RAUB BROCK CAPITAL MANAGEMENT, LP

Item 1 Cover Page FORM ADV PART 2A* Brochure March 2025 700 Larkspur Landing Circle, Suite 240 Larkspur, California 94939 www.raubbrock.com Tel: 415.927.6990 Fax: 415. 927-6996 *This brochure provides information about the qualifications and business practices of Raub Brock Capital Management, LP. If you have any questions about the contents of this brochure, please contact the Firm’s Chief Compliance Officer at telephone 415.927.6990. The information in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission or by any state authority. Raub Brock Capital Management, LP is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment advisor provide you with the information you need to determine whether to hire or retain the advisor. Additional information about Raub Brock Capital Management, LP is available on the U.S. Securities and Exchange Commission website at www.advisorinfo.sec.gov. The firm’s CRD number is 153994. 1  Item 2 MATERIAL CHANGES FROM PRIOR FORM ADV PART 2A This updated Form ADV Part 2A contains the following changes from the prior version: - Updated description of the Firm’s assets under management at Part 2A, Item 4. - No material updates to professional biographies at Part 2B. Item 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ......................................................................................................................... 1 ITEM 2 MATERIAL CHANGES FROM PRIOR FORM ADV PART 2A ................................................ 2 ITEM 3 TABLE OF CONTENTS ............................................................................................................ 2 ITEM 4 ADVISORY BUSINESS ............................................................................................................ 3 ITEM 5 FEES AND COMPENSATION ................................................................................................ 6 ITEM 6 PERFORMANCE-BASED FEES .............................................................................................. 9 ITEM 7 TYPES OF CLIENTS ................................................................................................................ 9 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS ................................ 10 ITEM 9 DISCIPLINARY INFORMATION ........................................................................................... 12 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................... 12 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .......................................................................................................... 13 ITEM 12 BROKERAGE PRACTICES ................................................................................................... 14 ITEM 13 REVIEW OF ACCOUNTS .................................................................................................... 18 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .......................................................... 18 ITEM 15 CUSTODY............................................................................................................................ 19 ITEM 16 INVESTMENT DISCRETION .................................................................................................. 19 ITEM 17 VOTING CLIENT SECURITIES .............................................................................................. 20 ITEM 18 FINANCIAL INFORMATION ................................................................................................ 20 INDEX OF ERISA RELATED DISCLOSURES ........................................................................................ 20 2  Item 4 ADVISORY BUSINESS Raub Brock Capital Management, LP (sometimes “Raub Brock,” the “Firm” or “Advisor”), a California limited partnership, provides investment management and financial planning services to its clients. Raub Brock and its predecessor firms have been providing investment management and planning services since 1989. Our current formation as a limited partnership was registered with the U.S. Securities and Exchange Commission (“SEC”) in 2010. Raub Brock’s principal owner is Richard H. Alpert. ASSETS UNDER MANAGEMENT AS OF DECEMBER 31, 2024 Discretionary Assets – $ 488,314,961 Non-discretionary Assets – $ 2,736,043,828 Total Assets Under Management - $ 3,224,358,789 ADVISORY SERVICES We are a disciplined, bottom up, concentrated U.S. equity investment manager. Our primary investment focus is on high quality, dividend growth large cap equity securities. We manage accounts of all types (individual, trust, retirement accounts, etc.) for individual private clients and separately managed, unified managed and wrap accounts for various types of institutional clients, including family offices, banks, pension and profit-sharing plans and third-party asset managers. Investment Management Services – Individually Managed Private Client Accounts Through conversations with clients and its financial planning process, Raub Brock and its clients agree upon investment objectives, guidelines and an asset allocation strategy based upon the client’s financial condition and investment objectives, investment experience, time horizon, risk tolerance level, income requirement and other factors. The Firm generally accepts new client relationships of $1 million or above; multiple investment accounts may be aggregated to meet this minimum. Raub Brock’s investment advisory services generally include: • Gathering information to determine client investment profile, such as: goals (financial and lifestyle), personal financial information (age, income, expenses, net worth, etc.) investment objectives (income, growth, liquidity, tax deferral, etc.) investment horizon and risk tolerance. • The determination of an appropriate asset allocation for the client’s investment portfolio, in accordance with the client’s specific financial objectives and risk tolerance and in consideration of other factors, including the client’s financial assets, real property, cash flow, liquidity needs, insurance and time horizon (education funding, home purchase, retirement, legacy planning). Clients may identify any investment restrictions to be placed on their account. Each client’s financial objectives, risk tolerance, and liquidity needs, along with a recommended asset allocation and permitted investments, are incorporated into an investment plan that is customized to the client. In the process, Raub Brock may adjust its investment policy with consideration to the client’s securities that are not under Raub Brock’s management. • Monitoring each client’s securities transactions, portfolio holdings and asset allocation on a continuous basis. 3  We offer a number of different investment strategy models to our private individual clients, based upon their individual investment goals and risk tolerance. Individual private client portfolios are most often a blend of our dominant investment model, the Dividend Growth Portfolio equity strategy and a client-tailored selection of mutual funds, exchange-traded funds, fixed income funds, real estate investment trusts and publicly traded limited partnerships to achieve portfolio exposure in specific asset classes, such as stocks traded on foreign exchanges, small capitalization stocks, emerging market stocks, real estate, natural resources, commodities, alternatives and bonds. A client retains the authority to make additions to and withdrawals from their portfolio account at any time, subject to the Firm’s right to terminate an account if the amount of assets drops below our account size minimum. Clients can withdraw account assets with notice to the Firm, subject to the usual and customary securities settlement procedures. However, we design client portfolios as long-term investments and caution our clients that asset withdrawals will impair the achievement of the client’s investment objectives. Additions to an account may be in cash or securities provided that we may decline to accept particular securities into a client’s account or may recommend that the security be liquidated if it is inconsistent with the Firm’s investment strategy or the client’s investment objectives. Clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Investment Management Services – Sub-advisory Services to Institutional Clients In addition to providing investment management services to individual private clients and family offices, Raub Brock provides sub-advisory investment management services to large institutional clients through separately managed account programs (SMA), unified managed account programs (UMA) and wrap fee programs. Such institutional clients are interested exclusively in the Firm’s Dividend Growth Portfolio equity strategy, (for institutional clients, referred to herein as the “Model Portfolio”). The securities recommendations comprising the Model Portfolio are the same securities recommendations that the Firm by and large follows for its individually managed private client accounts. The fees paid to Raub Brock under these sub-advisory arrangements are generally lower than the traditional management fees charged by Raub Brock. These sub-advisory relationships with institutional clients fall into three categories: • Model Portfolio Services – With Trade Executions. Certain institutional SMA advisor clients retain the Firm so that their underlying retail clients can access the Model Portfolio for their own investment accounts. Raub Brock’s services to some of these SMA programs includes development of the Model Portfolio, research, updates and monitoring of the Model Portfolio, and trade executions on behalf of the underlying SMA client accounts in response to model updates. Raub Brock does not enter into a direct relationship with the underlying clients of the SMA programs and does not provide account-specific performance reporting services to those underlying program participant clients. • Model Portfolio Services – With Notice of Model Updates Only. Different institutional SMA advisor and its UMA advisor clients also retain Raub Brock in order that their underlying retail clients can access the Model Portfolio for their investment accounts. However, Raub Brock’s services to these other SMA and UMA programs include only development 4  of the Model Portfolio, research, updates to and monitoring of the Model Portfolio, and “notice only” of model updates. For these program clients, the Firm does not provide trade execution services in response to model updates and does not provide account- specific performance reporting services to underlying clients. Raub Brock does not enter into a direct relationship with the underlying clients of the UMA and SMA programs. • Portfolio Management Services – Wrap Fee Programs. Raub Brock also provides portfolio management services to “wrap fee” programs sponsored by institutional client firms that want to make the Model Portfolio available to underlying wrap program participants. Wrap fee program sponsors typically offer comprehensive brokerage, custodial and advisory services for a single “wrap fee” based on a percentage of assets under management. The wrap sponsor’s services generally include, in addition to the selection of investment advisors such as Raub Brock, consultation on investment objectives and suitability, custodial services, the execution of portfolio transactions, trade confirmations, reporting and the evaluation of investment performance. The program sponsor pays Raub Brock a portion of the wrap fee in connection with the advisory services the Firm provides. When Raub Brock provides its services to wrap fee programs, it contracts with the wrap program sponsor for its services rather than the underlying client participants of the wrap program. The wrap sponsor serves as a master investment advisor and is responsible for client record-keeping and reporting. Each wrap program sponsor is primarily responsible for initially (and routinely thereafter), evaluating whether a given wrap program is suitable for their wrap program participants. Each wrap sponsor is responsible for uploading to the wrap program’s online platform, sufficient initial and updated client financial condition information to allow Raub Brock to verify initial (and monitor ongoing updates in relation to) individual participant suitability regarding the Model Portfolio. Fiduciary Status When we provide investment advice to each of our clients, we are fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities and Exchange Commission, as applicable. These regulations require us to act in our clients’ best interests and not put our interests ahead of our clients’ interests. Financial Planning/Consulting Services – Individually Managed Private Client Accounts The Firm provides financial planning and financial consulting services that may include, among other services: 1. accumulation and retirement planning; 2. employment compensation and benefit planning; 3. analysis of current investment holdings, investment strategy or asset allocation; 4. education funding; 5. insurance planning; and 6. estate planning. When requested and appropriate, routine financial planning analyses and recommendations are provided to clients as a part of the Firm’s investment management services, without separate fees. In cases where the client’s family circumstances, financial condition, estate plan, current assets and investment and retirement goals involve greater complexity and/or require consultations with outside professionals, financial planning and financial consulting services are charged an additional, separate fee and provided pursuant to a separate written agreement setting forth the terms and conditions of the engagement and describing the scope of the services to be provided. 5  Client Obligations In performing its services, Raub Brock relies upon the information received from its client or from their other professional legal and accounting advisors and is not required to independently verify such information. Each client is advised that it remains his/her/its responsibility to promptly notify Raub Brock if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Raub Brock’s previous recommendations and/or services. Advisor Does Not Provide Comprehensive Tax or Accounting Advice investment management services, Raub Brock’s decisions and In providing recommendations may include the consideration of the possible alternative tax consequences incidental to such decisions and recommendations. However, the Firm does not undertake to provide comprehensive tax or accounting advice or counseling. Although we prepare reports to assist our clients with the preparation of their tax returns, such reports do not represent the advice or approval of tax professionals. We advise clients to consult a tax professional in order to determine the tax and accounting consequences of investments in their accounts. TERMINATION OF AGREEMENT Raub Brock and its clients may terminate their respective investment management agreement at any time, upon written notice. The Firm does not assess any fees related to termination but is entitled to all management fees earned up to the date of termination. Any earned fees owed to Raub Brock are paid from the client’s account on a pro rata basis determined on the amount of time expired in the calendar quarter. If a copy of this Form ADV Part 2A disclosure statement was not delivered to the client prior to or simultaneous with a client entering into a written advisory contract with Advisor, then the client has the right to terminate the contract without penalty within five (5) business days after entering into the contract. For purposes of this provision, a contract is considered entered into when all parties to the contract have signed the contract. If the client terminates the contract on this basis, all fees paid by the client are refunded. Any transaction costs of the executing broker/custodian for establishing the custodial account or for trades occurring during those five days are non-refundable. Item 5 FEES AND COMPENSATION ADVISORY FEES Management Fees – Individually Managed Accounts For its individually managed private client accounts, Raub Brock charges a fee based on a percentage of the market value of the investments held in each client’s account. Assets in the Account are included in the fee assessment unless specifically identified in writing for exclusion. The management fee is billed quarterly, in arrears, and prorated for accounts established or terminated at times other than the start of the quarter. The management fee is computed on the last day of each quarter of management by determining the market value of the Account using the following guidelines: (a) for marketable securities: the current market price provided by custodian and (b) cash or equivalents, at dollar value. Fees charged are not calculated as a share of capital gains or 6  capital appreciation of any portion of the assets under management of an advisory client (SEC Rule 205(a)(1)). The annual management fee paid to Raub Brock is calculated according to the following standard fee schedule: Value of Account Assets On the market value of Account up to $500,000 Annual Fee Rate 1.25%, plus On the market value of Account above $500,000 up to $2,500,000 1.00% plus On the market value of Account above $2,500,000 up to $5,000,000 0.80%, plus On the market value of Account above $5,000,000 0.60% The foregoing describes Raub Brock’s basic fee schedule for individual private clients; however, fees are negotiable at the discretion of Raub Brock and arrangements with any particular client may vary. In some cases, the fees may be greater than fees charged by other investment advisors for similar services; in other cases, fees may be lower. Fees for multiple accounts of the same client are determined by aggregating the account holdings to determine the overall assets under management and investment management fee, then allocating the fee to each account on a pro rata basis. Clients are invoiced at the beginning of each calendar quarter for management services performed in the previous quarter. Clients customarily authorize Raub Brock to deduct its quarterly investment advisory fee directly from their custodial account. This authorization is granted under the terms of the client’s signed investment management agreement and the client’s instructions to the custodian. It is the client’s responsibility to verify the accuracy of the fee calculation, as the custodian will not determine whether the fee is properly calculated. Because client investment assets include money market funds, mutual funds, exchange traded funds, third-party funds or other such securities, the total investment management expense incurred by clients will consist of fees paid to Raub Brock, plus management fees charged directly to the fund portfolios by the fund management companies, plus any transaction fees charge by the custodian of client’s account. (See “Fund Disclosures” below.) Management Fees – Institutional Clients with Separately Managed/Unified Managed and Wrap Accounts For its institutional clients, the Firm charges an investment management fee that is calculated as a percentage of the underlying assets under management. The fees charged by the Firm under these arrangements are generally at a lower percentage of assets than those otherwise charged by Raub Brock for its non-institutional clients. However, because its fees are bundled into the overall program fees charged by the institutional advisor, the underlying clients of such advisors could pay more in management fees than those paid by non-institutional clients. The asset-based fee schedules for institutional clients are specific to each client relationship, based upon the type and size of the arrangement, and range from 50 to 70 basis points on the total assets under management. Fees paid to 7  Raub Brock under certain UMA arrangements are lower than the standard management fees charged by the Firm. Raub Brock’s fees are payable either quarterly or monthly and either in advance or arrears, depending upon the billing practices of the institutional advisor. Institutional relationships vary and, in some cases, the institutional advisor retains sole billing authority and pays Raub Brock directly from the management fees it receives. For institutional accounts over which Raub Brock has direct trading responsibility and for which it bills fees directly, fees payable in arrears are calculated on the value of assets in the account at the end of each billing period. The management fee is computed on the last day of each period by determining the market value of the Account using the following guidelines: (a) for marketable securities, the current market price provided by custodian and (b) cash or equivalents, at dollar value. Fees charged are not calculated as a share of capital gains or capital appreciation of the funds or any portion of the funds of an advisory client (SEC Rule 205(a)(1)). For wrap fee programs, the single wrap fee paid by each wrap program participant is distributed amongst the wrap sponsor advisor, the wrap program broker-dealer and Raub Brock as the Model advisor. Consequently, each wrap fee participant is advised to consider the level of the single fee charged under the program relative to the services provided, including the amount of portfolio activity in the account and the value of custodial and portfolio monitoring services. The single fee may be higher or lower than the total cost of all services the underlying client is receiving if they were to pay for each service separately. Financial Planning and Financial Consulting Services – Individually Managed Accounts For its financial planning services to its individually managed private clients, Raub Brock charges a fixed fee which is based upon the complexity of the planning services requested and ranges between $1,000 and $5,000. Raub Brock rarely charges hourly fees for its services but may choose to offer individual financial consultations at an hourly rate of $300 per hour depending upon the level and scope of service(s) required and the professional rendering the service(s). A portion of the estimated fee for the engagement is due upon entering into the engagement agreement; thereafter, ongoing fees are payable as invoiced. GENERAL FEE DISCLOSURES The foregoing describes Raub Brock’s basic fee schedules for its clients. The client’s fee is determined in accordance with the above fee structure; however, fees are negotiable at the discretion of Raub Brock and arrangements with any specific client may vary. Any deviations from the fee structure are based upon several factors including the amount of work involved, the amount of assets placed under management and the attention needed to manage the account. We believe our investment management fees are competitive with the fees charged by other investment advisors in the San Francisco Bay area for comparable services. However, comparable services may be available from other sources for lower fees than those charged by Raub Brock. Raub Brock receives no commissions on securities purchased or sold for client accounts. 8  We do not provide clients advice as to the tax deductibility of our advisory fees. Clients are directed to consult a tax professional to determine the potential tax deductibility of the payment of advisory fees. CUSTODIAN AND BROKERAGE FEES Clients incur certain charges imposed by their custodians and other third parties such as 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. Additionally, clients incur charges by the executing broker-dealer in the form of brokerage commissions and transaction fees on the investment transactions entered for their account(s). All these charges, fees and commissions are in addition to Advisor’s investment management fee. FUND DISCLOSURES Mutual funds, closed-end funds, exchange traded funds and alternative investment funds are investment vehicles and the investment strategies, objectives and types of securities held by such funds vary widely. In addition to the advisory fee charged by Raub Brock, clients indirectly pay for the expenses and advisory fees charged by the funds in which their assets are invested. All such funds incur operating expenses in connection with the management of the fund. Investment funds pass some or all these expenses through to their shareholders (the individual investors in the funds) in the form of management fees. The management fees charged vary from fund to fund. In addition, funds charge shareholders (individual investors in the funds) other types of fees such as early redemption or transaction fees. These charges also vary widely among funds. As a result, clients still pay management fees and other, “indirect” fees and expenses as charged by each mutual fund (or other fund) in which they are invested. Clients are provided a copy of a fund prospectus for each fund in which they invest by their custodian or by the fund sponsor rather than by Raub Brock. As required by law, a prospectus represents the fund’s complete disclosure of its management and fee structure. In addition, a fund’s prospectus can be obtained directly from the fund. BOND DISCLOSURE Clients whose assets are invested in bonds purchased directly from an underwriter may pay a sales credit or concession to the underwriter on the trade (in lieu of a sales commission). Item 6 PERFORMANCE-BASED FEES No part of Raub Brock’s investment management fee is based upon capital gains or the capital appreciation of assets. Item 7 TYPES OF CLIENTS Our clients include individuals and high net worth individuals, family offices, trusts and estates, banks and pension and profit-sharing plans and institutional advisors. Raub Brock also provides investment management services as a sub-advisor through separately managed, unified managed and wrap accounts. For its individually managed private client 9  accounts, Raub Brock requires a minimum portfolio of $1,000,000. As a result, Raub Brock’s services are not appropriate for everyone. Particularly for smaller accounts, other investment advisors may provide somewhat similar services for lower compensation, although still others may charge more for similar services. Item 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS METHODS OF ANALYSIS Raub Brock’s primary method of analysis is fundamental analysis. Fundamental analysis involves analyzing real data, including overall economic and company-specific information available to determine the value of a particular investment. Sources of information used by Raub Brock include third-party research materials, company annual reports and other regulatory filings, and financial newspapers and periodicals. We believe that dividend growth is the primary driver of long-term stock price appreciation. Accordingly, our efforts focus on identifying high quality companies that can deliver sustainable, above average growth in dividends. We invest in companies with growing dividends driven by consistent earnings and revenue growth, strong balance sheets, experienced management teams and leading products or services. We hold the view that such companies not only have the potential to contribute above average returns to the portfolio but also pose less risk. INVESTMENT STRATEGY For all client accounts over which Raub Brock has been granted discretionary authority, it is authorized to enter any type of investment transaction that it deems appropriate for the account, given the financial circumstances, investment objectives, risk tolerance and investment restrictions, if any, set by the individual client. Raub Brock currently utilizes general types of investments including equities, corporate and municipal bonds, investment company products (i.e. mutual funds, annuities, exchanged traded funds (“ETFs”), among other securities. For active investments the Firm relies on individual stocks and bonds, as well as equity and bond mutual funds. On the passive investment side, the Firm relies on indexed funds and ETFs. Generally, the Firm purchases securities in client accounts with the intent to hold them for one year or more (long term), although occasionally and when warranted, securities are held for the short term only (less than one year). Raub Brock does not use “short sales” in implementing investment advice for clients although it may use ETFs or hedge funds that employ “short sales” strategies. The Firm generally does not routinely engage in the purchase of securities on margin for clients, although the Firm may do so to cover short-term portfolio liquidity needs, or when the client requests that it do so. Due to the risks and costs of trading on margin the Firm does not recommend the use of margin by its clients. Nevertheless, from time to time, a client’s margin account may go into a negative cash position, which may occur for a day or two surrounding trade settlement for a given transaction or may result from a client withdrawal of funds from their account without notifying the Firm. Our policy is to cure this negative position when practicable depending on the extent of the shortfall and the availability of assets. On occasion, after consultation with and consent from the client, the Firm waits for a longer period of time to employ assets scheduled to become available to the account, for example from a maturing bond. 10  Alternative Investments In addition to these types of investments the Firm also provides investment advice regarding alternative investments to qualified clients for whom such investments are deemed suitable. These alternative investments include, but are not limited to, venture capital limited partnerships, private equity, managed future funds, hedge funds and third-party funds of funds. INVESTMENT RISKS All securities investments carry risk, including the risk that an investor loses a part or all his or her initial investment. Risk refers to the uncertainty that the actual return the investor realizes could differ from the expected return. Risks may be systematic, referring to factors that affect the returns on all comparable investments and that affect the market as a whole. Systematic risks include market risk, interest rate risk, reinvestment rate risk, purchasing power risk and exchange rate risk. Unsystematic risks depend on factors that are unique to the specific investment security. These risks include business risk and financial risk. Here are some of the general risks associated with parts of our investment strategy: Short-term purchases – on occasion, generally only for tax management purposes, we may determine to buy or sell securities in a client’s account and hold them for less than a year. Some of the risks associated with short-term trading that could affect investment performance are increased commissions and transaction costs to the account and increased tax obligations on the gains in a security’s value. Bond Pricing – The price of bonds depends in part on the current rate of interest. Rising interest rates decrease the current price of bonds because current purchasers require a competitive yield. As such, decreasing interest rates increase the current value of bonds with associated decrease in bond yield. We may decide to exchange to a lower or higher duration bond or to another asset class due to interest rate risk that could affect investment performance. Active Management Risk – Raub Brock portfolios are subject to the risk that our research and judgment about the attractiveness, value, or potential appreciation of any of our portfolio holdings may prove incorrect. If the securities selected or strategies employed by Raub Brock fail to produce the intended result, portfolios managed by Raub Brock could underperform other portfolios with similar objectives and investment strategies. Furthermore, because our process is geared to long-term investment, our portfolios are not immune to short-term market forces, which could impact any investor who instructs us to sell at an inopportune time. Investment Style Risk – At various stages of the market cycle, speculators tend to gravitate towards highly leveraged investments that are at that time generating high levels of profitability. Because portfolios managed by Raub Brock avoid investing in highly leveraged businesses, they will almost certainly underperform in those types of market environments. In general, Raub Brock portfolios should be expected to underperform anytime high-quality investments underperform riskier assets. Stock and Bond Market Risk – Stocks generally fluctuate more than bonds or cash and may decline rapidly over short time periods. There is always the chance that stock prices will decline because stock markets tend to move in cycles, with periods of rising and falling 11  prices. Prices of individual stocks can fall either because of factors related to the underlying business or industry or due to general weakness in the stock market as a whole. With any stock or bond there is a risk of a loss of capital. Clients must accept the risk associated with stock and bond market fluctuations or change to a more appropriate investment portfolio in alignment with their risk tolerance. Alternative Asset Classes – Many alternative investments are illiquid, which means that the investments are difficult to trade. Consequently, such holdings may limit a client's ability to dispose of such investments in a timely manner and at an advantageous price. Inflation – Inflation is the loss of purchasing power through a general rise in prices. If an investment portfolio is designed for current income with a real rate of return of 4% and inflation were to rise to 5% or higher, the account would result in a loss of purchasing power and create a negative real rate of return. Reinvestment of Dividends – An investor can choose to reinvest interest, dividends and capital gains to accumulate wealth. This is an appropriate strategy for a portfolio designed for capital growth. However, the reinvested earnings could result in a lower or a higher rate than was initially earned. Mutual Funds with Foreign Asset Holdings – Any investments in mutual funds that make foreign investments are subject to the uncertainty with changes in the foreign currency value. The client will bear more risk and may earn a substantially higher return or a substantially lower return. Liquidity Risk. Liquidity risk exists when investments are subject to restrictions making them difficult to sell, possibly preventing clients from selling such securities at an advantageous time or price. Margin Trading – In some cases, and generally only for short term financing considerations, clients may elect to assume a margin balance on their investment account. The client’s custodian may require a percentage of assets under management to be pledged as collateral for the margin amount. Clients risk that in a falling market, the pledged collateral will be insufficient to cover a margin call by their custodian. Consequently, all margin decisions are left to the client. Item 9 DISCIPLINARY INFORMATION Raub Brock has no disciplinary history and consequently, is not subject to any disciplinary disclosures. Item 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Raub Brock is an independent investment advisor, unaffiliated with any other financial institution or securities dealer or issuer. We recommend that our clients custody their investment accounts at Charles Schwab & Co., Inc. (“Schwab”), a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”) and a member of the Securities Investors Protection Corporation (“SIPC”). Although we recommend Schwab, we have no affiliation with Schwab, do not supervise its brokerage activities and are not subject to its supervision. 12  The Firm has several institutional clients to which it provides investment management services. We provide these services to other investment advisors, banks and trusts and third- party asset managers. In some cases, the firm has entered into formal sub-advisor arrangements. Although we refer our clients to other professionals such as attorneys or accountants for estate planning, tax or other matters, neither the Firm nor its principals or employees are affiliated with any law or accountancy firm other than noted above. Item 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING As a fiduciary, Raub Brock has a duty to act with utmost good faith and in the best interests of our each of our clients. Our clients entrust us with their assets, which in turn place a high standard on our conduct and integrity. The fiduciary duty is the core principle underlying the Firm’s Personal Trading and Code of Ethics policies and procedures, which are designed to ensure that our personnel: (i) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in performance of their duties; (ii) at all times place the interests of our clients first; (iii) disclose all actual or potential conflicts; (iv) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (v) conduct all personal trading consistent with applicable regulations and internal procedures and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (vi) not use any material non-public information in securities trading. The Code establishes policies regarding other matters such as pre-clearance of certain personal trades, reporting of outside business activities, the giving or receiving of gifts and certain political contributions, and ongoing personal portfolio holdings reporting. its employees and their immediate Raub Brock, families (sometimes collectively “employees”) are permitted to buy and sell securities for their personal investment accounts. The Firm has adopted employee personal trading policies and procedures and a code of ethics to govern proprietary (on behalf of the Firm itself) and employee trading practices. Raub Brock’s owner, officers and employees are required to report all personal securities transactions on a regular basis. All employees are required to sign a certification agreeing to abide by the Firm’s code of ethics. Employees are allowed to personally invest in the same securities that are purchased for client trading accounts and to own securities that are subsequently purchased for client accounts. However, it is our policy not to give preference to orders for personnel associated with the Firm regarding such trading. From time to time, trading by employees in particular securities is restricted in recognition of impending investment decisions on behalf of clients. If a security is purchased or sold for client accounts and employees on the same day, either employees pay or receive the same price as the client account, or the client account receives the more favorable price. If purchased or sold on different days, it is possible that the Firm and/or employees’ personal transactions might be executed at more favorable prices that were obtained for clients. Employees buy or sell different investments, based on personal investment considerations, which the Firm may not deem appropriate to buy or sell for clients. It is also possible that 13  employees take investment positions for their own accounts that are contrary to those taken on behalf of clients. Employees also buy and sell specific securities for their personal accounts based on personal investment considerations aside from company or industry fundamentals, which are not deemed appropriate to buy or sell for clients. This can occur when securities that are not suitable for clients at the time of purchase (e.g., speculative stocks, micro-cap stocks, penny stocks), are purchased by employees. If these securities subsequently appreciate, these personal transactions could be viewed as creating a conflict of interest. Conversely, employees liquidate security positions that are held both for their own account and for the accounts of Firm clients, sometimes in advance of clients. This occurs when personal considerations (i.e., liquidity needs, tax-planning, industry/sector weightings) deem a stock sale necessary for individual financial planning reasons. If the security subsequently falls in price, these personal transactions could be viewed as a conflict of interest. A copy of Raub Brock’s employee trading policies and code of ethics is made available to clients and prospective clients upon request. Item 12 BROKERAGE PRACTICES RECOMMENDATION OF SCHWAB AS CUSTODIAN/EXECUTING BROKER – PRIVATE CLIENTS Raub Brock recommends that its individually managed private clients establish brokerage accounts with Schwab to maintain custody of clients' assets and to effect trades for their accounts. Schwab is independently owned and operated and not affiliated with Raub Brock and does not supervise or otherwise monitor Raub Brock’s investment management services to its clients. Schwab provides Raub Brock with access to its institutional trading and custody services, which typically are not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor's clients' assets are maintained in accounts at Schwab but are not otherwise contingent upon Raub Brock committing to Schwab any specific amount of business (in the form of either assets in custody or trading). Schwab's services include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab also makes available to Raub Brock other products and services that benefit Raub Brock but do not benefit its clients. Some of these other products and services assist Raub Brock in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of Raub Brock's fees from its clients' accounts; and assist with back-office functions, recordkeeping and client reporting. Many of these services generally are used to service all or a substantial number of Raub Brock's accounts, including accounts not maintained at Schwab. Schwab also makes available other services intended to help Raub Brock manage and further develop its business. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance and marketing. In addition, Schwab makes available, arranges and/or pays for these types of services to Raub Brock by independent third parties. Schwab occasionally discounts or waives fees it otherwise would charge for some of these 14  services or pay all or a part of the fees of a third-party providing these services to Raub Brock. Raub Brock’s recommendation that its private clients maintain their assets at Schwab is based in part on the benefit to Raub Brock of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. CUSTODIAN/EXECUTING BROKER ARRANGEMENTS – INSTITUTIONAL CLIENTS All custodial and brokerage arrangements for the Firm’s separately managed account programs (SMA), unified managed account programs (UMA) and wrap fee programs are established by and at the discretion of the institutional client. BEST EXECUTION Raub Brock is not obligated to obtain the best net price or lowest brokerage commission on any particular transaction. Rather federal law requires investment managers to use their reasonable best efforts to obtain the most favorable execution for each transaction executed on behalf of client accounts. For Individually Managed Client Accounts: In selecting broker-dealers, Raub Brock’s primary objective is to obtain the best execution. Expected price, giving effect to brokerage commissions, if any, and other transaction costs, are principal factors, but the selection also takes account of other factors, including the execution, clearance and settlement capabilities of the broker-dealer, the broker-dealers willingness to commit capital, the broker-dealers reliability and financial stability, the size of the particular transaction and its complexity in terms of execution and settlement, the market for the security, the value of any research and other brokerage services provided by the broker-dealer, and the cost incurred by placing prime brokerage trades in client accounts. Based upon an evaluation of some or all these factors, Raub Brock may execute client trades through broker-dealers that charge fees that are higher than the lowest available fees. Raub Brock may select broker-dealers whose fees may be greater than those charged for similar investments if Raub Brock determines that brokerage services and research materials provided by that broker-dealer warrant the payment of higher fees. Raub Brock reviews transaction results periodically to determine the quality of execution provided by the various broker-dealers through whom Raub Brock executes transactions on behalf of clients. For Sub-advisory Services to Institutional Clients Sponsoring Wrap Fee Programs: As described above in Item 4, certain of the Firm’s institutional clients provide their underlying clients access to the Model Portfolio through wrap fee programs using custodial arrangements and trading platforms designated by the wrap program sponsor. Wrap program participants’ assets are custodied with the wrap program’s designated custodian which executes all securities trades in the participant accounts. Raub Brock is required to execute all wrap participants’ trades through the specified trading platforms/custodians and is unable to seek different or better trade execution, if any were available, from any other executing broker-dealer. Consequently, Raub Brock’s ability to obtain best execution is limited. 15  services, industry and company comments, SOFT DOLLAR ARRANGEMENTS AND POTENTIAL CONFLICTS Raub Brock is not currently a party to any formal “soft dollar” arrangements whereby an executing broker-dealer, including Schwab provides or purchases on its behalf, brokerage services or research products in exchange for a set level of brokerage commissions paid by Raub Brock clients on trades in their investment accounts. Such services or research products are known as “soft dollar” products and services. Soft dollar research and services would include among others, economic and market information, portfolio strategy advice, proxy voting technical data, recommendations, research conferences, general reports, periodical subscription fees, consultations, performance measurement data, on-line pricing, news wire charges, quotation services, computer hardware and software. If Raub Brock ever accepts soft dollar services and research in exchange for client trade commissions, the Firm’s policy would be to limit such arrangements to those falling within the safe harbor of Section 28(e) of the Securities and Exchange Act of 1934, as amended. Only bona fide research and brokerage products and services that aid the Firm in the performance of its investment decision-making responsibilities would be permitted and we would ensure that commissions paid are reasonable considering the value of the brokerage and research services acquired. Occasionally, Raub Brock receives discounts on software and other services from Schwab on a non-soft dollar basis. These discounts are generally offered to all firms who fit a common profile or asset threshold. Such discounts are accepted with the intent of benefiting all clients and their value is not considered in the process of selecting securities to purchase for client accounts. AGGREGATION OF TRADES AND POTENTIAL CONFLICTS Raub Brock is authorized to combine transaction orders on behalf of multiple clients and allocate the securities or proceeds on an average price basis among the various participants in the transactions. While we believe that aggregating orders should be advantageous to all participants over time, in any particular instance, the average price could be less advantageous to any given client than if such client had executed the transaction alone or had completed its transaction before the other participants. When orders are aggregated, the price paid by each account is the average price of the order. Transaction costs are allocated to each client by the client’s custodian according to the client’s custodial agreement. It is our policy that, over time, trades are not allocated in any manner that favors one group of clients over another group. Client transactions are aggregated according to custodian in consideration of “trade away” charges that are imposed if trades are directed to a non-custodial broker-dealer for execution. Aggregated trades placed with different executing brokers may be priced differently. Raub Brock and/or its associated persons may participate in such aggregated client orders. However, there are circumstances in which transactions on behalf of Raub Brock or its associated persons may not, under certain laws and regulations, be aggregated with those of clients. In such cases, neither Raub Brock nor any associated person will affect transactions in the same security on the same day as clients until after the clients’ transactions have been executed. 16  ALLOCATION OF OPPORTUNITIES AND POTENTIAL CONFLICTS Because we manage more than one client account, there is a conflict of interest related to the allocation of investment opportunities among all accounts managed by the Firm. We attempt to resolve all such conflicts in a manner that is generally fair to all clients over time. We may give advice and take action with respect to any of our clients that may differ from advice given or the timing or nature of action taken with respect to any other client based upon individual client circumstances. It is our policy, to the greatest extent practicable, to allocate investment opportunities over time on a fair and equitable basis relative to all clients. The Firm is not obligated to acquire for any client account any security that the Firm or its owners, officers, employees or affiliated persons may acquire for their own accounts or for the account of any other client, if in the discretion of the portfolio managers, based upon the client’s financial condition and investment objectives and guidelines, it is not practical or desirable to acquire a position in such security for that account. DIRECTED BROKERAGE In a limited number of cases, clients direct Raub Brock to place all orders for securities transactions with a specific broker-dealer (directed brokerage). In these cases, Raub Brock is not obligated to, and will generally not solicit competitive bids for each transaction or seek the lowest commission rates for the client. As such, the client will likely pay higher commission costs, higher security prices and transaction costs than it otherwise would have had it not directed Raub Brock to trade through a specific broker. In addition, the client may be unable to obtain the most favorable price on transactions executed by Raub Brock as a result of Raub Brock’ inability to aggregate/bunch the trades from this account with other client trades. Furthermore, the client may not be able to participate in the allocation of a security of limited availability (such as an IPO), if those new issue shares are not provided by the client’s directed broker or dealer. In addition, Raub Brock may not execute securities transactions with client-directed brokers until non-directed brokerage orders are completed. Accordingly, clients directing brokerage may not generate returns equal to clients that do not direct brokerage. Due to these circumstances, there may be a disparity in commission rates charged to a client who directs Raub Brock to use a particular broker and performance and other differences from other similarly managed accounts. Clients who direct brokerage should understand that similar brokerage services may be obtained from other broker-dealers at lower costs and possibly with more favorable execution. TRADE ROTATION PRACTICES The Dividend Growth Portfolio equity strategy (again, for our institutional clients, the Model Portfolio) is the Firm’s predominant investment strategy for all its clients, with certain variations adopted for the Firm’s individual private clients based upon individual financial goals and tolerances. Periodically, in response to research and market conditions, the Firm updates and refines the strategy/Model Portfolio. For its individual private clients that follow the strategy and for certain SMA and wrap fee program participants, the Firm will execute securities trades to implement the updates. For other SMA and UMA institutional advisors, notice only of the updates is provided through electronic updates to the Model Portfolio on an automated institutional platform or via email. 17  To prevent the underlying participants of any institutional advisor, or the Firm’s individual private clients from being disadvantaged over time, the Firm has adopted a randomized trade rotation protocol that rotates the order in which notice of the strategy/Model Portfolio updates is provided or updating trade executions are made. In this regard, Raub Brock trade staff maintains an internal spreadsheet listing the participating executing brokers for all clients and which automatically randomly rotates through the list with each strategy/Model Portfolio update to determine which broker will be first for notice of the model update or any actual trade executions. For institutional advisors that are provided notice of model updates only (and not also trade execution), Raub Brock does not control when or if such advisors implement the model changes through actual trade executions. It is possible that although any group of notice- only investment advisors is first in the rotation to receive notice of updates, the advisers may enter their trade executions for the accounts managed by them after Raub Brock has executed trades for other institutional clients or for the Firm’s individually managed accounts. Consequently, Raub Brock cannot guarantee that the underlying clients of notice-only advisers will receive prices as favorable as any other client following the strategy/Model Portfolio. Purchases and sales of securities by any individual or institutional account managed by Raub Brock could have an adverse effect on the price or availability of securities identified from time to time in the strategy/Model Portfolio, and Raub Brock is not precluded by reason of such actual or possible adverse effects, from making such purchases, sales or recommendations for any account managed by the Firm. Item 13 REVIEW OF ACCOUNTS All individually managed client accounts are reviewed by Richard Alpert, the Firm’s portfolio manager, for consistency with the client’s investment policy. The portfolio manager monitors client portfolios and holdings as part of an ongoing process that tracks asset class allocations, cash allocations and other account factors. Periodic allocation adjustments are required due to client investment guideline changes, client deposits and withdrawals and significant life changes for the client (births, deaths, marriage, divorce, etc.) Additionally, client accounts are reviewed in response to changes in the financial markets and/or changes in the Firm’s investment strategy. Clients receive reports at least quarterly, summarizing portfolio holdings, asset allocations and portfolio performance. Investment commentary is included as the Firm deems appropriate in the form of a newsletter. In addition, clients receive transaction confirmations and a monthly account statement from the custodian of their account. Item 14 CLIENT REFERRALS AND OTHER COMPENSATION Raub Brock does not pay referral fees to any third-party firm or individual for recommending the Firm to prospective clients. We do not direct brokerage transactions to any broker- dealer in exchange for receiving client referrals from that broker-dealer. Neither the Firm nor its employees are paid referral fees by any third party for referring clients to their businesses. Firm employees are not paid “sales awards” or other prizes for referring clients to the Firm. 18  Item 15 CUSTODY Raub Brock does not maintain physical custody of client funds or securities. Clients are required to set up their investment accounts with a “qualified custodian,” namely a broker dealer, bank or trust company. Raub Brock is unable to take even temporary possession of client assets for the purpose of transferring them to the client’s account. Each client has a direct relationship with their custodian and is responsible for making deposits to and withdrawals from their account as necessary. The Firm is given the authority to receive payment of its management fees directly from the account, but it is not authorized to make any other withdrawals or to transfer money out of the account to a third party. Disclosures Related to Custodians The Schwab Advisor Services Division of Schwab acts as custodian and executing broker- dealer for Raub Brock clients. Schwab is independently owned and operated and not affiliated with Raub Brock and does not supervise or otherwise monitor our investment management services to our clients. For Raub Brock client accounts maintained in its custody, Schwab generally does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab or that settle into client accounts that are held with Schwab. In most cases, trade executions for client accounts custodied at Schwab are made by Schwab to avoid “trade away” charges otherwise imposed for trades executed at other broker-dealers. In cases where the desired security is not available for purchase or sale through the custodial broker, and in light of our best execution evaluation, certain executions may be made at a different broker-dealer. Schwab sends account statements directly to the client (or to an independent third-party representative designated by the client), no less than monthly, showing all funds and securities held, their current value and all transactions executed in the client’s account, including the payment to Raub Brock of its investment management fees. Item 16 INVESTMENT DISCRETION The timing of any buys or sells; The amount of securities to buy or sell; and The broker-dealer to be used in the transaction; and Clients appoint Raub Brock as their investment advisor and grant full trading and investment authority over their assets at the time they establish their investment accounts. Subject to the Firm’s investment strategy and the client’s investment objectives, our portfolio managers are given full discretion to determine: Types of investments; • • Which securities to buy; • Which securities to sell; • • • This discretion may be limited by client investment guidelines and by any investment restrictions set by the client. Where possible, the Firm negotiates the commission rates at which transactions for client accounts are affected, with the objective of attaining the most favorable price and market execution for each transaction. 19  Client securities transactions generally are executed through the custodian of the client’s account to avoid “trade away” fees for trades that are executed at other broker-dealers. In some cases, a particular security may not be available through the client’s custodian or available only under execution parameters or at an overall cost that makes the use of an alternative executing broker more advantageous for that transaction. In such cases, the portfolio managers have the discretion to select the broker to execute the trade. Item 17 VOTING CLIENT SECURITIES It is Raub Brock general policy not to vote proxy solicitations or shareholder actions received on behalf of individually managed clients related to the securities held in the client’s account. Unless otherwise agreed to with the client, all such solicitations are forwarded to the client by the client’s custodian upon receipt of a client request. Under certain circumstances, the Firm may agree to vote proxy solicitations or shareholder actions on behalf of an institutional advisor requesting that it do so. In these limited cases, the Firm has adopted proxy voting guidelines which it follows in voting such matters. Any client wishing to review our proxy voting policies in full may request a copy. Item 18 FINANCIAL INFORMATION Raub Brock does not require or solicit prepayment of its management fees from clients six months or more in advance. There are no adverse conditions related to the Firm’s finances that are likely to impair our ability to meet our contractual commitments to our clients. The Firm has never been the subject of a bankruptcy filing. INDEX OF ERISA RELATED DISCLOSURES Raub Brock provides investment management services to retirement plans governed by the Employee Retirement Investment Security Act (“ERISA”). Under Section 408(b)(2), ERISA requires that specific disclosures be made to ERISA plan fiduciaries authorized to enter, extend or renew, their investment management agreement with the Firm. The following Index identifies the disclosures required and the location where plan representatives may find them. Any questions should be addressed to our Chief Compliance Officer at the number noted on the cover page of this ADV Part 2A. Required Disclosure Location of the Required Disclosure Description of the services that Advisor provide to covered ERISA plans Item 4 of this Form ADV Part 2A and Paragraphs 1- 4 of the investment management agreement. St at em ent s th at th e services that Advisor will provide to covered ERISA plans will be as an ERISA fiduciary and registered investment adviser Item 4 of this Form ADV Part 2A and Paragraph 12 of the investment management agreement signed with our firm. 20  Description of the direct compensation to be paid to Advisor Item 5 of this Form ADV Part 2A and Paragraph 5 of the investment management agreement signed with our firm. Items 5, 10, 12 and 14, if any, of this Form ADV Part 2A Description of the indirect compensation Advisor might receive from third parties in connection with providing services to covered ERISA plans, if any Items 5, 10, 12 and 14, if any, of this Form ADV Part 2A Description of the compensation to be shared between Advisor and any third party or any affiliated entity, if any Compensation that Advisor will receive upon termination of its agreement to provide investment management services, if any Item 4 of this Form ADV Part 2A and Paragraph 16 of the investment management agreement. 21  Item 1 – Cover Page FORM ADV PART 2B* Brochure Supplement Professional Backgrounds of: Richard H. Alpert David W. Raub Eric J. Richards Zachary C. Norman Cheryl L. Gross Greg S. Sommer Patrick Tinucci 700 Larkspur Landing Circle, Suite 240 Larkspur, California 94939 www.raubbrock.com Tel: 415.927.6990 Fax: 415. 927-6996 *This brochure supplement provides information about the qualifications of Raub Brock Capital Management L.P.’s investment advisory personnel. This is a supplement to the Raub Brock brochure which you should have received previously. Please contact Tina Marshall, Compliance Administrator, at telephone 415-927-6990, if you have not received the brochure or if you have any questions about this supplement. Additional information about Raub Brock Capital Management, LP is available on the SEC’s website at www.adviserinfo.sec.gov. 22  Each member of Raub Brock Capital Management, LP’s professional staff is evaluated on the basis of his or her education and work experience. Prior related business experience, a specialized business or technical skill or applicable undergraduate/post-graduate work are required. _______________________________________________________ RICHARD H. ALPERT, CFP® Born - 1970 Item 2 - Educational Background and Business Experience Education The Colorado College (BA 1994) Professional Designations: Certified Financial Planner (“CFP®”) 1, designation conferred 2006, Business Background 2010 – Present 2005 – 2010 2003 – 2005 2003 – 2005 2002 – 2003 Raub Brock Capital Management, LP, Larkspur, CA Principal, Limited Partner and Portfolio Manager NewFocus Financial Group, LLC, Larkspur, CA, Investment Advisor Representative MML Investor Services, Inc., Springfield, MA Registered Representative Massachusetts Mutual Life Insurance Co., Springfield, MA Agent New England Securities Corp, Boston, MA Agent Professional and Community Activities Mr. Alpert is a member of the Financial Planning Association of San Francisco. Item 3 – Disciplinary Information Mr. Alpert has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Mr. Alpert is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. 23  Item 6 – Supervision Principal Richard H. Alpert is supervised by the Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ DAVID W. RAUB Born - 1944 Item 2 - Educational Background and Business Experience Education Pennsylvania State University (BA 1966) Harvard Law School (JD 1969) Business Background 2001 – Present 1982 – 2012 Raub Brock Capital Management, LP, Larkspur, CA Founding Advisor [Retired], Investment Committee Member Canterbury & Raub, Larkspur, CA Attorney, Estate Planning, Probate and Trust Administration Professional and Community Activities Mr. Raub is a current member and past President and Board member of the Marin County Estate Planning Council. Mr. Raub is a member of the San Francisco Bach Choir and Marin Symphony Chorus. Item 3 – Disciplinary Information Mr. Raub has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Mr. Raub is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. 24  Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ ERIC J. RICHARDS, CFA® Born: 1977 Item 2 - Educational Background and Business Experience Education: Saint Olaf College, Northfield, Minnesota, Bachelor of Arts, Math and Economics, 1999 Georgetown University, Masters Business Administration, 2005 Professional Designations: Chartered Financial Analyst (“CFA®”)2 designation conferred 2003 Securities Exams – Series 7, 63, 86, 87 Business Background: 2017 – Present 2007 – 2016 2005 – 2007 1999 – 2003 Raub Brock Capital Management, LP, Larkspur, CA Senior Research Analyst Fred Alger Management, New York, NY Vice President, Analyst Bear, Stearns & Co, New York, NY Equity Research Associate Board of Governors of the Federal Reserve System, Washington, DC Assistant Economist Professional and Community Activities: Mr. Richards is a member of the CFA Society of San Francisco. Item 3 – Disciplinary Information Mr. Richards has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Mr. Richards is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. 25  Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ ZACHARY C. NORMAN Born: 1987 Item 2 - Educational Background and Business Experience Education: Dominican University of California, Master of Business Administration, Global Strategic Management, 2013 Dominican University of California, Bachelor of Arts, Finance 2011 Securities Exams – Series 65 Business Background: 2015 – Present 2011 – 2014 2011 2010 Raub Brock Capital Management, LP, Larkspur, CA Director of Trading Lateef Investment Management, Greenbrae, CA Equity Trader, previously, Operations and Finance Associate Axion Capital Management, San Rafael, CA Consultant and Analyst Hutchinson Whampoa, Guangzhou, China Analyst and Intern Professional and Community Activities: Mr. Norman is a private pilot and a lifelong musician. He speaks three languages. Item 3 – Disciplinary Information Mr. Norman has no legal or disciplinary events or disclosures. 26  Item 4 – Other Business Activities Mr. Norman is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ CHERYL L. GROSS, CFP® Born: 1970 Item 2 - Educational Background and Business Experience Education: University of Michigan, Ann Arbor – PhD, Psychology, 1997 University of Michigan, Ann Arbor – Master of Arts, Psychology, 1994 University of California, Berkeley – Bachelor of Arts, Psychology, 1992 Professional Designations: Certified Financial Planner (“CFP®”) 1, designation conferred 2017. Enrolled Agent (“EA”)3, designation conferred 2010. Securities Exams – Series 65 Business Background: 2017 – Present 2016 – 2017 2012 – 2016 2014 – 2017 2004 - 2012 Raub Brock Capital Management, LP, Larkspur, CA Financial Advisor Broadwing Capital Advisors, Mill Valley, CA Investment Advisor Representative Broadwing Capital Advisors, Mill Valley, CA Advisor Assistant Town of Tiburon, Tiburon, CA Minutes Clerk A.T.L. Tax & Financial Services, Corte Madera, CA Owner and Tax Preparer 27  Professional and Community Activities: Ms. Gross is a member of the Financial Planning Association of San Francisco. Item 3 – Disciplinary Information Ms. Gross has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Ms. Gross is engaged in no other business activities outside of her employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ GREGORY S. SOMMER, CFA® Born: 1984 Item 2 - Educational Background and Business Experience Education: Cornell SC Johnson College of Business, Master of Business Administration, May 2021 University of Oregon, Bachelor of Science in Finance, Minor in Economics, December 2006 Professional Designations: Chartered Financial Analyst (“CFA®”)2 designation conferred 2016 Securities Exams – Series 7, 66 Business Background: 2024 – Present Raub Brock Capital Management, LP, Larkspur, CA, Senior Research Analyst 28  202I – 2023 2016 – 2020 2012 – 2016 2012 – 2012 2008 – 2010 Gordon Hasketi Research Advisors, New York, NY, Research Associate Wells Fargo Bank, Foster City, CA, Equity Research Analyst II Atherton Lane Advisers (Acquired by BNY Mellon), Menlo Park, CA Associate Portfolio Manager Centaur Partners, Palo Alto, CA, Senior Analyst Willima O’Neill & Company, Los Angeles, CA Research Analyst Professional and Community Activities: Mr. Sommer is a member of the CFA Society of San Francisco. Item 3 – Disciplinary Information Mr. Sommer has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Mr. Sommer is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _______________________________________________________ PATRICK TINUCCI, CFA® Born: 1990 Item 2 - Educational Background and Business Experience Education: University of Colorado, Leeds School of Business, Bachelor of Science, Business Administration, December 2023 29  Professional Designations: Chartered Financial Analyst (“CFA®”)2 designation conferred 2017 Securities Exams – Series 7, 63, 86, 87 Business Background: 2024 – Present 2017 – 2024 2015 – 2017 2014 – 2015 Raub Brock Capital Management, LP, Larkspur, CA, Senior Research Analyst Hahn Capital Management, San Francisco, CA, Senior Equity Analyst RBC Capital Markets, San Francisco, CA, Equity Research Senior Associate Stifel Nicolaus, Denver, CO, Equity Research Associate Professional and Community Activities: Mr. Tinucci is a member of the CFA Society of San Francisco. Item 3 – Disciplinary Information Mr. Tinucci has no legal or disciplinary events or disclosures. Item 4 – Other Business Activities Mr. Tinucci is engaged in no other business activities outside of his employment with Raub Brock Capital Management, LP. Item 5 – Additional Compensation Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to unsolicited discounts on software or brokerage services from client custodians, neither the Firm nor any of its employees receive any economic benefit from any non-client for the provision of investment advisory services. Employees are not paid “sales awards” or other prizes for referring clients to the Firm. Item 6 – Supervision All Firm personnel are supervised by the Firm’s Principal Richard H. Alpert and Chief Compliance Officer, Wendy J. Phillippay. Supervision is ongoing and includes account reviews, trade supervision, annual compliance reviews including the testing of Firm systems, staff meetings and employee reviews. _____________________________________ 1 The Certified Financial Planner® (“CFP®”) designation requires the holder to meet education, examination, experience and ethics requirements, and pay an ongoing certification fee. A bachelor's degree (or higher), or its equivalent in any discipline, from an accredited college or university is required Students are required to complete course training in nine core financial topic areas, sit for a 10-hour CFP Board Certification Examination, acquire three years full-time 30  or equivalent (2,000 hours per year) part-time work experience in the financial planning field and undergo an extensive background check—including an ethics, character and criminal check. To maintain the CFP certification, CFP professionals must complete 30 hours of continuing education (CE) accepted by CFP Board (including completion of 2 hours of CFP Board approved Ethics CE). 2 The Chartered Financial Analyst (“CFA®”) designation requires the holder to pass three six- hour exams, possess a bachelor's degree (or equivalent, as assessed by CFA Institute) and have 48 months of qualified, professional work experience. CFA charter holders are also obligated to adhere to a strict code of ethics and standards governing professional conduct. 3 An Enrolled Agent (“EA”) is a federally authorized tax practitioner who has technical expertise in the field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all administrative levels of the Internal Revenue Service for audits, collections and appeals. 31