... 15 Item 12 – Brokerage Practices ................................................................................................................. 16 How We Select Brokers/Custodians ....................................................................................................... 17 4 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Your Brokerage and Custody Costs ........................................................................................................ 17 Products and Services Available to Us from Schwab ............................................................................. 17 Services That Benefit You ...................................................................................................................... 18 Services That May Not Directly Benefit You ......................................................................................... 18 Services That Generally Benefit Only Us ............................................................................................... 18 Our Interest in Schwab’s Services .......................................................................................................... 19 Directed Brokerage Transactions ............................................................................................................ 19 Aggregation and Allocation of Transactions .......................................................................................... 19 Item 13 – Review of Accounts .................................................................................................................. 21 Managed Account Reviews & Reporting ............................................................................................... 21 Financial Plan Reviews & Reporting ...................................................................................................... 22 Item 14 – Client Referrals and Other Compensation ............................................................................ 22 Schwab Support Products and Services .................................................................................................. 22 Recommendation of Unaffiliated Professionals...................................................................................... 22 Item 15 – Custody ..................................................................................................................................... 23 Item 16 – Investment Discretion .............................................................................................................. 23 Discretionary Management ..................................................................................................................... 23 Non-Discretionary Management ............................................................................................................. 24 Item 17 – Voting Client Securities ........................................................................................................... 24 Item 18 – Financial Information .............................................................................................................. 24 Form ADV, Part 2B Brochure Supplement ............................................................................................... i Description of Professional Designations Used in this Brochure Supplement ......................................... ii Mark Rylance, CFP® ............................................................................................................................. iii Jon Theriault, CFP® ............................................................................................................................... v Daniel Sexton, CFP® ............................................................................................................................. vii Eric Papa, CFP® .................................................................................................................................... ix 5 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Item 4 – Advisory Business In 1976, Richard S. Crum founded RS Crum Advisory Services, which was incorporated in 2003 as R. S. Crum, Inc. (“RS Crum, Inc.,” the “Firm,” “we,” “our,” or “us”). In July 2011, the Firm completed a transfer of ownership to senior employees. Currently, RS Crum, Inc.’s principal owners are Mark Rylance, Jon Theriault, and Daniel Sexton. RS Crum, Inc. is an SEC registered investment adviser. Registration with the SEC does not in any way constitute an endorsement by the SEC of an investment adviser's skill or expertise. Since our beginning, RS Crum, Inc. has provided investment management, financial planning, and business consulting services on a FEE ONLY basis to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. The Firm does not participate or offer product sales (or accept commissions) in connection with services. We believe this enhances objectivity to our clients. The client always maintains control of their assets as their accounts are held by a qualified custodian. The Firm does not act as a custodian of client assets, providing additional security for the client. Types of Advisory Services RS Crum, Inc. manages investments primarily on a discretionary and, in limited circumstances, on a non- discretionary basis. On a more than an occasional basis, the Firm provides advice to clients on matters not involving securities as further described below. The scope of financial advice and/or planning services differs from client to client depending on their specific need. RS Crum, Inc. provides services on a continuous (ongoing) and limited engagement basis. RS Crum, Inc. offers both comprehensive financial services and services that are limited in scope. Areas that could be covered include: • Budget, Cash Flow, and Net Worth Assessment • Summary of Client Goals • Investment Management • Retirement Analysis • Transitional Event Planning • Real Estate Analysis • Business Consulting The Firm might also work with a client’s other advisors as they generally relate to estate planning, tax planning, and / or insurance. See below Item 14 – Client Referrals and Other Compensation. Services that are Limited in Duration 6 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure RS Crum, Inc. offers engagements of limited duration up to one year. The cost of a limited engagement does not include the follow up or monitoring of future activities. In addition, the limited engagement does not include periodic review nor is there any obligation on the part of the client to re-utilize RS Crum, Inc. Clients who previously received services on a limited engagement may choose to have such services updated and/or modified. This decision is solely that of the client. RS Crum, Inc. does not send periodic reminders or advocate any specific time frame wherein a “financial check-up” may become advantageous. However, the client is told that time and economic circumstances do change and that every financial plan will need modification and/or revision at some future time. The policy of RS Crum, Inc. is to charge a flat fee for such services. Continuous (On-Going) Advisory Services Clients may engage RS Crum, Inc. for financial services on an ongoing basis (i.e., month to month). A fee, paid monthly or quarterly, is determined and agreed upon by both parties prior to entering any service arrangement. The fee and billing schedule are included in a formal engagement contract. This contract is signed by parties and retained on file before work begins. An electronic copy is also retained. A fee might be determined that may not relate purely to asset management. This fee might be based on estimated work and responsibilities attributable to the service provided in other financial areas such as estate planning, income tax planning, retirement analysis, business consulting, etc. Ongoing investment management is normally conducted on a discretionary basis. Although clients participate in identifying specific goals, they usually are not involved in the “day-to-day” specificity of investment selection. Clients receive periodic statements and confirmations of trading activity from independent account custodian(s) or third-party administrator(s). RS Crum, Inc. receives duplicate account statements and confirmations. RS Crum, Inc. DOES NOT maintain general powers of attorney over client accounts. New Clients (Limited Duration and Continuous Advisory Clients) An initial consultation is given free of charge to potential clients. This meeting may include a general discussion of their financial options, alternatives, and goals in one or more of the following financial areas, but not limited to: • Budget, Cash Flow, and Net Worth • Investments • Income Tax • Retirement 7 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure • Estate • Real Estate • Business Consulting A copy of the ADV Part 2A (Brochure) is generally delivered to any potential new client(s) prior to the initial conference or it is provided at the initial meeting, but otherwise no later than at time of contract signing. Prospective clients are normally asked to provide the following at or prior to the initial meeting: • Most recent year’s income tax returns • Brief description of assets and liabilities (or a financial statement if available) • Brief written description of goals or special questions or matters to be covered during that session • Any additional data that may be relevant to the discussions The initial interview session generally lasts from 1 to 2 hours. No decision is required to engage RS Crum, Inc. at the initial meeting or to the cost, duration, or scope of services that might be provided. Prospective clients are typically contacted within several business days of the initial consultation to discuss such matters. A written engagement letter is prepared for each client prior to commencing any specified activity. In part, this letter discusses the cost and duration of services as well as specific areas the client wishes to be included. Financial areas not specified in the Advisory/Engagement Letter are not included. Generally, a portion of the fee is due on signing, to pay for services in advance. Such advanced fees usually cover the first quarter of services. A signed copy of this letter is required in advance of any work and is retained on file. An electronic copy is also retained. Investment Management RS Crum, Inc. manages client accounts on an individual basis separate from other client portfolios. Our goal is to manage risk and accumulate wealth safely for our clients. Individual portfolios are based on an asset allocation invested across an array of asset classes that may include cash, stocks, bonds, and alternative investments. RS Crum, Inc. provides continuous and regular investment services on a discretionary basis. We have the ongoing responsibility to select and/or make recommendations, based upon the objectives of the client, as to specific securities and / or asset allocation. Our investment management services include designing, implementing, and continued monitoring of client accounts, limited only by the client’s individual needs and any restrictions imposed on the account. Our asset allocation models and recommendations for new portfolios consist of various types of securities, depending on the investment objective of each model, the client’s objectives, and/or the size of 8 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure the account. Below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss we discuss the types of securities that we recommend. Non-managed Accounts Assets or securities that are identified as non-managed are removed from managed accounts or designated as non-managed within RS Crum, Inc.’s portfolio management platform. RS Crum, Inc. will only be responsible for the supervision and management of securities we recommend. RS Crum, Inc. will not be responsible for the supervision or management of non-managed assets. Non-managed assets are not included in the calculation of portfolio investment performance or fees, nor does RS Crum, Inc. monitor non-managed assets. Non-managed assets may include securities held in a client’s account that is under management with RS Crum, Inc. that were: 1. Delivered into the account by the client; 2. Purchased by the client; 3. Purchased by RS Crum, Inc. at the request of the client as an accommodation; or 4. Designated by the client to be non-managed securities. Clients are instructed to keep RS Crum, Inc. informed of changes in their financial situation. Financial Planning RS Crum, Inc. offers advice through written financial plans and/or consultations. Written plans may involve analysis and discussions with the client, and usually involve cash flow projections to model the potential outcomes of retirement, estate planning, and other decisions. This might include examining different retirement dates, real estate or business sales, evaluating employee stock options, educating children or grandchildren, support of parents or heirs with special needs, inheritances or other scenarios. Certain consultations address immediate and specific issues, such as deciding on a pension option, leasing or buying a car or choosing a mortgage. Analysis or research of such topics may be limited since these are discussions to resolve a short-term concern. Financial planning may be the only service provided to the client and does not require that the client use or purchase the investment advisory services offered by the Firm. The client is under no obligation to act upon RS Crum, Inc.’s recommendations, and if the client elects to act on any of the recommendations, the client is under no obligation to implement through the Firm. Retirement Investment Advice When we provide investment advice to clients regarding their retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement 9 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of our advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC between our interests and the clients’ interests, so we operate under a special rule that requires us to act in the clients’ best interests and not put our interest ahead of theirs. For example, if we recommend that a client roll over assets from one retirement account to another and receive increased compensation as a result of that recommendation, we have a conflict that requires us to operate under this special rule. Assets Under Management RS Crum, Inc.’s discretionary assets under management as of December 31, 2024, were $604,371,190. For some clients, RS Crum, Inc. provides investment advice, supervision of, and reporting of accounts on a non-discretionary basis. As of December 31, 2024, RS Crum, Inc.’s non-discretionary assets under management were $12,611,268. Item 5 – Fees and Compensation Fees are negotiable and are discussed and agreed upon with clients prior to the beginning of services. The following is RS Crum, Inc’s standard tiered fee schedule applied as a percentage of assets under management (AUM). Assets Under Management (AUM) Up to $1 Million From $1 Million to $5 Million From $5 Million to $10 Million Greater than $10 Million Annual Percentage 1.0% 0.75% 0.50% 0.25% This schedule may be discounted depending on several factors, including but not limited to, the scope and complexity of the services provided, the total value of assets managed, the number of accounts and/or the individual needs of the client. Discounts may take the form of a lower starting annual percentage and/or amended AUM break points. Effective AUM rates (the rate paid on your total AUM) range from 0.4% – 1.00% of assets under management (AUM) annually. Accounts may also be subject to a minimum quarterly fee. For some legacy clients, RS Crum, Inc. has applied either a fixed or flat fee (retainer) or a different Annual Percentage of AUM schedule than described above. These fee schedules are documented in the respective clients’ written Advisory Agreement and may still be in effect for these clients. The specific manner and frequency fees are charged is established in a client’s written Advisory Agreement. The Firm will generally bill fees quarterly, in advance, based on the market value of assets in 10 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure the account on the last business day of the previous quarter. The Firm has used a monthly billing frequency in the past and some legacy clients remain on that cycle. Each client’s specific fee schedule is documented in the written Advisory Agreement. For the majority of clients, RS Crum, Inc. accepts the authority to bill (debit) client account(s) directly for fees. Clients receive an informational invoice prior to fees being debited. Normally, fees are withdrawn within ten (10) business days after the invoice date. The account custodian withdraws advisory fees from the client’s account based on our instruction, as outlined in our Advisory Agreement. All clients will receive brokerage statements from the custodian no less frequently than quarterly that will show the deduction of the advisory fee. RS Crum, Inc. will send an invoice to all clients who choose not to have advisory fees withdrawn directly from their custodian account and clients can pay management fees by check. The invoice is payable upon receipt and will include the fee calculation and amount due. Some employees are compensated through an annual salary with bonuses. For some employees, a bonus is based on the amount of a client’s first year fee. This creates an incentive to charge a higher fee and/or manage more of a client’s assets. RS Crum, Inc.’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses, which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment providers and other parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to RS Crum, Inc.’s fee. RS Crum, Inc. does not receive any portion of these commissions, fees, and costs. Later in this brochure, Item 12 – Brokerage Practices further describes the factors that RS Crum, Inc. considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Cancellation of Services (Limited Duration or Continuous) Services can be cancelled by either party at any time without penalty by written notice. Clients shall be charged pro rata for services provided through the date of termination. If the client made an advance payment, RS Crum, Inc. will refund any unearned portion of the advanced payment. Item 6 – Performance-Based Fees and Side-By-Side Management 11 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure RS Crum, Inc. does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients RS Crum, Inc. typically provides services to high income and high net worth individuals, trusts, estates, or charitable organizations. In addition, we provide services to businesses such as corporations, LLCs, sole proprietorships or pension and retirement plans. Other than RS Crum, Inc.’s minimum fee, no account requirement is maintained for portfolio management services (See Item 5 Fees and Compensation). Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The main sources of information include financial newspapers and magazines, research materials and services prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Security analysis methods include fundamental analysis. Investment Strategies RS Crum, Inc. manages client accounts on an individual basis utilizing an allocation model that invests in a broad spectrum of investment categories. These categories may include cash, bonds, equities (stocks), ETFs, mutual funds, and alternative investments. Portfolios are globally diversified to manage the risk associated with traditional markets. RS Crum, Inc. seeks to select securities with characteristics that are consistent with the investment objectives of each investment category. Since client portfolios are managed individually, portfolios with a similar investment objective and asset allocation may differ. Timing, account size and tax factors may also influence our investment decisions. Our asset allocation models and recommendations include mutual fund only allocations. The mutual funds recommended may include mutual funds offered by Dimensional Fund Advisors (“DFA”). Our recommendations are not limited to DFA funds. DFA offers professionally managed mutual funds at relatively low expense ratios and are not available directly to individual investors but are limited to a select group of independent financial advisors approved by DFA. We are unaffiliated with DFA. RS Crum, Inc.’s advisory representatives work with clients to determine their investment objectives, time horizon, income needs as well as their ability to take risk, need to take risk, tax considerations, and any 12 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure special considerations and/or restrictions in order to develop the asset allocation and portfolio construction utilized for the client. We are responsible for the supervision and management of securities we recommend. For information on the treatment of Non-Managed Accounts and / or Securities, please see above Item 4 Advisory Business. Investing Involves Risk Investing in securities involves risk of loss that clients should be prepared to bear. General Risks of Owning Securities The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect security prices and income. Specific Security Risks Mutual Funds (Open-end Investment Company) A mutual fund is a company that pools money from many investors and invests the money in stocks, bonds, short-term money-market instruments, other securities or assets, or some combination of these investments. The portfolio of the fund consists of the combined holdings it owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the income those holdings generate. The price that investors pay for mutual fund shares is the fund’s per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of purchase. Exchange-Traded Funds (ETFs) An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) containing a basket of stocks. Typically, the objective of an ETF is to achieve returns similar to a particular market index, including sector indexes. An ETF is similar to an index fund in that it will primarily invest in securities of companies that are included in a selected market. Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange. Like stock mutual funds, the prices of the underlying securities and the overall market may affect ETF prices. Similarly, factors affecting a particular industry segment may affect ETF prices that track that particular sector. Equity Securities 13 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Equity securities represent an ownership position in a company. Equity securities typically consist of common stocks. The prices of stocks and the income they generate (such as dividends) may fluctuate based on events specific to the company that issued the shares, conditions affecting the general economy and overall market changes, changes or weakness in the business sector the company does business in, and other factors. Further, prices of these securities can be affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the security or other assets or indices. Debt Securities (Bonds) Issuers use debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Cash and Cash Equivalents The account may hold cash or invest in cash equivalents. Cash and cash equivalents are the most liquid of investments. Cash and cash equivalents are considered very low-risk investments, meaning, there is little risk of losing the principal investment. Typically, low risk also means low return and the interest an investor can earn on this type of investment is low relative to other types of investing vehicles. Other Business Risks Cybersecurity Risk Investment advisers and their service providers may be prone to operational and information security risks resulting from cyber-attacks. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally (including, for example, through cyber- attacks known as “phishing” and “spear-phishing”), denial-of-service attacks on websites, the unauthorized release of confidential information and causing operational disruption. Cyber-attacks may interfere with the processing of transactions, cause the release of private information or confidential information of RS Crum, Inc., cause reputational damage, and subject RS. Crum Inc. to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. While RS Crum, Inc. has established business continuity plans and systems designed to prevent such cyber-attacks, there are limitations in such plans including the possibility that certain risks have not been identified or mitigated Coronavirus or Pandemic Risk The global outbreak of the 2019 novel coronavirus (“COVID-19”), together with resulting voluntary and 14 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure U.S. federal and state and non-U.S. governmental actions, including, without limitation, mandatory business closures, public gathering limitations, restrictions on travel and quarantines, has meaningfully disrupted the global economy and markets. Although the long-term economic fallout of COVID-19 is difficult to predict, it has and is expected to continue to have ongoing material adverse effects across many, if not all, aspects of the regional, national and global economy. A pandemic such as COVID-19 may impact the ability of RS. Crum Inc. to operate effectively, including the ability of its personnel or its service providers and other contractors to function, communicate and travel to the extent necessary. The spread of any contagious and debilitating health condition among RS Crum, Inc.’s personnel and its service providers may also affect RS Crum, Inc.’s ability to properly perform our duties. Item 9 – Disciplinary Information Registered investment advisers are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc. or the integrity of the Firm’s management. RS Crum, Inc. and our personnel seek to maintain the highest level of business professionalism, integrity, and ethics. The Firm and its employees have not been involved in any legal or disciplinary events. Item 10 – Other Financial Industry Activities and Affiliations RS Crum, Inc.’s principal business is providing investment and financial advice and its only source of compensation is from fees paid directly to the Firm by clients. Neither RS Crum, Inc., nor any of its management or other personnel, accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Additionally, RS Crum, Inc. does NOT pay, directly or indirectly, for client referrals or accept any other form of kickback or compensation. Although RS Crum, Inc. is a member of several industry trade associations, it does not have any affiliations that are material to its business or present any conflict of interest with its clients. While we may refer clients to other professionals (see Item 14 below), we receive no compensation and do not believe that any of these referrals creates a material conflict of interest. Item 11 – Code of Ethics 15 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure RS Crum, Inc. believes that we owe clients the highest level of trust and fair dealing. As part of our fiduciary duty, we place the interests of our clients ahead of the interests of the Firm and our personnel. RS Crum, Inc.’s personnel are required to conduct themselves with integrity and follow the principles and policies detailed in our Code of Ethics. RS Crum, Inc.’s Code of Ethics attempts to address specific conflicts of interest that either we have identified or that could likely arise. Our personnel are required to follow clear guidelines from the Code of Ethics in areas such as gifts and entertainment, other business activities, prohibitions of insider trading, and adherence to applicable state and federal securities laws. Additionally, individuals who formulate investment advice for clients, or who have access to nonpublic information regarding any clients’ purchase or sale of securities, are subject to personal trading policies governed by the Code of Ethics (see below). RS Crum, Inc. and its affiliates may trade for their own accounts in securities, which are recommended to and/or purchased for RS Crum, Inc.’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of RS Crum, Inc. 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. The Code of Ethics requires pre-clearance of many employee transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between RS Crum, Inc. and its clients. The Chief Compliance Officer of RS Crum, Inc. is Daniel Sexton. He reviews employee trades each quarter, except for his own trading activity that is reviewed by another principal or officer of the Firm. Under the Code of Ethics, certain classes of securities (i.e., open-end mutual funds and U.S. Government Securities) have been designated as exempt transactions, based upon a determination that trading in these would not materially interfere with the best interest of RS Crum, Inc.’s clients. RS Crum, Inc.’s clients or prospective clients may request a copy of the Firm's Code of Ethics by contacting our office. Item 12 – Brokerage Practices Investment Management RS Crum, Inc. requires clients to open one or more custodian accounts in their own name at a qualified custodian of the client’s choice. We encourage the use of a discount type broker and often recommend that clients custody assets through Charles Schwab & Co., Inc. (“Schwab”). A client is not under any 16 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure obligation to effect trades through any recommended broker or custody their assets with any broker-dealer we recommend. All clients are free to select any broker-dealer of his or her choice. The client will enter into a separate agreement with the broker-dealer/custodian to custody the assets. For clients that we provide investment management services to we require that clients grant us limited power of attorney to execute client transactions. RS Crum, Inc. is independently owned and operated, and unaffiliated with any broker-dealer/custodian. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. This does not require us to solicit competitive bids and does not have an obligation to seek the lowest available commission price. We consider a wide range of factors, including, among others: 1. Combination of transaction execution services and asset custody services (generally without a separate fee for custody) 2. Capability to execute, clear, and settle trades (buy and sell securities for your account) 3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) 4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) 5. Availability of investment research and tools that assist us in making investment decisions 6. Quality of services 7. Competitiveness of the price of those services (commission rates and other fees) and willingness to negotiate the prices 8. Reputation, financial strength, and stability 9. Prior service to us and our other clients 10. Availability of other products and services that benefit us, as discussed below (see Products and Services Available to Us From Schwab) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services. However, Schwab receives compensation by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. This commitment benefits you because the overall commission rates you pay are lower than they would be otherwise. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on relevant factors, including those listed above (see How We Select Brokers/Custodians). Products and Services Available to Us from Schwab 17 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like us. They provide RS Crum, Inc. and our clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. If our clients collectively have less than $10 million in assets at Schwab, Schwab may charge us quarterly service fees of $1,200. Following is a more detailed description of Schwab’s support services: Services That Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: 1. Provide access to client account data (such as duplicate trade confirmations and account statements) 2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts 3. Provide pricing and other market data 4. Facilitate payment of our fees from our clients’ accounts 5. Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 1. Educational conferences and events (which may include Schwab paying for related travel expenses, entertainment and meals associated with attending) 18 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure 2. Consulting on technology, compliance, legal, and business needs 3. Publications and conferences on practice management and business succession 4. Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We do not have to pay for Schwab’s services so long as our clients collectively keep a total of at least $10 million of their assets in accounts at Schwab. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. The $10 million minimum may give us an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. We primarily support our selection of Schwab by the scope, quality, and price of Schwab’s services (see How We Select Brokers/Custodians, above) and not Schwab’s services that benefit only us. Directed Brokerage Transactions We are prepared to work with any broker-dealer that the client chooses, and the client may direct the RS Crum, Inc. to use a particular broker-dealer to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that broker-dealer, and RS Crum, Inc. will not seek better execution services or prices from other broker-dealers or be able to “batch” client transactions for execution through other broker-dealers with orders for other accounts managed by RS Crum, Inc. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to RS Crum, Inc.’s duty of best execution, the Firm may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Aggregation and Allocation of Transactions RS Crum, Inc. sometimes aggregates transactions in like securities among client accounts as well as with accounts of RS Crum, Inc. and our personnel. Aggregation presents a conflict of interest as we may have an incentive to allocate more favorable executions to our own accounts or the accounts of our personnel. Our policies to address this conflict are as follows: 19 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure 1. We will disclose our aggregation policies in this brochure; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek best execution (which includes the duty to seek best price) for our clients. The trade also needs to be consistent with the terms of our investment advisory agreement with each client that has an account included in the aggregation; 3. We will not favor any account over any other account. This includes accounts of RS Crum, Inc. or any of our personnel. Each account in the aggregated order will participate at the average share price for all of our transactions in a given security on a given business day (per custodian). All accounts will pay their individual transaction costs; 4. Before entering an aggregated order, we will prepare a written statement (the “Allocation Statement”) specifying the participating accounts and how we intend to allocate the order among those accounts; 5. If the aggregated order is filled entirely, we will allocate shares among clients according to the Allocation Statement; if the order is partially filled, we will generally allocate it pro-rata according to the Allocation Statement. However, we may allocate the order differently than specified in the Allocation Statement if all client accounts receive fair and equitable treatment. Examples include but are not limited to: a. When only a small percentage of the order is executed, with respect to purchase allocations, allocations may be given to accounts high in cash; b. With respect to sale allocations, allocations may be given to accounts low in cash; c. We may allocate shares to the account with the smallest order, or to the smallest position, or to an account that is out of line with respect to security or sector weightings, relative to other portfolios with similar mandates; d. We may allocate to one account when that account has limitations in its investment guidelines prohibiting it from purchasing other securities that we expect to produce similar investment results and that can be purchased by other accounts in the block; e. If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account’s assets after an order is placed; In any case, we will explain the reasons for a different allocation in writing, which the CCO must approve; 20 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure 6. If an aggregated order is partially filled and we allocate it differently than the Allocation Statement specifies, no participating account may purchase or sell the security for a reasonable period following the execution of the block trade. This only applies when the participating account sells or receives more shares than it would have if the aggregated order been completely filled; 7. Our books and records will separately reflect each aggregated order and the securities held by, bought, and sold for each client account; 8. Funds and securities of clients participating in an aggregated order will be deposited with one or more qualified custodians. Clients’ cash and securities will not be held collectively any longer than is necessary to settle the trade on a delivery versus payment basis. Following settlement, cash or securities held collectively for clients will be delivered out to the qualified custodian as soon as practical; 9. We do not receive additional compensation or remuneration of any kind as a result of aggregating orders; and 10. We will provide individual investment advice and treatment to each client’s account. Item 13 – Review of Accounts Managed Account Reviews & Reporting RS Crum, Inc.’s Advisers are responsible for assigning an investment model to each account or, on occasion, assigning a model to a household of client accounts. With the use of a third-party trading software/service, accounts are monitored for trading opportunities due to, but not limited to, cash needs, deposits and withdrawals, and deviation from model allocation. The monitoring of accounts and the creation of trade tickets is delegated to our Trader. The Trader will exercise diligence in entering and executing trades for clients. When necessary, trades identified by the Trader are reviewed by the Adviser for consistency with client goals and/or tax considerations. We will provide reports per the terms outlined in the client Advisory Agreement. Generally, we compile periodic investment reports and Statement of Assets and provide these to clients. Most clients receive a Statement of Assets semi-annually. Some clients receive reports as frequently as quarterly. RS Crum, Inc.’s Statement of Assets report contains portfolio performance for the period, portfolio value, and a listing of individual securities. Each client receives a written statement from the custodian that includes an accounting of all holdings and transactions in the account for the reporting period. 21 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Financial Plan Reviews & Reporting RS Crum, Inc. provides financial planning services on a comprehensive and limited basis. We work with clients on an ongoing basis to review the plan as needed or as requested by the client. Item 14 – Client Referrals and Other Compensation Schwab Support Products and Services We receive an economic benefit from Schwab in the form of the support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). We do not base particular investment advice, such as buying particular securities for our clients, on the availability of Schwab’s products and services to us. Recommendation of Unaffiliated Professionals We may refer clients to unaffiliated professionals for a variety of services such as insurance, mortgage brokerage, real estate sales, legal, and/or tax/accounting services. In turn, these professionals may refer clients to RS Crum, Inc. for investment management/financial planning needs. We will not refer clients to financial planners and other investment advisers unless they are licensed, registered, or exempt from registration as an investment adviser. We do not have any arrangements with individuals or companies that we refer clients to, and we do not receive any compensation for these referrals. However, it could be concluded that RS Crum, Inc. is receiving an indirect economic benefit from this practice, as the relationships are mutually beneficial. For example, there could be an incentive for us to recommend services of firms who refer clients to RS Crum, Inc. We refer clients to professionals we believe are competent and qualified in their field. It is ultimately the client’s responsibility to evaluate the provider. We will generally provide the client with a list of professionals that the client can contact, and it is solely the client’s decision whether to engage a recommended firm. Clients are under no obligation to purchase any products or services through these professionals, and RS Crum, Inc. has no control over the services provided by another firm. Clients who choose to engage these professionals will sign a separate agreement with the other firm. Fees charged by the other firm are separate from and in addition to fees charged by RS Crum, Inc. If the client desires, RS Crum, Inc. will work with these professionals or the client’s other advisers (such as an accountant, attorney, or other investment adviser) to help ensure that the provider understands the client’s financial plan/investments and to coordinate services for the client. RS Crum, Inc. does not share information with an unaffiliated professional unless first authorized by the client. 22 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure Item 15 – Custody Clients will engage an independent broker-dealer/custodian to maintain their account(s) and, as such, RS Crum, Inc. will not have physical custody of Client assets, monies or securities. However, RS Crum, Inc. maintains a limited power of attorney over clients’ accounts when clients authorize us to deduct our management fees directly from the client’s account. Since RS Crum, Inc. may withdraw investment advisory fees directly from Clients’ accounts, RS Crum, Inc. is considered to have custody in a limited capacity. All checks or wire transfers for deposit to client accounts are required to be made out to or sent to the account custodian. Clients will receive statements directly from their qualified custodian at least quarterly. The statements will reflect the client’s funds and securities held with the qualified custodian as well as any transactions that occurred in the account, including the deduction of our fee. Clients should carefully review the account statements they receive from the qualified custodian. When clients receive statements from RS Crum, Inc. as well as from the qualified custodian, they should compare these two reports carefully. Clients with any questions about their statements should contact us at the address or phone number on the cover of this brochure. Clients who do not receive a statement from their qualified custodian at least quarterly should also notify us. RS Crum, Inc. is deemed to have custody of clients’ funds or securities when clients have a standing letter of authorization (“SLOA”) with their custodian to move money from a client’s account to a third-party and, under that SLOA, authorize us to designate the amount or timing of transfers to those specifically authorized account(s) with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. Item 16 – Investment Discretion Discretionary Management RS Crum, Inc. usually receives discretionary trading authority (via a Limited Power of Attorney) from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. RS Crum, Inc. does not contact clients before placing trades in their account, but clients will receive confirmations directly from the broker for any trades placed. Clients grant us discretionary authority in the agreement they sign with us. Clients also give us trading authority over their accounts when they sign the custodian paperwork. 23 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure However, certain client-imposed conditions may limit our discretionary authority, such as where the client prohibits transactions in specific security types or industries or directs RS Crum, Inc. to execute transactions through specific broker-dealers. Non-Discretionary Management For non-discretionary accounts, RS Crum, Inc. will contact the client before making recommendations we deem appropriate for the client. Non-discretionary clients should be aware that recommendations are typically time sensitive and the following circumstances may cause market movements to work against the client: • When we have trading authority, RS Crum, Inc. will not effect the transaction until we receive verbal or written instructions from the client; • When we do not have trading authority, the client is responsible for placing the trade; • RS Crum, Inc. generally will not aggregate transactions for non-discretionary accounts with discretionary accounts; and • Transactions for non-discretionary accounts will generally be effected after transactions in discretionary accounts. Item 17 – Voting Client Securities As a matter of Firm policy and practice, RS Crum, Inc. does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent. RS Crum, Inc. might provide advice, if requested, regarding the clients’ voting of proxies. RS Crum, Inc. will not be deemed to have proxy voting authority solely as a result of providing advice or information about a particular proxy vote to a client. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in the plan accounts. Item 18 – Financial Information 24 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum, Inc. Form ADV Part 2A Brochure RS Crum, Inc. has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 25 RS Crum, Inc. Brochure Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Form ADV, Part 2B Brochure Supplement Mark Rylance, CFP® Jon Theriault, CFP® Daniel Sexton, CFP® Eric Papa, CFP® RS Crum, Inc. 4 Upper Newport Plaza Drive Suite 201 Newport Beach, CA 92660 (949) 428-9696 www.rscrum.com March 27, 2025 This Brochure Supplement provides information about Mark Rylance, Jon Theriault, Daniel Sexton, and Eric Papa that supplements the RS Crum, Inc. Brochure. You should have received a copy of that Brochure. Please contact our office if you did not receive a copy or if you have any questions about the contents of this supplement. Additional information about Mark Rylance, Jon Theriault, Daniel Sexton, and Eric Papa is available on the SEC’s website at www.adviserinfo.sec.gov. i RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Supervised Persons RS Crum, Inc.’s Supervised Persons are its officers (or other persons occupying a similar status or performing similar functions) and employees, as well as other persons who provide advice on behalf of the Firm and are subject to RS Crum, Inc.’s supervision and control. Description of Professional Designations Used in this Brochure Supplement CERTIFIED FINANCIAL PLANNER™ The CERTIFIED FINANCIAL PLANNER™ and CFP® (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. The CFP® is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To earn the credential, each CFP® candidate must have a bachelor’s degree (or higher) from an accredited college or university and three years of full-time personal financial planning experience. In addition, candidates must take the CFP® Certification examination and complete a CFP® board- registered program or hold an accepted designation, degree, or license. Every two years, CFP® certificate holders must complete a minimum of 30 hours of continuing education. More information regarding the CFP® is available at http://www.cfp.net/default.asp. ii RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Mark Rylance, CFP® Item 2 - Educational Background and Business Experience Born: 1968 Education: University of Arizona - BS Business Administration CERTIFIED FINANCIAL PLANNER™ (CFP®) Background: RS Crum, Inc., Lead Advisor / Owner – 2011 to Present RS Crum, Inc., Lead Advisor – 2003 to 2011 Prior to coming to RS Crum, Inc., Mr. Rylance worked for 6 years at Merrill Lynch as a financial consultant for their Private Client Group. Professional Designations: CERTIFIED FINANCIAL PLANNER™ Item 3 - Disciplinary Information Registered investment advisers and their supervised persons are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr. Rylance or the integrity of RS Crum, Inc.’s management. Not applicable; Mr. Rylance has no legal or disciplinary action applicable to his status and / or registration. Item 4 - Other Business Activities RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of compensation are fees paid to the Firm directly by the client. Neither RS Crum, Inc. nor Mr. Rylance accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Although Mr. Rylance is a member of several industry trade associations, he does not have any affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients. Item 5 - Additional Compensation Mr. Rylance receives no other compensation besides his salary, bonus, and other customary employment benefits. Item 6 - Supervision RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance is responsible for the general supervision of Supervised Persons of the Firm; however, he is not supervised. Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of others will exercise reasonable supervision over those subject to their supervision or authority to prevent iii RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to them. RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and allocate resources for client care, services, and business priorities. In addition, the Firm requires Supervised Persons and employees to complete regular financial disclosures and review, at least annually, the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility. iv RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Jon Theriault, CFP® Item 2 - Educational Background and Business Experience Born: 1972 Education: University of Arizona - BS Business Administration Pepperdine University – MBA (Finance) CERTIFIED FINANCIAL PLANNER™ (CFP®) Background: RS Crum, Inc., Lead Advisor / Owner – 2011 to Present RS Crum, Inc., Lead Advisor – 2008 to 2011 Prior to coming to RS Crum, Inc. Mr. Theriault worked for 13 years providing consulting, valuation, and merger and acquisition advisory services to privately held business owners. Professional Designations: CERTIFIED FINANCIAL PLANNER™ Item 3 - Disciplinary Information Registered investment advisers and their supervised persons are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr. Theriault or the integrity of RS Crum, Inc.’s management. Not applicable; Mr. Theriault has no legal or disciplinary action applicable to his status and / or registration. Item 4 - Other Business Activities RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of compensation are fees paid to the Firm directly by the client. Neither RS Crum, Inc. nor Mr. Theriault accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Although Mr. Theriault is a member of several industry trade associations, he does not have any affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients. Item 5 - Additional Compensation Mr. Theriault receives no other compensation besides his salary, bonus, and other customary employment benefits. Item 6 - Supervision RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling 949-428-9696. v RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of others will exercise reasonable supervision over those subject to their supervision or authority to prevent violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to them. RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and allocate resources for client care, services, and business priorities. In addition, the Firm requires Supervised Persons and employees to complete regular financial disclosures and review, at least annually, the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility. vi RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Daniel Sexton, CFP® Item 2 - Educational Background and Business Experience Born: 1966 Education: California State University, Long Beach BS Business (Finance), Minor Business Economics CERTIFIED FINANCIAL PLANNER™ (CFP®) Background: RS Crum, Inc., Lead Advisor / Owner – 2011 to Present RS Crum, Inc., Lead Advisor – 2003 to 2011 RS Crum, Inc. (formerly RS Crum Advisory Services), Employee 1996 to 2003 Prior to coming to RS Crum, Inc. Mr. Sexton was employed in the aerospace industry as a technical writer. Professional Designations: CERTIFIED FINANCIAL PLANNER™ Item 3 - Disciplinary Information Registered investment advisers and their supervised persons are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr. Sexton or the integrity of RS Crum, Inc.’s management. Not applicable; Mr. Sexton has no legal or disciplinary action applicable to his status and / or registration. Item 4 - Other Business Activities RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of compensation are fees paid to the Firm directly by the client. Neither RS Crum, Inc. nor Mr. Sexton accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Although Mr. Sexton is a member of several industry trade associations, he does not have any affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients. Item 5 - Additional Compensation Mr. Sexton receives no other compensation besides his salary, bonus, and other customary employment benefits. Item 6 - Supervision RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling 949-428-9696. vii RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of others will exercise reasonable supervision over those subject to their supervision or authority to prevent violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to them. RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and allocate resources for client care, services, and business priorities. In addition, the Firm requires Supervised Persons and employees to complete regular financial disclosures and review, at least annually, the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility. viii RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement Eric Papa, CFP® Item 2 - Educational Background and Business Experience Born: 1995 Education: UCSB – BA Economics American College of Financial Services – CFP® Certification Education Program CERTIFIED FINANCIAL PLANNER™ (CFP®) Background: RS Crum, Inc., Associate Advisor – 2024 to Present Prior to coming to RS Crum, Inc., Mr. Papa worked for 2 1/2 years as a Financial Planning Specialist and 2 years as a Private Wealth Associate providing financial planning service and analysis for individuals. Professional Designations: CERTIFIED FINANCIAL PLANNER™ Item 3 - Disciplinary Information Registered investment advisers and their supervised persons are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr. Papa or the integrity of RS Crum, Inc.’s management. Not applicable; Mr. Papa has no legal or disciplinary action applicable to his status and / or registration. Item 4 - Other Business Activities RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of compensation are fees paid to the Firm directly by the client. Neither RS Crum, Inc. nor Mr. Papa accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Although Mr. Papa is a member of several industry trade associations, he does not have any affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients. Item 5 - Additional Compensation Mr. Papa receives no other compensation besides his salary, bonus, and other customary employment benefits. Item 6 - Supervision RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling 949-428-9696. Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of others will exercise reasonable supervision over those subject to their supervision or authority to prevent violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons ix RS Crum, Inc. Brochure Supplement Revised March 27, 2025 RS Crum Inc. Form ADV Part 2A Brochure Supplement may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to them. RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and allocate resources for client care, services, and business priorities. In addition, the Firm requires Supervised Persons and employees to complete regular financial disclosures and review, at least annually, the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility. x RS Crum, Inc. Brochure Supplement Revised March 27, 2025