RMR WEALTH BUILDERS, INC.

Item 1: Cover Page ____________________________________________________________________________________________________ RMR WEALTH BUILDERS, INC. FORM ADV PART 2A APPENDIX 1 Wrap Fee Program Brochure (CRD # 169005 / SEC # 801-80404) 111 Grove Street Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 https://www.rmrwealth.com https://www.facebook.com/rmrwealth/ https://www.linkedin.com/company/rmr-wealth-builders-inc-/ March 27, 2025 This Wrap Fee Program Brochure provides information about the qualifications and business practices of RMR Wealth Builders, Inc., an investment advisory firm registered with the United States Securities and Exchange Commission . If you have questions about this Brochure's contents, please contact us at 201.836.2460 or compliance@rmrwealth.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority. Registration does not imply any level of skill or training. Investments involve risk, including the possible loss of principal. Additional information about RMR Wealth Builders, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in RMR Wealth Builders, Inc. or CRD # 169005. Results will provide you with all firm disclosure brochures.) 1  Item 2: Material Changes ____________________________________________________________________________________________________ In this item, RMR Wealth Builders, Inc. ("RMR" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 29, 2024, changes have been made to the following Brochure sections: Item 4: Services, Fees & Compensation Assets Under Management As of December 31, 2024, RMR’s assets under continuous management total $2,199,565,329. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $ 2,139,602,190 $ 59,963,139 $ 2,199,565,329 Item 6: Portfolio Manager Selection & Evaluation Digital Assets This section was updated to reflect that Digital Asset services clients will maintain their assets with an available custodian offered through Securitize, a platform solution RMR engaged to deliver these services. Available custodians include but are not limited to, Gemini, Coinbase, Anchorage Digital, and the Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under these services. Full Brochure Availability At any time, we may amend this document to reflect changes in RMR’s business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at or the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "RMR Wealth Builders, Inc.” or CRD # 169005. The SEC's website also provides information about any RMR-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at 201.836.2460 or compliance@rmrwealth.com. 2  Item 3: Table of Contents ____________________________________________________________________________________________________ Item 1: Cover Page.........................................................................................................................................................1 Item 2: Material Changes................................................................................................................................................2 Item 3: Table of Contents.................................................................................................................................................3 Item 4: Services, Fees & Compensation.........................................................................................................................4 Item 5: Account Requirements & Types of Clients.........................................................................................................14 Item 6: Portfolio Manager Selection & Evaluation..........................................................................................................14 Item 7: Client Information Provided to Portfolio Managers.............................................................................................30 Item 8: Client Contact with Portfolio Managers..............................................................................................................31 Item 9: Additional Information.......................................................................................................................................31 3  Item 4: Services, Fees & Compensation ____________________________________________________________________________________________________ Types of Advisory Services RMR Wealth Builders, Inc. (hereafter “RMR” or the “Adviser”) is an investment advisor registered with the United States Securities and Exchange Commission pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). The firm, headquartered at 111 Grove Street, Suite 203, Montclair, New Jersey, was founded in 1986 and incorporated in New Jersey. The Adviser also maintains office locations in AZ, CA, CT, FL, MA, NJ, NY, PA, RI, WY, & UT. For over 35 years, RMR, through its founding partners, has embraced the discipline and practice of aligning fiduciary standards and professional principles. The equal owners of the privately owned company are Ryan P. DeGrau (Chief Executive Officer), Douglas R. Roth (Co-Chairman), Joseph J. Russo (Co-Chairman) and Edward A. Majitenyi (President), who undertake all of the Adviser's significant strategic and administrative decisions. Their combined experience in the industry is over 100 years. (Please refer to each Principal’s Form ADV Part 2B Brochure Supplement for additional details on their formal education and business background.) RMR is a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. As used in this brochure, the words "we," "our," or "us" refer to RMR and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to RMR’s Covered Persons and Supervised Personnel: the firm’s Officers and Directors (“Control Persons”), employees, and Investment Professionals - the Registered Investment IARs (hereinafter “IARs”) who, as either employees or independent contractors of the firm, are licensed, supervised, and approved by RMR to provide investment advice or advisory services on behalf of the Adviser. RMR’s investment advisory services are designed to help our clients strive to attain their financial goals. RMR’s IARs perform a critical role in each client’s account's introduction, communication, and management. IARs will collect financial profile information from clients at the onset of the advisory relationship, make a reasonable effort to confirm or update the written client information no less than annually to keep the data current and recommend specific advisory services or programs deemed appropriate for each client’s financial circumstances, goals, objectives and situation. Each advisory relationship at RMR will be managed by one or more such IARs registered with the firm, who serve as the primary point of contact between the Adviser and client. IARs are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their IAR may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the Investment Professionals providing advisory services, clients should refer to their IAR’s Form ADV 2B Brochure Supplement, a separate disclosure document delivered to them, along with this Brochure, before or at the relationship inception. If the client did not receive these items, they should contact their IAR or RMR’s Chief Compliance Officer at 201.836.2460 for a copy of these essential and informative disclosure documents.) Assets Under Management As of December 31, 2024, RMR’s assets under continuous management total $2,199,565,329. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $ 2,139,602,190 $ 59,963,139 $ 2,199,565,329 Non-Exclusive Relationship RMR supports and maintains an open environment where its Associates have access to the technology, tools, products, and support we believe are necessary to meet our goal of providing diverse and quality client services. Together with the assistance of our preferred Qualified Custodian(s), we aim to deliver a white-glove approach with respect to the resources, support, 4  operations, technology, compliance, guidance, oversight, business development, investment selection, and platform access we make available to our Investment Professionals and clients. RMR's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client may differ or conflict with that provided for the same security or investment for another. Client Responsibilities The advisory services delivered by RMR depend on and rely upon client information. RMR cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Investment Advisory Agreement (“Advisory Agreement” or “Agreement”). RMR's IARs will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. RMR will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify RMR in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. Wrap Fee Program RMR, as Manager and Sponsor, offers investment and portfolio management services via its Wrap Fee Program Services, a transaction fee rebate program that differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee" or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). RMR’s IARs recommend the Wrap Fee Program and serve as the Portfolio Managers servicing the Program’s managed client accounts (the "Managed Accounts" or "accounts"), for which RMR will receive management fees and a portion of the fees related to the administrative services from the Wrap Fee Program. RMR’s IARs (hereafter, the “Portfolio Managers”) receive no extra compensation for their clients participating in the Wrap Fee Program; they receive the regular and customer advisory fees, as detailed in each client’s executed Wrap Fee Program Advisory Agreement. (See “Wrap Fees.”) Wrap Fee Program Disclosures Wrap Fee Program clients must understand the following: • The benefits under the Wrap Fee Program largely depend on the size of the account, the management fee charged, and the number of transactions likely to be generated in the account. • RMR and its IARs receive compensation due to client participation in our Wrap Fee Program. This compensation may be more than the amount RMR or its Investment Professionals would receive if the client paid separately for investment advice, brokerage, and other services. (For example, this type of Program may not be suitable for accounts with little trading activity.) • To evaluate whether our Wrap Fee Program is suitable for their circumstances, clients should compare our Wrap Fee and any other costs of the Wrap Fee Program with the amounts that other advisers would charge broker-dealers and custodians for advisory fees, brokerage, other execution costs, and custodial services comparable to those provided under the Wrap Fee Program. • Participating in a Wrap Fee Program may cost a client more or less than purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. Similar services may be obtainable at lower costs on an unbundled basis through different firms. Accordingly, a conflict of interest exists because we have a financial incentive to recommend RMR’s Wrap Fee Program. Receiving a portion of advisory fees incentivizes Portfolio Managers to recommend that clients participate in our Wrap Fee Program rather than a non-wrap fee program or other programs or services where clients pay for trade execution costs over brokerage accounts that charge commissions. 5  The following summarizes each service selection available through RMR's Wrap Fee Program. Clients should carefully review this Brochure and consult with their IAR, the applicable Program Agreement, and the corresponding fee schedule for complete information regarding each service. The Wrap Fee Portfolio Management Services Programs RMR's Investment Professionals will emphasize continuous personal client contact and interaction in providing the following Wrap Fee Program selections: IAR Client Investment Portfolio Wrap Fee Program (hereafter “CIP Program”), or 1. 2. Third-Party Manager Wrap Fee Program (hereafter “TPM Wrap Fee Program,” with RMR As Investment Adviser and the TPM as Sub-adviser) Before participating in the Wrap Fee Program, clients will be required to enter into a written RMR Advisory Agreement for Wrap Fee services that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to us - either discretionary or non-discretionary. RMR’s Wrap Fee Program Services selections involve different custodial and administrative services and fee arrangements. The annual Wrap Fee for participation, which is negotiable, depends upon the market value of the client assets under our management. RMR will receive a portion of the total fee, or the range of fees, paid to Portfolio Managers under the selected Wrap Fee Program. This fee will be charged separately to the client’s account by the Wrap Fee Program custodian and paid for by the client. (See “Wrap Fees.”) At relationship inception, IARs will work with clients to determine their financial situation, risk tolerance, investment objectives, time horizon and other relevant guidelines (“Suitability Information”). All advisory clients will undergo this initial interview and discussion to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, and realistic and measurable goals are set based on the disclosed information and objectives to define those goals. According to the selected service(s), the client’s written Agreement will document the details of the advisory relationship and final advisory fee structure. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. According to the client’s Agreement, custody of client assets will be held by one of RMR’s (or the Third-Party Manager’s, as applicable) chosen independent and separate Qualified Custodians who will take possession of the cash, securities, and other assets within the client's portfolio account. RMR delivers a report to the Qualified Custodian, and fees are then typically automatically directly debited from the client's account. RMR urges clients to review Qualified Custodial account statements received promptly upon receipt and compare them against the client’s executed Advisory Agreement, the appropriate benchmark for their portfolio, and any periodic portfolio report, data or statement they may request from us to ensure the accuracy of account transactions. RMR will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Wrap Fee Program Services Agreement as applicable to the type of account opened and according to the Adviser’s standard Fee Schedule as reflected herein and more fully explained in each client’s executed Agreement. Clients should consult their Agreement for complete details. As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and IAR review their financial situation and portfolio through regular contact and annual meetings to determine fluctuations in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Independent Third-Party Manager ("TPM") As Overlay Manager, your IAR will recommend, select, monitor, and replace the Wrap Fee Program’s Independent Third-Party Manager (“TPM”) if necessary. The TPM will offer a selection of Model Portfolios that use a variety of investment strategies as described in Item 6: Portfolio Manager Selection & Evaluation and in each TPM’s Form ADV Disclosure Brochure, with varying levels of risk from which clients can choose. RMR or your IAR do not manage TPM assets. One or more third-party asset managers manage TPM assets on a discretionary basis. 6  Trading Authorization & Account Management Style RMR advisory services are offered either on a discretionary or non-discretionary basis. • TPM investment accounts are offered only on a discretionary basis. • CIP investment accounts are offered on either a discretionary or non-discretionary basis. An explanation of each type of management style follows: Discretionary Authority Under discretionary account management authority, RMR has the discretion to select and replace the TPM Investment Manager, and the TPM Investment Manager has the discretion to select and manage the assets in the client’s investment account. Securities transactions will be executed for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as deemed appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and the client and IAR/TPM may agree to from time to time - collectively, the “Investment Guidelines.” We will not wire or transfer funds to third parties without your written approval. Discretionary authority is limited to investments within a client's Managed Accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian. Client consent will only be required for trades on positions explicitly discussed and designated as requiring consent during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or other types of securities and refuse to approve securities transactions. Clients will execute all documents RMR or their custodian requires to establish the account trading authorization. RMR will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their IAR may agree to from time to time. Under this management style, RMR must receive approval from the client before placing any trades in the client's account. As a result, until RMR reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and RMR engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with the jointly agreed upon investment objectives, RMR reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. 7  Fees RMR’s Wrap Fee Program fees generally use a tiered or “blended” annual fee calculation. Based on the account's value at the end of the last billing period, the fee schedule identifies specific portions of the account value to be charged at different rates. The account's total value is compared against this schedule, and based on the account size, the separate fee rates are blended to determine the total quarterly account fee for that period according to the following schedule: Annual Advisory Fee Schedule Assets Under Management (“AUM”) First $0 - $250,000 Next $250,001 - $500,000 Next $500,001 - $1,000,000 Next $1,000,001 - $2,500,000 Next $2,500,001 - $5,000,000 Next $5,000,001 + Maximum Annual Fee 2.65% 2.50% 2.00% 1.75% 1.50% 1.25% *Lower fees for comparable services can sometimes be available from other sources. The annual account management fee is billed quarterly based on the number of days in the quarter divided by 365 multiplied by the AUM fee. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Subsequent fees will not be prorated unless additional funds or securities are added to the account or the client Agreement is terminated. Fees are negotiable based on account value and type but will not exceed the maximum Annual Fee. The final fee schedule is documented in the client’s executed Agreement. Additional funds and/or securities deposits during a particular calendar quarter will be subject to billing on a pro-rata basis. Clients who withdraw funds from a managed account during a billing period are not generally entitled to a pro-rata refund unless they terminate their client Agreement or it is otherwise stated in the Client Agreement. Annual Account Administration Fee Effective April 1, 2024, RMR increased its annual Administrative Fees for accounts billed directly from $52 to $80. In return for such fees, which are prorated daily and charged quarterly based on the number of days in the quarter x 365 (same as below), they are assessed to RMR fee-based program clients according to their executed Advisory Agreement. Regardless of the number of assets under management and as illustrated in the Advisory Agreement, clients receive access and use of the BlackDiamond Wealth Platform, an online trading and reporting system that provides them with direct login and access to their portfolio information, wherein they – either independently or with the assistance of a Dedicated Service Team Member, can review their holdings, obtain account summaries, reports, education and training materials and other forms of client communications and support intended to aid clients in monitoring their investments. IAR Client Investment Portfolio Wrap Fee Program Services Fees - clients who elect to receive asset management services through RMR’s CIP Program will pay for the services according to this Brochure with an ongoing asset management fee based on a schedule of percentage of assets under management (“AUM”), according to the above Annual Advisory Fee Schedule. The maximum annual account management fee charged in any RMR Managed Account Program is 2.65%. Third-Party Manager Wrap Fee Program Services Fees - clients participating in RMR’s TPM Program services will pay Program fees according to this Brochure, based on a percentage of assets managed within the TPM Program. Clients are informed of the amount to be received by RMR via the Form ADV disclosure documents, Agreement, and Fee Disclosure Statement they receive/accept at the time of relationship inception. The fee arrangement is also detailed within each referred manager's Form ADV Part 2A disclosure brochure and the separate manager’s contract the client enters with the manager. Fees can be structured in one of the following ways and are disclosed in each client's Agreement:  RMR receives a split of management fees with the TPM,  a fixed flat percentage fee on total assets in the account,  a tiered fee schedule calculated by applying different rates to different levels of assets, or  a linear fee schedule where a breakpoint percentage fee is assessed for the total account assets. 8  The first pay period's fees will be calculated pro rata at the account's inception. The fee is calculated via Black Diamond and debited from the custodian. While RMR generally remits payment to the TPM, in some instances, the TPM will directly bill the client’s account, resulting in the client seeing two line items for the single fee they pay for this service. Fees will be paid to referred managers according to Agreement provisions. RMR’s fees are charged in addition to each referred third-party manager's fee. RMR’s portion of the total management fee represents the maximum fee we may earn under the TPM Program and will not exceed the limits imposed by any regulatory agency. It is important to note that the client's TPM can charge fees in addition to those reflected in RMR’s Annual Advisory Fee Schedule and will typically reserve the right to reduce or waive the fee at their sole discretion. Added fees and expenses can also be charged by investments within the portfolio's model(s). Each month, clients participating in the TPM Program will receive either a written statement or electronic notice via established secure online access from their TPM custodian, alerting them to statement availability and detailing all account activity. The client is encouraged to promptly review their account statement(s) upon receipt to verify the accuracy of all information. Fee payment in full is expected for fees upon invoice presentation. Clients should refer to their respective RMR Advisory Agreement and the referred manager’s contract for complete details on services, costs, and fees. RMR may change its standard Annual Advisory Fee Schedule at any time by providing the client with 30 days advance written notice. Fees & Fee Billing Clients have two options to pay their RMR advisory fees, either via (1) direct debit or (2) billed, and will select their chosen method by indicating their preference in the Agreement they execute with RMR. RMR or its administrative agent, as authorized by the client, typically requests that for discretionary accounts, the Qualified Custodian directly debits account management fees from the client’s account automatically. For non-discretionary accounts, the client will be contacted to provide consent. Clients may also be billed fees by directly writing a check to RMR or its administrative agent for the fee amount. For all advisory services, fee payment in full is expected promptly upon invoice presentation. The exact process for fee payment is as follows: Directly Debited Fees - for directly debited fees, clients will authorize RMR in writing to directly deduct advisory fees due from their custodial account and provide the custodian with authorization to deduct such fees and instructions to remit them straight to RMR.   For this type of fee payment, when fees are due, RMR will provide the Qualified Custodian with an advisory fee calculation based on the terms of the client's Agreement and direct the Qualified Custodian to remit the client a statement of the activity to the client's address of record - or another authorized address, as otherwise designated in writing by the client, reflecting the fee amounts paid to RMR for the quarter in question. If paid directly, the Qualified Custodian will automatically deduct the client's advisory fees due, as instructed by RMR, at the end of each calendar quarter, regardless of the market performance of the portfolio during the quarter just ended. The account management fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings, according to the discretionary authority granted by the client to RMR, IAR and referred third-party manager, as applicable for the type of account established. When authorized by the client to debit advisory fees from client accounts, RMR is deemed to have custody of client assets to the extent that the adviser can instruct custodians to deduct the fees. RMR urges clients to compare their custodial account statements with any periodic portfolio report or date they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us may vary based on accounting procedures, reporting dates, or valuation methodologies. If a client is not receiving statements directly from their custodian, in addition to advising their IAR promptly, RMR also recommends that they contact their custodian directly. 9  Billed Fees - clients who wish to be directly billed by RMR for their advisory services fees will authorize this form of payment in writing on their advisory services contract and request that RMR invoice them directly quarterly for any fees due. Clients will then make their fee payments to RMR by separate check or credit card, and under no circumstance will any RMR advisory fees be deducted from amounts they hold within their custodial account(s). Other Fees & Expenses The fees clients pay for RMR’s investment advisory services are separate and distinct from administrative fees, annual custody fees, brokerage costs, commissions, debit and credit interest, default charges, direct investments (such as limited partnerships and limited liability companies), margin and trade extensions, mailgrams, money market fees, physical reorganization costs, renege assessments, legal return/bounced check/stop payment/transfer and ship or safekeeping fees, transfer and sub-transfer agent and distributor fees, and other miscellaneous charges when purchasing or selling securities or for products and services customarily assessed by product manufacturers (which include but are not limited to, insurance companies, mutual or exchange- traded funds, real estate, oil and gas, and other providers of direct investments, as described in each product sponsors product prospectus to their shareholders) and the client’s account Broker-Dealers/Qualified Custodians. RMR does not share in any portion of such additional fees or expenses imposed. Additional details on some of the above-mentioned and other customary fees and expenses clients may pay to other parties in connection with their portfolio accounts and investments follow: Margin Interest - is the interest the client pays to a Broker-Dealer/Qualified Custodian on loans made to finance the purchase or sale of securities or securities in the client’s investment account. The interest rate charged and other information about the loan, including how interest is calculated and other disclosures of risk and liability, will be described to the client in the margin agreement the client executes with their Broker-Dealer/Qualified Custodian. Fees for advice and execution on these securities are based on the total asset value of the account, which includes the value of the securities purchased on margin. While a negative amount may show on a client's statement for the margined security due to a lower net market value, the fee amount is based on the absolute market value. This could create a conflict of interest where RMR may have the incentive to encourage using margin to create a higher market value and, therefore, receive a higher fee. Using margin may also result in interest charges and all other fees and expenses associated with the security involved. As noted previously, third-party managers responsible for managing a portion of or all of a client’s account can also receive a portion of the advisory fees clients pay RMR, depending on the specific third-party manager disclosure and agreement. Clients should be aware that sharing in a portion of any fee presents a potential conflict of interest because IARs will have a greater incentive to recommend - or make investment decisions regarding investments that provide additional compensation to RMR and your IAR. Any mutual fund share class that pays 12b-1 fees received by RMR will be credited back to the client. Further information regarding fees and charges assessed by a mutual fund is available in the appropriate prospectus. Revenue Sharing & Other Considerations RMR recommends a broad selection of investment products and mutual funds. Some of the investment products and mutual funds we endorse have marketing and distribution agreements with third parties designed to help facilitate the distribution of such investment products. As a result of these arrangements, RMR’s IARs can attend educational sessions, seminars, due diligence presentations, and conferences that provide education and training on various industry topics, including, but not limited to, securities markets, regulations, and company-specific products. Clients should be aware that different products charge different commissions, and our IARs do not receive a greater or lesser percentage of the commission for sales of these products. Regardless, the marketing and educational activities paid for by a product sponsor could lead to a potential conflict where IARs focus more on such offerings. Clients are under no obligation, contractually or otherwise, to purchase insurance or securities products through any person affiliated with RMR. Clients can purchase recommended investment products through other brokers or agents not affiliated with RMR. Further, clients are encouraged to consider and speak to their IAR, tax, and other Investment Professionals regarding the following before transferring securities into an account with our firm: • whether a commission was previously or will be paid pursuant to a previously disclosed deferred compensation agreement, if you want the security to be managed as part of an account subject to an advisory fee and if you prefer to hold the security in an unmanaged brokerage account not subject to an advisory fee. • • To fully understand the total account costs they will pay, the client’s responsibility is to read and understand RMR’s advisory 10  Agreement and those of any referred third-party manager and the prospectus, disclosures, and legal documentation provided that explains the difference in the fees, costs, expenses, commissions and other matters for securities purchased or sold in their investment account as well as the disclosures made regarding all fees charged by our firm, their Broker-Dealer/Qualified Custodian, and others, as applicable for the type of account established. Clients are again encouraged to contact their IAR, tax, and other Investment Professionals to help resolve any questions. Account Additions, Withdrawals, Terminations & Assignments Clients may make additions to their accounts in cash or securities at any time. RMR reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If RMR liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level such as contingent deferred sales charges, and tax ramifications. Clients may make withdrawals from their RMR accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Additions or withdrawals within a client account over $10,000 monthly will incur additional prorated fees or a prorated refund. Generally, terminations can be made to an RMR services Agreement by written notice without penalty within five (5) business days after the Agreement execution date. After that, the Advisory Agreements between RMR and the client will continue in effect until either party terminates the Agreement following the terms of the Agreement, which state that Agreements may be terminated by either party upon at least thirty (30) days' written notice to the other party. A "business day" shall be any day when the New York Stock Exchange is open for trading. Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's obligation to pay management and other fees due, pro-rated through the termination date. • • • RMR will refund any unearned fees resulting from client advance payments to the Adviser. Likewise, if RMR bills the client in arrears for services that have already been rendered, RMR will prorate those fees up to the termination date of the client Agreement. Any pre-paid, unearned fees will be promptly refunded to the client pro rata based on the termination date. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of written notice of the client's death. The disability or incompetency of the client will not terminate or change the terms of this Agreement; however, the client’s executor, guardian, attorney-in-fact, or other authorized representative may terminate this Agreement by giving written notice to RMR. Before termination, all directions given or actions taken or omitted by RMR before the effective Agreement termination shall be binding upon the client and any successor or legal representative. The Adviser will no longer be entitled to receive fees from the termination date and has no obligation to recommend or act concerning an account's securities, cash, or other investments on the terminated Agreement. The executed Advisory Agreement will govern additions, withdrawals, and terminations to third-party manager services. Each third-party manager's Agreement will continue until the client or TPM is terminated by written notice to the other. The third-party manager is responsible for refunding unearned fees per their contract terms. If the total value of the client's account or aggregated accounts falls below the TPM’s minimum account size because of a withdrawal or other reasons, the TPM may terminate the Program Agreement. Before participating in any TPM offering, clients should review all applicable disclosure brochures, investor profiles, and third-party manager contracts. Finally, no RMR Agreement may be assigned - within the meaning of the Investment Advisers Act of 1940, as amended, by the Adviser - without the prior consent of the client. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Investment Advisers Act of 1940, as amended, shall not be considered an assignment.) 11  Brokerage Practices RMR does not maintain custody of the assets we manage on your behalf. Client assets must be held in an account at a "Qualified Custodian," generally a Broker-Dealer or bank. RMR’s preferred Qualified Custodians are Fidelity Investments Institutional Services Company, Inc. (“Fidelity”) and Charles Schwab & Co., Inc. (“Charles Schwab” or “Schwab”), both independent and separate registered Broker-Dealers, Members of FINRA and the SIPC, who will take possession of the cash, securities, and other assets within the client's portfolio account and buy and sell securities upon our instructions, as indicated within each client’s written Agreement and the documents they execute to establish their custodial account with each Qualified Custodian unless the client directs otherwise. Research & Other Benefits An investment adviser receives custodial soft dollar benefits when the firm obtains custodial research or other products and services related to client securities transactions. RMR may receive certain benefits from our Broker-Dealers/Qualified Custodians. These benefits include but are not limited to electronic access and download of trades, balances and positions, confirmation and statements in the Broker-Dealer or Qualified Custodian's portfolio management software and access to related blotters, duplicate and batched client statements, confirmations and year-end summaries. RMR also receives a dedicated trading desk and service group that assists our clients, an account services manager dedicated to our accounts, access to a real-time order matching system, mutual funds with no transaction fees, and select institutional money managers. In addition, we can receive discounts on compliance, marketing, research, technology and practice management products or services provided to us by third-party vendors and the ability to have advisory fees directly debited from client accounts following applicable federal and state requirements. Our approved, Qualified Custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services, discount, or waive fees for some of these services or pay all or a part of a third party's fees. In effect, the fees paid by our clients generate the soft dollars used to pay for such administrative services. The Adviser will not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. The availability of the above services, commonly called "soft dollars," benefits us because we do not have to produce, purchase, or pay for them as long as our clients collectively keep a minimum amount of assets in our Qualified Custodian accounts. Beyond that, these services are not contingent upon us committing any specific amount of business in trading commissions or assets in custody. A conflict exists in such situations because RMR can be incentivized to select or recommend a Broker-Dealer based on the Adviser’s interest in receiving research or other products or services rather than the Adviser’s clients’ interest in receiving the best value in custody services and most favorable execution of their transactions. While the conflict of interest exists, our clients also measure our overall performance; the cost of these services necessarily reduces portfolio performance. It is in our best interests to minimize these costs to improve the overall performance of client portfolios. Furthermore, we believe that the selection of any Qualified Custodian and Broker-Dealers is in the best interests of our clients. The scope, quality, and price of services received primarily support our selection, not services that benefit only us. (Please contact us directly for the most current qualifying amount of client assets numbers.) Directed Brokerage RMR’s Wrap Fee program requires that clients open and maintain a brokerage account through our pre-approved Broker- Dealer/Qualified Custodian. Clients are free to use the Broker-Dealer/Qualified Custodian or financial institution of their choice for any recommendation. However, clients who select RMR as their investment manager must maintain their accounts at one of our approved Broker- Dealers/Qualified Custodians. Clients should be aware that not all advisers require their clients to direct brokerage. Clients who wish to direct brokerage will do so in writing and shall be responsible for negotiating the terms and arrangements with the Broker-Dealer/Qualified Custodian of their choosing. RMR will not be obligated to seek better execution services or prices or aggregate client account transactions for execution through other custodians with orders for different accounts we manage. As a result, a disparity in commission charges can exist between those charged to clients who do not direct brokerage and those who do, resulting in potentially higher trading expenses, costs, and less favorable transaction execution for clients with directed brokerage transactions. Directing brokerage may cost the client money. Clients wishing to direct brokerage should consider the 12  costs or disadvantages of such requests, including paying higher commissions or other transaction costs and greater spreads, being unable to aggregate orders to reduce transaction costs, or receiving less favorable prices on transactions for the account that would otherwise be the case. Accordingly, the client should satisfy themselves that their designated broker can provide adequate prices and execution of their transactions. Subject to its duty to seek best execution, RMR may also decline a client's request to direct brokerage if, at our discretion, such brokerage arrangements would result in operational difficulties. Directed Brokerage - Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted if the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. (Note: ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan.) Trade Aggregation RMR combines multiple orders for shares of the same securities purchased for the advisory accounts we manage ("aggregated trading"). Under RMR’s CIP Wrap Fee Program, –when accounts are being traded, they are included in the block trades processed to rebalance model accounts. If we are trading a one-off position to raise cash, they are not traded. For TPM Wrap Fee Programs, since RMR does not trade these accounts, trade aggregation will occur according to the third-party manager’s direction. The costs of not aggregating orders when the opportunity exists include the inability to facilitate best execution, potentially increasing brokerage commissions or other costs. RMR does not aggregate orders for block trading purposes under its Wrap Fee Program. Types of Investments Clients will invest by establishing one or more accounts (the "Managed Accounts" or "accounts"), each of which is reviewed for qualification and suitability. Assets managed as part of the Wrap Fee Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Wrap Fee Program Services typically provide investment advice for various types of investments and security types, including, but not limited to, stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), unit investment trusts, derivatives, and other investments as discussed herein. The client’s Suitability Information helps us in selecting and allocating assets as follows: Capital Preservation - a portfolio geared towards capital preservation that invests predominately in the fixed-income sleeve while striving to minimize potential losses. This option is focused on clients who prefer more loss protection than a stock-invested portfolio may offer. Conservative – a portfolio designed for clients with interest primarily concerned with reducing asset risk – such as those approaching retirement or who desire decreased risk of loss but still desire some exposure to stocks to provide asset growth potential. Conservative Growth - this portfolio is designed for clients who want the potential for some asset growth. Most assets are invested in the fixed-income sleeve, yet there is a reasonable exposure to equity sleeves. Moderate - this portfolio seeks capital preservation and investment growth as near-equal objectives. The risk/return goal is designed to address a client’s wish for the potential for higher returns from stocks over time without the extreme variations that can occur in the short term. Moderate Growth - a portfolio weighted more toward equity sleeves but with a significant amount of funds in the fixed- income sleeve. This option is designed for clients with a medium to long-term investment horizon. Growth - this portfolio seeks growth through equities while attempting to balance risk using fixed-income funds. It is designed for clients who are comfortable accepting some risk in exchange for the potential for higher returns provided by stocks over time. Aggressive – a portfolio invested predominately in equity with only a small proportion invested in bonds. The goal is to produce investment growth. This portfolio is designed for clients willing to accept a much higher percentage of equities 13  in exchange for the potential for higher returns. Clients should typically have an investment time horizon of more than five years. Item 5: Account Requirements & Types of Clients ____________________________________________________________________________________________________ Types of Clients RMR primarily provides investment advisory services to individuals, high-net-worth individuals, partnerships, trusts, corporations, retirement/pension and profit-sharing plans, charitable organizations, and other institutions and business entities. Minimum Account Size There is no account minimum for RMR’s services and no ongoing contribution requirements for client accounts, although this practice is highly recommended for continuing savings, asset allocation, and tax efficiency. Accounts managed by unaffiliated third-party managers are subject to the independent TPM’s account minimums (typically between $25,000 and $1,000,000), as disclosed in each referred manager's contract. In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they execute with their referred TPM. The following are considerations and other information for your review: Item 6: Portfolio Manager Selection & Evaluation ____________________________________________________________________________________________________ We are the sponsor and Portfolio Manager for CIP and TPM investment accounts. Should we choose to utilize one or more portfolio managers throughout serving you, the evaluation of each portfolio manager will be based on data and information from several sources, including the manager and independent databases. Among the types of information analyzed are historical performance, investment philosophy, investment style, historical volatility, and correlation across asset classes. Performance-Based Fees & Side-by-Side Management Performance-based fees are fees based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. RMR does not accept performance-based fees or participate in side-by-side management. Methods of Analysis We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. With this type of analysis, economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions, and the lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. Fundamental Analysis - a security evaluation method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price to determine what position to take with that security (underpriced = buy, overpriced = sell or short). This security analysis method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Quantitative Analysis - an analysis technique that seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try 14  to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Technical Analysis (“Charting”) - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that the performance of the stock, rather than the performance of the company itself, has more to do with the company’s future stock price. Some risks of this type of analysis include biased opinions or indicators that – while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. Our investment strategies and advice will vary depending on each client's financial situation. Therefore, it is essential that clients notify us immediately regarding any material changes to their financial circumstances, including, for example, a change in their current or expected income level, tax circumstances, or employment status. While RMR’s IARs may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. Additionally, when balancing portfolios, IARs will consider only the account’s managed assets, not other investments the client may hold elsewhere. Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation as we determine investments and allocations based on their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in their best interest objective. Client restrictions and guidelines will also affect the composition of their portfolio. In addition to the “Risks of Loss & Other Types of Risks” provided for review herein, the following are other items can also be items for consideration when determining investment strategies and practices: Asset Allocation - an investment strategy that aims to balance risk and reward by allocating assets among various asset classes. At a high level, there are three main asset classes - (1) equities (stocks), (2) fixed income (bonds), and (3) cash and cash equivalent, each with different risk and reward profiles and behaviors. Asset classes are often further divided into domestic and foreign investments. Equities are frequently divided into small, intermediate, and large capitalization and fixed income into short, intermediate, and long-term durations. The general theory behind asset allocation is that each asset class will perform differently from others in changed market conditions. By diversifying a portfolio of investments among various asset classes, advisors seek to reduce a portfolio's overall volatility and risk by avoiding overexposure to any asset class during different market cycles. Asset allocation does not guarantee a profit or protect against loss. Capital Growth and/or Income Strategy - a“growth and income strategy” often invests in companies with earnings growth and those that pay dividends. Risks associated with a capital growth and income strategy are similar to those experienced with income and growth strategies. For example, bonds can be called when interest rates drop, and replacing a called bond with another paying the same interest may be impossible. Companies can suspend dividends for certain stocks if they experience financial problems. A growth investing strategy includes the search for stocks that have growth potential. The latter means that the stock price will rise at a certain point in time. As a result, growth investors may target young companies that have the potential to exceed their peers in the industry or sector. By its very nature, growth investing implies risk because some of the young companies may fail. Dollar Cost Averaging - the technique of regularly buying a fixed dollar amount of a particular investment, regardless of the share price (“DCA”). More shares are purchased when prices are low and fewer when prices are high. This investment strategy is believed to lessen the risk of investing a large amount at a single investment at a higher price. DCA strategies are ineffective and do not prevent loss in declining markets. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Short-Term Purchases - securities are purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. 15  Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Buying on margin means borrowing money from a Broker-Dealer to purchase stock. Margin trading allows investors to buy more stock than they would typically be able to buy. An initial investment of at least $2,000 is required for a margin account, although some brokerages require more. This deposit is known as the minimum margin. Once the account is operational, the holder can borrow up to 50% of the stock purchase price. This portion of the deposit purchase price is the initial margin. Investors can be required to deposit more than 50% of the purchase price. Not all stocks qualify to be bought on margin. When selling the stock in a margin account, the proceeds go to the Broker-Dealer against the repayment of the loan until it is fully paid. A maintenance margin restriction also exists - the minimum account balance that must be maintained before the Broker-Dealer forces the deposit of additional funds or sell stock to pay down the loan (when this happens, it is known as a “margin call.”) If, for any reason, a margin call is unmet, the Broker-Dealer has the right to sell account securities to increase the account equity until above the maintenance margin. Additionally, the Broker-Dealer may not be required to consult the account holder before selling. Under most margin agreements, a firm can sell the account securities without waiting for the account holder to meet the margin call, and the account holder cannot control which stock is sold to cover the margin call. Interest on the loan must also be paid. The interest charges are applied to the account unless separate payments are made. Over time, the debt level increases as interest charges accrue. As debt rises, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer an investment is held, the greater the return needed to break even. In volatile markets, prices can fall quickly, and more money can be lost than invested. (Note: RMR requires the pre-approval of a designated Home Office Principal before implementing any margin strategy.) Options Writing - a securities transaction that involves selling options, which are the right, but not the obligation, to buy or sell a particular security at a specified price before the option's expiration date. When an investor sells an option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. The buyer pays the seller a premium (the option's market price at a particular time) in exchange for the seller writing the option. Short Selling - clients participating in these portfolios will receive additional disclosure information regarding the risks of short-sale investments. Unhedged, short selling is very risky. Unlike a straightforward investment in stocks, where shares are purchased with the expectation that their price will increase to sell at a profit, in a "short sale," stock is borrowed from a brokerage firm and then immediately sold in hopes that the price will have dropped when they are required to be purchased at a later date. Thus, a short seller hopes a stock's price will decrease in the future to use market declines to their advantage. Short sellers make money when the stock prices fall and lose money when prices increase. The SEC has strict regulations regarding short selling. No ceiling exists on how much a short seller can lose in a trade - if the share price keeps increasing, the short seller must pay the prevailing stock price to buy back the shares. However, a ceiling exists on gains that can be made because a stock’s price cannot fall below zero. In addition, a short seller must undertake to pay the earnings on their borrowed securities as long as they choose to keep their short position open. If a company declares huge dividends or issues bonus shares, the short seller must also pay that amount to the lender. Any such occurrence can skew the entire short investment and make it unprofitable. Finally, a broker can use the funds in the short seller's margin account to buy back the loaned shares or issue a “call away” to require the short seller to return the borrowed securities. If this call is made by the broker when the stock price is significantly higher than the price at the time of the short sale, the investor can suffer tremendous losses. Tax Considerations RMR’s strategies and investments can have unique and significant tax implications. However, unless expressly agreed upon otherwise and in writing, tax efficiency is not the primary consideration in managing client assets. Regardless of client account size or any other factors, RMR strongly recommends that our clients continuously consult with a tax professional before and throughout investing their assets. Qualified Custodians will typically default to the FIFO (“First-In, First-Out”) accounting method for calculating portfolio investment cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If a client or their tax advisor believes another accounting method is more advantageous, immediately notify our firm and the account Qualified Custodian of the selected accounting method in writing. (Note: Decisions about cost-basis accounting methods must be made before trades settle, as the cost-basis method cannot be changed after settlement.) 16  Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. RMR will generally provide investment advice and money management for a varied range of product offerings and securities including, but not limited to, business development companies, commercial paper, certificates of deposits, derivatives, digital assets, equities, exchange-traded funds (“ETFs”) exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships in real estate, oil, and gas, load and no-load mutual funds, options, real estate investment trusts, private placements, bonds (treasury inflation protected/inflation-linked), unit investment trusts, warrants, and non-U.S. securities. RMR typically avoids market timing but will increase cash holdings when necessary. When recommending investments in mutual funds, it is RMR’s policy to consider all available share classes and select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically have a lower cost than other share classes. Generally, institutional class shares do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost. Although RMR provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. Cash Management As indicated below, RMR usually invests clients' cash balances in Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts, money market funds, or certificates of deposit. In managing the cash maintained in client accounts, we will typically utilize the sole exclusive cash vehicles made available by the custodian, according to their parameters. Other cash management and money-market options may be available away from the custodian with higher yields or safer underlying investments. In most cases, at least a partial cash balance will be maintained in a money market or FDIC-insured deposit account to allow for the debit of Advisory Fees or anticipated cash distributions to clients. We will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: This type of investment product is usually not FDIC insured, insured by any Federal government agency, a deposit, other obligation, or guaranteed by the adviser.) Risks of Specific Securities Utilized While RMR seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. IARs will recommend various types of securities, as indicated herein and deemed appropriate for each client’s situation, restrictions (if any) and goals. Although advice is provided predominantly on the products listed within this Brochure, RMR reserves the right to advise on any suitable investment product for a client's specific circumstances, needs, and individual goals and objectives. We will use other securities to help diversify a portfolio when applicable and appropriate. Investing also risks missing more favorable returns that could be achieved by investing in alternate securities or commodities. Any of the above investment strategies may lead to a loss of investments, especially if the markets move against the client. Additionally, we may advise on other investments held in the portfolio at the inception of the advisory relationship. Since investment strategies and advice are based on each client's financial situation, the advice we provide to one client may differ or conflict with that provided for the same security or investment for another, as each client's needs and risk tolerance differ. Clients should be aware of the material risk of loss when using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. 17  Recommendation of Particular Security Types RMR recommends various types of securities and does not primarily recommend one type over another since each client has different needs and risk tolerance. As each security type has its unique set of associated risks, it would be impossible to present every specific risk of each investment type. Even within the same kind of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. A description of some of the security types we may recommend and some of their inherent risks follow: Annuities - annuities are financial products that pay out a fixed stream of payments to an individual, primarily used as an income stream for retirees. The period when an annuity is funded before the payouts begin is called the accumulation phase. The annuitization phase begins once payments commence. Annuities can be structured as fixed or variable. Fixed annuities provide regular periodic payments to the owner/annuitant. Variable annuities allow the owner/annuitant to receive larger periodic payments if the investments in the annuity do well; however, if the investments do poorly, the owner/annuitant will receive smaller payments. In addition, the annuity services offered by RMR will incur additional charges, expenses, and miscellaneous fees that are separate and distinct from the Advisory fee charged by the Adviser. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default when the bond is set to mature; and, whether the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character, paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Certificates of Deposit - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Corporate Bonds - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but 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 higher its interest rate risk. Digital Assets - As used herein, “Digital Assets” refers to an asset issued and/or transferred using a distributed ledger or blockchain technology. The investment objective of RMR’s Digital Asset Account allocation is to offer interested clients exposure to the Digital Assets market via a portfolio comprised of Digital Assets. Digital Asset services clients will maintain their assets with an available custodian offered through Securitize, a platform solution RMR engaged in delivering these services. Available custodians include but are not limited to, Gemini, Coinbase, Anchorage Digital, and the Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under these services. An investment in Digital Assets is appropriate only for clients who (1) understand the speculative nature of such securities, (2) can bear the economic risk of the investment, (3) have no urgent need for liquidity with the assets committed to this type of investment, and (4) and are willing to accept the risks of loss of their entire investment in exchange for the potential benefits and returns Digital Assets may offer. 18  Given the complexity of this product, investment decisions made for the allocation of any portfolio of Digital Assets are expressly subject to various potential risks, including but not limited to the following: Custody Risk - under the Advisers Act, SEC-registered investment advisers must hold securities with “Qualified Custodians,” among other requirements. Certain Digital Assets may be deemed to be securities. Some Digital Assets do not currently fall under the SEC definition of security. Therefore, many companies providing Digital Assets custodial services fall outside the SEC’s definition of “Qualified Custodian.” Accordingly, clients seeking to purchase actual digital coins/tokens/currencies may need to use non-Qualified Custodians to hold all or a portion of their Digital Assets. Further, Digital Asset holdings are not considered legal tender or insured by the government like U.S. bank deposits. Therefore, investors do not have the same protections as a bank account can offer. Unlike most traditional currencies, such as the U.S. dollar, the value of a Digital Asset is not tied to promises by a government or a central bank - Digital Asset investments are uninsured. Exchange & Business Hours Risk - exchanges can stop operating due to security breaches, fraud, insolvency, market manipulation, market surveillance, KYC/AML procedures, non-compliance with applicable rules and regulations, technical glitches, hackers, malware or other reasons. Blockchain technology is a relatively new and untested technology that operates as a distributed ledger. Blockchain systems could be subject to internet connectivity disruptions, consensus failures or cybersecurity attacks, and the date or time an investor initiates a transaction may differ from when the transaction is recorded on the blockchain. Digital Asset prices can fluctuate, sometimes heavily, after traditional market hours. RMR accepts no responsibility for being unable to buy or sell Digital Assets outside of standard industry trading hours. Government Oversight of Digital Assets Risk - regulatory agencies and/or the constructs responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and subject to change. Regulators may adopt laws, regulations, policies or rules directly or indirectly affecting Digital Assets, their treatment, transacting, custody, and valuation. Liquidity Risk - any liquidity may be limited or disrupted, and there can be no guarantees of the ability to sell or exchange Digital Assets at any price. There is a possibility that trades cannot be settled, may be challenging to settle, or can be traded only at significantly adverse prices depending on the market situation or market volume. Loss of Confidence Risk - Digital Assets are part of a new and rapidly evolving “Digital Assets industry,” subject to high uncertainty. For a relatively small use of Digital Assets in the retail and commercial marketplace, online platforms have generated a large trading activity by speculators seeking to profit from the short-term or long-term holding of Digital Assets. Most Digital Assets are not backed by a central bank, national or international organization, assets or other credit. Their value is strictly determined by the value that market participants place on them through their transactions, which means that a loss of confidence may bring about a collapse of trading activities and an abrupt drop in value. Peer-to-Peer Transaction Risk - Digital Assets can be traded on numerous online platforms through third- party service providers and peer-to-peer transactions between parties. Many marketplaces bring together counterparties without providing clearing or intermediary services or being regulated. In such a case, all risks (such as double-selling) remain between the parties directly involved in the transaction. Price Volatility of Digital Assets Risk - a principal risk in trading Digital Assets is the rapid market price fluctuation. The value of client portfolios relates in part to the value of the Digital Assets held in the client portfolio; fluctuations in the price of Digital Assets could adversely affect the value of a client’s portfolio. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex factors such as supply and demand, availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Digital Assets users and market participants; perceived or actual security vulnerability; and traditional risk factors including inflation levels; fiscal policy; interest rates; and political, natural and economic events. Protocol & Governance Risk - Digital Assets are a relatively recent technological innovation. Bitcoin, invented in 2009, is widely considered the first popular Digital Asset. Other Digital Assets in which we may invest were created after Bitcoin. There can be no assurance that the Digital Asset industry will continue in its current 19  form. Digital Assets are generally designed and supported by an underlying blockchain or protocol, such as the Bitcoin Protocol or the Ethereum Protocol. Any malfunction, malicious attack, breakdown or abandonment of the network may have an adverse effect on the Digital Asset’s protocol or network, which could lead to loss of value of the Digital Asset. Moreover, advances in cryptography, or technical advances such as quantum computing, could present risks to Digital Assets by rendering the cryptographic consensus mechanism that underpins a Digital Asset’s protocol ineffective. There can be no assurance that changes or developments in Digital Asset protocols will not adversely impact your Account. Regulatory Risk - regulatory uncertainties surrounding blockchain and distributed ledger technologies abound. Because global and national standards are far from being fully established, fund managers face the heavy disclosure obligation to disclose existing regulatory considerations and the potential outcome of various regulatory issues that have yet to be decided. The comprehensive regulation facilitating institutional investment will require coordinating global standards, particularly for the exchanges. For U.S. governance, regulatory standards will likely be set not by a single authority but by a combination of state, national, international and industry bodies, judicial precedent, international agreements, and industry associations. Service Providers Risk - service providers that support Digital Assets and the Digital Asset marketplace(s) may not be subject to the same regulatory and professional oversight as traditional securities service providers. Further, there is no assurance that the availability of and access to virtual currency service providers will not be negatively affected by government regulation or the supply and demand for Digital Assets. Accordingly, companies or financial institutions that currently support virtual currency may not do so. Taxation Risk - it should be noted that there is substantial uncertainty concerning the tax treatment of an investment in Digital Assets. Digital Assets may be considered assets in certain jurisdictions and currency in others. Sales or value-added taxes may be imposed on purchases and sales of Digital Assets. Based on their home jurisdiction, the investors may require specific tax advice regularly to ensure the tax treatment of their investments in Digital Assets. Technology & Security Risk - Digital Assets are computer-coded entries on a digital ledger, or blockchain, visible to and verifiable by nodes. Ownership is reflected in a string of numbers on a distributed ledger, accessible only by a public and private key in “wallets.” A custodian could hold a “private key” and a “public key” to the Digital Asset to satisfy regulatory requirements. A custodian can maintain private keys in digital form on a computer hard drive unconnected from the internet and protected by layers of cybersecurity. The custodian can also preserve and secure the private key in a “cold wallet” by, for example, locking it in a physical vault. In any event, the technology used for safeguarding Digital Assets is emerging. Digital Assets are essentially bearer assets. In general, anyone who obtains possession of the private key can, in theory, misappropriate the asset, no matter where the private key is maintained. Unanticipated Risks - Digital Assets are new and still largely untested. In addition to the risks disclosed, there are other risks associated with purchasing Digital Assets that RMR cannot anticipate. Such risks may further materialize as unanticipated variations or combinations of the risks discussed. Digital Asset investments are inherently global; therefore, exchange platforms, custodians, counterparties, and issuers are rarely located within a single jurisdiction. The industry does not have a standard regulation or auditing practice for accounts holding Digital Assets to verify ownership. The Investment has counterparty and custody risks, including loss or theft of the Digital Asset Itself. Valuation Risk - the valuation of Digital Assets can differ significantly depending on the price source or otherwise due to factors including, but not limited to, market fragmentation, unregulated markets, illiquidity and volatility. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. Volatility & Loss Risks - Digital Assets are highly speculative and involve high risk. Prices of Digital Assets are incredibly volatile and can have higher volatility than other traditional investments such as stocks and bonds, and market movements can be challenging to predict. If the value goes down, it is not guaranteed to rise again. As a result, there is a significant risk of losing the entire principal investment. Gains or losses are unpredictable, and there can be no guarantee of returns. Interests should not be purchased by anyone who cannot afford the loss of their entire investment. Transactions in Digital Assets may be irreversible, and losses due to fraudulent or accidental transactions may not be recoverable. No regulation or standard auditing 20  practice currently exists for accounts holding digital assets to verify ownership. There are counterparty and custody risks associated with Digital Assets, including loss or theft of the Digital Asset. Exchange-Traded Funds (“ETFs”) - are typically investment companies classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, particularly when ETF shares are listed on a securities exchange. An ETF is designed to track the price of an index or a collection of underlying assets as closely as possible. Shares can be bought and sold like shares of publicly traded companies throughout the day and may trade at a discount or premium to their NAV. This difference between the bid and ask prices is often called the "spread." The spread varies over time based on the ETF's trading volume and market liquidity, and it is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, like traditional mutual funds, some ETFs (particularly those that invest in commodities such as gold and precious metals) are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged ETFs, in particular, present distinct risks and are not appropriate for all investors. Leveraged ETFs should be utilized only by those investors who understand the risks of seeking daily leveraged and inverse investment results, generally for short- term active trading in an actively monitored and managed investment program. Investors must be aware of the daily nature of the leveraged and inverse investment strategies employed, high expense ratios, and lack of guarantee of long-term inverse returns, among other considerations, before participating in this type of investment. Exchange-Traded Notes (“ETNs”) - an ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to various assets, such as commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption depends on the ETN issuer's ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer's credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. Fixed Income Call Options - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Limited Partnerships, Limited Liability Companies & Business Development Companies - limited partnerships, limited liability companies and business development companies represent different forms of ownership of investment assets. These entities are investment vehicles that may own full or partial interest in various operating businesses. The types of operating companies may include but are not limited to equipment leasing, oil and gas, alternative energy, and real estate. Managed Futures Funds - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that trade various derivative instruments, including options, futures, forwards, or spot contracts, which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds. It may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and costs. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay 21  various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission notes, "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long- term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds - mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. Mutual funds can also be "closed-end" or "open-end." So-called “open-end” mutual funds allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. Some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund; others charge such fees, which can also reduce returns. Mutual funds are sold with different share classes and will offer investors discounts on sales charges, as described and explained in each fund's prospectus. Funds will have a manager who trades the fund's investments following the fund's investment objective. Mutual fund shares held in client accounts may also be subject to 12b-1 fees, short-term redemption fees, and other fund annual expenses. No-load or load-wave mutual funds used in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Non-advisory accounts typically have upfront or back-end charges. Each fund's prospectus fully describes these fees and costs. If clients have mutual funds in their portfolio, they will pay their adviser and any third-party manager, custodian, and mutual fund manager to manage their assets and other fund expenses paid by the fund's shareholders. If clients transfer in particular share classes of mutual funds and liquidate the shares after the transfer, those shares can also incur contingent deferred sales charges (“CDSCs”) from the mutual fund company if they are within the CDSC holding period. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. In short, all these costs of managing the funds can reduce the fund’s returns. Options - options are complex securities involving risks that are not necessarily in everyone’s best interest. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: 1. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. 2. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. 22  The option trading risks of options buyers are the risk of losing your entire investment in a relatively short period. This risk increases if, as expiration nears, the stock is below the call's strike price (for a call option) or if the stock is higher than the put's strike price (for a put option). European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. In addition, specific exercise provisions of a specific option contract may create risks, and regulatory agencies may impose exercise restrictions, which stop you from realizing value. Selling options is more complicated and can be even riskier. The option trading risks for options sellers include but are not limited to: options sold may be exercised at any time before expiration, covered call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock, the sale, - - writers of naked calls risk unlimited losses if the underlying stock rises, writers of a naked put are exposed to a maximum loss of the strike price less the premium received from - - writers of naked positions run margin risks if the position goes into significant losses, and such risks may include liquidation by the broker, - writers of call options can lose more money than a short seller of that stock on the same rise on that - underlying stock - an example of how the leverage in options can work against the options trader, writers of naked calls must deliver shares of the underlying stock if those call options are exercised, call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions, - - writers of stock options are obligated under the options that they sold even if a trading market is not - available or they cannot perform a closing transaction, and the value of the underlying stock may surge or drop unexpectedly, leading to automatic exercises. - Other option trading risks include the complexity of some option strategies carrying a significant risk on their own, option trading exchanges or markets and options contracts are open to changes at all times, options markets have the right to halt the trading of any options, thus preventing investors from realizing value, there is a risk of erroneous reporting of exercise value, investors trading through that firm may be affected If an options brokerage firm goes insolvent, and Internationally traded options have unique risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. (Note: RMR requires the pre-approval of a designated Home Office Principal before any naked option writing strategy can be implemented.) Options Contracts - Options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should know the option trading risks associated with their investment(s). Real Estate - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and growing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. 23  Real Estate Investment Trusts - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations. Hence, cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re- extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Securities Futures Contracts - a futures contract (on tangibles and intangibles) is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a specific commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Risks of Loss & Other Types of Risk clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. RMR cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client. It may depend on many distinct risks, each affecting the probability and magnitude of potential losses. The following risks, which are not all-inclusive, are additional risks provided for careful consideration by a prospective client before retaining our services. (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities – an adviser's investment activities involve risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and advisor investment decisions will not always be profitable. Artificial Intelligence - we may leverage artificial intelligence ("AI") to enhance operational efficiency and improve client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment advice. Instead, our AI applications are primarily focused on automating administrative and client service-related tasks, including meeting preparation, note-taking, CRM updates, task management, and generating meeting recap notes. We believe AI streamlines client engagement, reduces administrative burdens, and ultimately enhances the overall client experience. It is essential to recognize that AI models are inherently complex, and their outputs may sometimes be incomplete, inaccurate, or biased. While AI serves to augment our operations, its use introduces certain risks, such as the potential for inaccuracies, decision-making errors, and challenges related to the effective deployment of the technology. Additionally, AI usage may pose risks to the confidentiality of client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both client and proprietary information. We continuously evaluate the performance of AI technologies to 24  ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance Business Risk - is the risks associated with a specific industry or company. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which ensures that the client's interest is always held above that of the firm and its associates. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non- U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an asset to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions 25  decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, such as losing your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. 26  Market Timing Risk - The risk of market timing based on charting and technical analysis is that charts may not accurately predict future price movements. Current securities prices may reflect all information known about the security. Daily changes in market prices of securities may follow random patterns and may not be predictable with reliable accuracy. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. The risk of cyclical analysis is that economic/business cycles may not be predictable and have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the rules to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - companies face a complex set of laws and circumstances in each country they operate in. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks - a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and 27  key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stock Risk - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"). Still, the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Fund Risk - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - a stock's market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always insured by the Federal Deposit Insurance Corporation; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. 28  However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrant Risks - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. RMR attempts to address the above risks by diversifying among multiple asset classes and asset strategies, creating different portfolio segments. Any security eligible for inclusion in the portfolio with low or no liquidity may be removed and replaced by the next highest-ranked security in the same asset segment. Due to the fluctuating nature of security prices, the weighting of an individual security or sector in the portfolio may change after the portfolio is established. RMR does not represent or guarantee that the services provided or any analysis methods provided can predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate within a wide range, such as the overall stock and bond market fluctuations. 29  Before acting on RMR’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, and other financial Investment Professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable IAR. Voting Client Securities Proxy Voting RMR will not ask for or accept voting authority for client securities and is not obligated to forward proxy notices to clients or their agents. Clients will receive proxy material directly from the security issuer, their Qualified Custodian, or the Insurance Company and/or its approved Custodian(s). Clients are responsible for exercising their right to vote for proxies. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the Plan Fiduciary holds proxy voting authority and responsibility for the Plan account in accordance with the requirements of Plan documentation. If the Investment Manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the Plan document. RMR may recommend and refer certain clients to third-party asset allocation or Managed Account programs. Depending on the referred manager’s proxy voting policies and procedures - and as disclosed within the TPM’s Form ADV 2A and separate advisory contract, clients participating in one of these programs may appoint the referred manager as their agent and attorney- in-fact with discretion to vote proxies for securities held in their account. Clients should carefully review the TPM’s disclosure brochures and advisory contract to understand the referred manager’s proxy voting policies and procedures. While RMR will assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because it supplies client information about a particular proxy vote in any of the above situations. The client must vote for their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. RMR has no duty or obligation to evaluate a client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client’s account or securities issuers. RMR does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client’s account or the issuers of such securities. RMR is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client’s responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. For TPM investment accounts, depending on the TPM's proxy voting policies and procedures, the TPM may require that you appoint them as your agent and attorney-in-fact with discretion to vote proxies on your behalf. Please review the TPM's disclosure brochure carefully to understand their proxy voting policies and procedures. Item 7: Client Information Provided to Portfolio Managers ____________________________________________________________________________________________________ In addition to the personal data required to open an account, such as your name, address, birth date, Social Security number and employment information, we supply the Portfolio Manager and/or Program sponsor with information regarding your financial background and investment objectives to the extent such information is provided by you, at the time it is received from you, and when it is of benefit to the manager for performance of their responsibilities. We communicate changes in your policy to the Portfolio Manager as they occur. 30  Item 8: Client Contact with Portfolio Managers ____________________________________________________________________________________________________ There are no restrictions on clients contacting managers directly. Each Managed Account is managed individually and separate from the accounts of other managed clients. You receive confirmations of each securities transaction placed by the manager for your account and periodic custodian account statements and reports. There are no restrictions on a client’s ability to contact their Portfolio Manager or us directly with any questions regarding their account. RMR, through its IARs, is available to clients on an ongoing basis to discuss client financial circumstances, the selected portfolio and the securities therein or to process instructions from clients concerning advisory assets. Clients are encouraged to contact us directly with questions regarding their Wrap Fee Program account, investment objectives, risk tolerance changes, or restrictions on managing their Wrap Fee Program assets. Item 9: Additional Information ____________________________________________________________________________________________________ Disciplinary Information Registered investment advisers are required to disclose all material facts concerning any legal or disciplinary events that may be relevant to a client's or prospective client's evaluation of the adviser or its management’s integrity. A state regulatory agency took disciplinary actions against certain members of RMR's management for violations of securities regulations, rules, and/or statutory provisions. These matters have since been resolved. For complete details on our disciplinary history and full disclosure documents, please visit the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov and search for our firm name or CRD #169005. Beyond these matters, neither the Adviser nor its management has any additional disciplinary or legal proceedings to disclose that would be material to a client’s evaluation of this advisory practice. RMR has no outstanding issues, and the firm, along with all Control Persons, is appropriately registered without restriction. You may also view information about any affiliated person who is registered or required to be registered as an Investment Adviser Representative of the firm by similarly searching their name or CRD # on the same IAPD website. Copies of this information can also be obtained by contacting us directly. Other Financial Industry Activities and Affiliations Broker-Dealer & Registered Representatives of A Broker-Dealer RMR is not registered and does not intend to register as a Broker-Dealer. From time to time and in connection with their approved outside business activities, certain of RMR’s Investment Professionals can also be Registered Representatives (“RRs”) of non- affiliated Broker-Dealers, Member FINRA and SIPC. When acting in the capacity of RRs of such unaffiliated Broker-Dealers, these Associates will sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, variable annuity, or others to clients and receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. (See “Conflicts of Interest” at the end of this section for additional important information.) Investment Advisor Representatives of Other Unaffiliated Investment Advisory Firms Certain RMR IARs are also registered IARs of other non-affiliated registered investment advisory firms. IARs who maintain outside business activities with such firms are required to provide the disclosure documents of outside investment adviser’s disclosure brochures and documentation. RMR clients should understand that any assets they place under the management or within any other outside investment advisory firm’s programs are separate and distinct from their Agreement and assets managed by RMR. Further, a conflict of interest exists to the extent that while the services offered by RMR and another unaffiliated adviser may be similar, clients' fees and other costs for such services may differ. RMR does not share any portion of the investment advisory fee a client will pay for another firm due to an RMR Associate’s outside business activity. Commissions or other compensation earned by RMR Associates in their capacities as employees of unaffiliated firms are separate and in addition to the advisory fees paid to RMR under our Agreements. (See “Conflicts of Interest” at the end of this section for additional important information.) Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither the Adviser nor any management persons are registered or intend to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an Associated Person of the preceding entities. 31  Insurance Sales & Services - Affiliated & Unaffiliated Insurance Agencies RMR Wealth Builders, Inc., the investment adviser, is affiliated with RMR Wealth Builders, Inc., a New Jersey Insurance Producer of a similar name (Insurance Producer License # 8729246). RMR’s insurance-licensed Investment Professionals will offer variable life, variable annuity, accident & health, sickness and life or other insurance products from time to time and when appropriate to their RMR advisory clients in connection with their approved outside business activities for these products and recommend advisory clients consider either insurance products and services. Insurance company personnel also retain the discretion to introduce non-advisory clients to the investment adviser for advisory services. In this capacity, in addition to their compensation from RMR, insurance-licensed Investment Professionals can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of insurance products from the insurance agencies with whom they are presently or with whom they may become appointed in the future. The insurance commissions earned by these individuals are separate from and in addition to RMR’s advisory fees. Commissions are based on the standard commission schedule of the insurance products provider and are generally not negotiable. This presents a conflict of interest since, to the extent that clients of the investment adviser can also use an insurance company’s services, the activities and fees of such companies are essential to understand. RMR Associates, licensed as Insurance Agents, are incentivized to effect suitable insurance transactions based on the potential for commission compensation received rather than the client’s best interests. Advisory clients should be aware that when using the services of any such insurance entity, such services are not provided by RMR, the investment adviser. Any insurance services offered are separate and distinct from the client's relationship, Advisory Agreement and services provided by RMR (the investment adviser). The insurance commission paid to licensed Insurance Agents will be based on the standard commission schedule of the insurance products provider and are generally not negotiable. Insurance commissions are separate from RMR’s advisory fees. The services of companies other than the Adviser are also subject to separate and distinct contractual arrangements. Further, the protections afforded to clients under applicable investment advisory laws and regulations generally do not apply to those provided by any RMR affiliate or an unaffiliated company. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Adviser or utilize the services of any affiliate or other industry relationship. Advisory clients maintain complete discretion regarding whether to use the services of RMR, RMR-affiliated entities, or other industry relationships that may be recommended. (See “Conflicts of Interest” at the end of this section for additional important information.) Designations & Other Outside Business Activities Our IARs can, with approval, operate their own independent companies outside of RMR. These unaffiliated companies include, among others, accounting and tax practices and insurance services. As such, there is a potential conflict of interest because RMR’s Investment Professionals can earn compensation from RMR and the unrelated business activity. In addition, RMR Associates hold various other designations in connection with these approved outside business activities, separate from their role as IARs with RMR. RMR does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from RMR’s advisory services and fees. (See “Conflicts of Interest” at the end of this section for additional important information.) Recommendation of Other Advisers & Third-Party Money Managers RMR may allocate all or a portion of client assets to a third-party adviser or manager. RMR receives compensation from the third-party referred managers and advisers, who we recommend that you use their services, and, in such instances, the fees can be shared between RMR and the third-party adviser or manager. Before selecting any outside manager, RMR will review the manager to ensure they fit the adviser’s models' criteria and conduct initial background due diligence. Referred managers must be registered with an appropriate regulatory body and enter RMR's Terms and Conditions Agreement before being included as a potential client referral. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which clients are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style, will be disclosed in each contract between the RMR, the third-party money managers, and the client. RMR reserves the right to add or delete managers as deemed necessary. 32  These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the third party. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended referred managers. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access accounts of plan participants to provide advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to provide advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans that RMR and its IARs are the advisors of record. Future Clients RMR may provide investment advisory services to other clients in the future. Other future clients may have investment objectives, programs, strategies and positions that are similar to or may conflict with those of our current clients or may compete with or have interests adverse to our current clients. This conflict could affect the prices and availability of financial instruments in which the current clients invest. However, there can be no assurance that other future clients with similar investment objectives, programs or strategies will hold the same positions or perform substantially similar to our current clients. Furthermore, our activities with respect to other future clients could conflict with our activities relating to our current clients. RMR may give advice or take action for the investments and transactions in one client account that may differ from the advice given or the timing or nature of action taken for financial instruments and transactions for other client accounts due to a variety of factors such as regulatory and tax issues and differences in investment programs. As a result, even though our clients may have similar investment objectives and pursue similar investment strategies, they may have substantially different portfolios and investment returns. Conflicts of interest may also arise when we make decisions on behalf of clients where the interests of some clients differ from the interests of others. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Other Business Relationships RMR uses third-party resources to help run its business and provide services to its clients, mostly back-office related. RMR sources these professionals striving to act in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither RMR nor its Associates receive compensation for such use or referrals. Conflicts of Interest The practice of making clients aware of the above other financial activities, affiliations, designations, and relationships and the services discussed above presents a conflict of interest since RMR’s Investment Professionals may have a financial incentive to submit advisory clients to certain companies or services over others due to potential compensation received in connection with the transaction. This can incentivize them to introduce their clients to the professionals or services based on their compensation rather than client needs. Likewise, persons associated with the affiliated companies or outside relationships may refer their non-advisory clients to RMR. RMR addresses this conflict of interest by requiring Associates to always act in each client's best interests. Before the transaction, RMR’s Investment Professionals must fully disclose such relationships when making recommendations. If offering clients advice or products outside of RMR, they satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid/received before transaction execution. When acting in this capacity, RMR’s Investment Professionals are not acting on behalf of RMR, the investment adviser, concerning the client's services under an RMR Advisory Agreement. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. Further, they are not obligated to place the transaction through RMR if they elect to act on any recommendation received. The client may act on recommendations received by placing their business and securities transactions with any brokerage firm or third party. RMR makes no assurances that another entity's products or services are at the lowest available cost. Clients may obtain 33  the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMRs Code is available for review free of charge to any client or prospective client upon request. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt a Code of Ethics that sets forth standards of conduct and requires compliance with federal securities laws. RMR takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Personnel who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, RMR has adopted a Code of Ethics (“Code”) that sets forth the firm's conduct standards in keeping with its fiduciary obligation. RMR strives to comply with applicable laws and regulations governing our practices. The adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all RMR Associates, including individuals registered with the adviser as IARs or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. RMR's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates that they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Associates are required to attest no less than annually to their compliance with and understanding of the above matters - including confirmation and acknowledgment by every licensed IAR of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMR's Code is available for review free of charge to any client or prospective client upon request. An electronic copy of our Code of Ethics is also available for your review at www.rmrwealth.com. Participation Or Interest In Client Transactions Neither our firm nor any persons associated with our firm have any material financial interests in client transactions beyond the provision of investment advisory services as disclosed herein. Further, RMR’s policy is that neither the firm nor any Associates may share in the gains and losses associated with any purchase or sale of a security on your behalf. Personal Trading Practices RMR or persons associated with our firm may buy or sell securities that we recommend to you or securities in which you are already invested; at the same time, we buy or sell such securities for our account. This act can allow them to buy or sell the same securities before or after, suggesting them to clients and profiting from the recommendations provided. RMR’s policy is that neither our firm nor persons associated with our firm shall have priority over client accounts in the purchase or sale of securities; we will always transact client business before their own when similar securities are being bought or sold and document any transactions that could be construed as a conflict of interest, per firm procedures. Regardless, a conflict of interest exists in such cases because we can trade ahead of clients and potentially receive more favorable prices than they will receive. 34  RMR recognizes that the individual investment transactions of members and Associates of the adviser demand the application of a high Code of Ethics and require all such transactions to be carried out in a way that does not endanger the interest of any client. At the same time, RMR believes that if the investment goals of clients and firm members are similar, having common ownership of some securities is logical and desirable. RMR has instituted within its Code of Ethics (“Code”) a Personal Securities Transactions & Trading Policy, which consists of personal trading and pre-clearance procedures for Associate account transactions and a transaction reporting system to monitor compliance with this policy. The firm’s Code also includes policies and procedures to address insider trading, other personal securities transactions, and many other essential safeguards required of its Associates. Upon employment or affiliation and at least annually after that, Associates must sign an acknowledgment stating they have read, comprehend, and agree to comply with its Code. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. RMR does not permit insider trading and has implemented procedures to ensure that Associates observe its insider trading policy. Associates know the rules regarding material non-public information and insider trading and seek to ensure they do not benefit personally from the short-term market effects of their client recommendations. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details on how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMR’s Code of Ethics is available for review free of charge to any client or prospective client, who can contact us directly. Conflicts of Interest RMRs policy prohibits the firm, its Associates, and any related person from participating in trading that may be detrimental to any advisory client or in conflict with the Adviser's written supervisory compliance policies and procedures, Code of Ethics, or any applicable rules of state and federal securities laws, including prohibitions on personal and insider trading. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures, including maintaining transaction records, to ensure that no Associate receives preferential treatment over advisory clients or affects the markets. RMR performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm that no conflicts have occurred. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMR's Code is available for review free of charge upon request by any client or prospective client contacting us directly. Review of Accounts Initial client Agreements are reviewed and approved by the Director of Compliance & Operations, their Designee or another firm Principal, as appropriate. Designated Supervisors will also periodically review ongoing client account transactions and oversee IAR annual account review obligations. All portfolio management accounts are monitored annually or more frequently as agreed upon with the client. Content & Frequency of Regular Reports Provided to Clients Firm Statements & Reports RMR client communications occur at several levels. Client meetings will generally be held annually to review the client’s account and determine the appropriateness of its holdings. Meetings, telephone calls, emails, and letters will provide information from time to time as circumstances warrant. Market commentaries, articles and newsletters on investment and financial planning topics can also be provided to all clients throughout the year. While clients will not receive additional reviews, statements, and reports outside of those required under Rule 206(4)-2 of the Adviser’s Act or beyond the services contracted for in the client’s Agreement, additional reporting may be made available on an ad-hoc basis as agreed to between RMR and the client. Custodial Statements & Reports At the time of account inception, clients will direct their Qualified Custodian to send them statements at least quarterly, (1) reflecting all account transactions that occurred during the previous reporting period, the funds, securities, and other property in the account at the end of the period, and (2) provide RMR duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. 35  The client’s Qualified Custodian will then provide quarterly account statements describing all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the period beginning and ending. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Clients may also receive trade confirmation documents from their custodians for each buy or sell transaction within their account. Client statements will be sent to the address provided by the client to RMR or such other address to which the client may request in writing that they be sent. RMR urges clients to promptly review any statements they receive from their custodian upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate blended benchmark applicable to the type of investments held in the account and any periodic report or information from us. The information obtained from RMR may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodology of particular securities. RMR encourages clients to ask us questions about their assets' custody, safety, or security or any statements received. Clients may request a verbal or written report at any time. If a client believes there are any inaccuracies or discrepancies in any reports received, or if they do not understand the information reflected in any document received, they should promptly, and in all cases before the next statement cycle, report their concerns to RMR. Unless the client indicates otherwise, by promptly notifying us in writing of concerns regarding statements received or specific investment restrictions on the account(s), investments made in line with the client's stated investment objectives RMR recommends or makes on behalf of a client shall be deemed to conform with the client's investment objectives. Client Referrals & Other Compensation Preferred Qualified Custodians RMR receives an economic benefit from our preferred Qualified Custodians through the support products and services available to us and other independent investment advisers who also recommend their clients maintain accounts with them. Because of such arrangements, we benefit from referral arrangements because the cost of these services would otherwise be borne directly by our firm. While clients do not pay more for assets maintained at our preferred Qualified Custodians, clients should consider these conflicts - the products and services provided by each custodian, their benefits to us, and any related conflicts of interest described herein, when making a custodian selection. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account custodian.) Economic Benefits Provided by Third Parties Custodians and certain mutual funds participate in activities designed to help facilitate the distribution of their products by providing RMR’s Investment Professionals with sales awards and other prizes, instruction about their products, and through marketing activities or instructive programs including, but not limited to, fund representative conference attendance, one-on-one marketing efforts and/or due diligence presentations. When RMR participates in these activities, the Adviser receives additional compensation such as 12b-1 fees disclosed in a fund’s prospectus fee table and expense reimbursements. These payments are generally paid from the fund or fund affiliate’s assets. Therefore, certain expenses not paid out of fund assets would not appear in a fund’s expense table. No portion of these payments to RMR or an IAR is made using brokerage commissions generated by the fund. It is important to understand that no payments other than 12b-1 fees received by RMR are paid or directed to any IAR recommending these funds. RMR IARs do not receive a greater or lesser percentage of the commission for sales of mutual funds. You should be aware that different funds charge different commissions. Because RMR IARs receive no direct increase or change in the percent of commissions they are paid for selling shares of one fund over another, we do not believe that they are subject to a conflict of interest based on the percent of commission each IAR receives when recommending one fund’s shares over another’s. However, the marketing and educational activities paid for by a fund could lead our IARs to focus more on those funds. Promoter Relationships RMR has entered into solicitor (“Promoter”) relationships with qualified individuals who are paid to refer clients to the Adviser, which can result in the provision of investment advisory services. When engaging Promoters, RMR will ensure all are licensed and otherwise qualified as required. Unlicensed Promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all Promoter arrangements are defined by a contract between the Promoter and RMR, which sets forth the terms of the Agreement and form of 36  compensation to the Promoter, a percentage of the Advisory Fees received from referred clients. As a consultant and independent contractor, and not an employee of Advisor, the Promoter will use its best efforts to solicit and refer as clients to Advisor those individuals or entities which it believes are in the best interest of the client to be introduced to the investment advisory services provided by Advisor. The Promoter has no authority to accept any client(s) on behalf of the Adviser, and the Adviser has no responsibility to accept any prospective client referred by the Promoter. The Promoter’s primary role is to introduce and assist each prospective client in establishing a relationship with the Adviser, including introducing prospective clients and providing information about RMR. The Promoter’s services may also include periodic contacts to update client information on behalf of the Adviser. The Promoter will keep confidential any client information obtained in connection with this arrangement, which will not be disclosed without the appropriate consent obtained. For the solicitation services provided by the Promoter, the Adviser will either pay a flat one-time fee for any solicited client or a percentage of investment Advisory Fees received from any solicited client over a period agreed upon in the Promoter’s contract with RMR. This fee is not passed on to the client. RMR will also make available and refer clients to the FICA® | For Advisors Cash Management Program sponsored by StoneCastle Cash Management, LLC and earn a referral fee from StoneCastle if clients participate. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss” for complete details.) Conflicts of Interest Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the Promoter's referral. Additionally, Promoters that refer business to more than one investment adviser could be financially incentivized to recommend advisers with more favorable compensation arrangements; comparable services and/or lower fees may be available through other firms. Accordingly, RMR requires its Promoters to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. RMR satisfies similar requirements when serving as a StoneCastle Cash Management, LLC Promoter. Besides our clients' fees and those disclosed herein, RMR does not receive additional economic benefits. Further details of mitigating conflicts of interest can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. A copy of RMR's Code of Ethics is available for free review to any client or prospective client upon request. Financial Information Balance Sheet RMR does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this Brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither RMR nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. RMR has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years RMR has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 37 

ITEM 1: COVER PAGE ____________________________________________________________________________________________________ RMR WEALTH BUILDERS, INC. Form ADV Part 2A - Firm Brochure (CRD # 169005 / SEC # 801-80404) 111 Grove Street Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 https://www.rmrwealth.com https://www.facebook.com/rmrwealth/ https://www.linkedin.com/company/rmr-wealth-builders-inc-/ March 31, 2025 This Form ADV Part 2A Disclosure Brochure (“Brochure”) provides information about the qualifications and business practices of RMR Wealth Builders, Inc., an investment advisory firm registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact us at 201.836.2460 or compliance@rmrwealth.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Registration does not imply any level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide information to determine whether to retain their services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about RMR Wealth Builders, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in RMR Wealth Builders, Inc. or CRD # 169005. Results will provide you with all firm disclosure brochures.) 1  ITEM 2: MATERIAL CHANGES ____________________________________________________________________________________________________ In this item, RMR Wealth Builders, Inc. ("RMR" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 29, 2024, changes have been made to the following Brochure sections: Item 4: Services, Fees & Compensation Assets Under Management As of December 31, 2024, RMR’s assets under continuous management total $2,199,565,329. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $ 2,139,602,190 $ 59,963,139 $ 2,199,565,329 Advisory Services This section was updated to reflect that Digital Asset services clients will maintain their assets with an available custodian offered through Securitize, a platform solution RMR engaged to deliver these services. Available custodians include but are not limited to, Gemini, Coinbase, Anchorage Digital, and the Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under these services. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred Qualified Custodians and custodial practices.) Item 12: Brokerage Practices This section was similarly updated to reflect Securitize as a platform solution. Full Brochure Availability At any time, we may amend this document to reflect changes in RMR’s business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at or the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "RMR Wealth Builders, Inc.” or CRD # 169005. The SEC's website also provides information about any RMR-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at 201.836.2460 or compliance@rmrwealth.com. 2  ITEM 3: TABLE OF CONTENTS ____________________________________________________________________________________________________ Item 1: Cover Page ................................................................................................................................................. 1 Item 2: Material Changes ........................................................................................................................................ 2 Item 3: Table of Contents ........................................................................................................................................ 3 Item 4: Advisory Business ....................................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................................... 17 Item 6: Performance-Based Fees & Side-By-Side Management .......................................................................... 24 Item 7: Types of Clients ........................................................................................................................................ 24 Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss ................. 24 Item 9: Disciplinary Information ............................................................................................................................. 40 Item 10: Other Financial Industry Activities & Affiliations ...................................................................................... 40 Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading ............................... 43 Item 12: Brokerage Practices ................................................................................................................................ 45 Item 13: Reviews of Accounts ............................................................................................................................... 49 Item 14: Client Referrals & Other Compensation .................................................................................................. 50 Item 15: Custody ................................................................................................................................................... 52 Item 16: Investment Discretion .............................................................................................................................. 53 Item 17: Voting Client Securities ........................................................................................................................... 54 Item 18: Financial Information ............................................................................................................................... 55 Item 19: Requirement for State Registered Advisers ............................................................................................ 55 Item 20: Additional Information ............................................................................................................................. 55 3  ITEM 4: ADVISORY BUSINESS ____________________________________________________________________________________________________ Overview RMR Wealth Builders, Inc. (hereafter “RMR” or the “Adviser”) is an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). The firm, headquartered at 111 Grove Street, Suite 203, Montclair, New Jersey, was founded in 1986 and incorporated in New Jersey. The Adviser also maintains additional office locations in AZ, CA, CT, FL, MA, NJ, NY, PA, RI, WY, & UT. For over 35 years, RMR, through its founding partners, has embraced the discipline and practice of aligning fiduciary standards and professional principles. The equal owners of the privately owned company are Ryan P. DeGrau (Chief Executive Officer), Douglas R. Roth (Co-Chairman), Joseph J. Russo (Co-Chairman) and Edward A. Majitenyi (President), who undertake all of the Adviser's significant strategic and administrative decisions. Their combined experience in the industry is over 100 years. (Please refer to each Principal’s Form ADV Part 2B Brochure Supplement for additional details on their formal education and business background.) RMR serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. As used in this brochure, the words "we," "our," or "us" refer to RMR and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to RMR’s Covered Persons and Supervised Personnel: the firm’s Officers and Directors (“Control Persons”), employees, and Investment Professionals - the Registered Investment Advisor Representatives (hereinafter “IARs”) who, as either employees or independent contractors of the firm, are licensed, supervised, and approved by RMR to provide investment advice or advisory services on behalf of the Adviser. RMR’s investment advisory services are designed to help our clients strive to attain their financial goals. RMR’s IARs perform a critical role in each client’s account's introduction, communication, and management. Clients are introduced to us by these experienced IARs, and each advisory relationship at RMR will be managed by one or more such IARs registered with the firm, who serve as the primary point of contact between the Adviser and client. IARs are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their IAR may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the Investment Professionals providing advisory services, clients should refer to their IAR’s Form ADV 2B Brochure Supplement, a separate disclosure document delivered to them, along with this Brochure, before or at the relationship inception. If the client did not receive these items, they should contact their IAR or RMR’s Chief Compliance Officer at 201.836.2460 for a copy of these essential and informative disclosure documents.) IARs will collect financial profile information from clients at the onset of the advisory relationship, make a reasonable effort to confirm or update the written client information no less than annually to keep the data current and recommend specific advisory services or programs deemed appropriate for each client’s financial circumstances, goals, objectives and situation. RMR offers access to a wide range of services and products to aid clients in the pursuit of their financial goals and a variety of investments from which to choose, including but not limited to mutual funds, exchange-traded funds ("ETFs"), variable annuities, business development companies ("BDCs"), real estate investment trusts ("REITs"), equities, fixed-income securities and Digital Assets. (Please refer to the description of each type of advisory service, as well as Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss, for additional information.) Non-Exclusive Relationship RMR supports and maintains an open environment where its Associates and IARs have access to the technology, tools, products, and support we believe are necessary to meet our goal of providing diverse and quality client services. Together with the assistance of our preferred Qualified Custodian(s), we aim to deliver a white-glove approach with respect to the resources, support, operations, technology, compliance, guidance, oversight, business development, investment selection, and platform 4  access we make available to our Investment Professionals and clients. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred Qualified Custodians and custodial practices.) RMR's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client may differ or conflict with that provided for the same security or investment for another. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss.) Other Professional Service Provider Recommendations If requested by the client, RMR may recommend the services of other professionals for implementation purposes. These professionals, who may be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Unless disclosed otherwise, RMR is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any RMR client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract, including fees and charges. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from RMR. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities RMR's advisory services depend on and rely upon the information received from our clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Investment Management Agreement contract (hereafter, the “Advisory Agreement,” or “Agreement”). Regardless of whether the client has provided discretionary authority or retains the right to make the final decision, it is the client’s responsibility to ensure their RMR IAR has all the information necessary to make recommendations and/or manage the account in the client's best interest. Clients will acknowledge and consent to this obligation to promptly notify RMR in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. Our IARs will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - RMR will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. RMR reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided. Description of Advisory Services RMR is a financial planning and investment management firm; it does not sell advisory securities on a commission basis. RMR's Investment Professionals emphasize personal client contact and interaction in providing the following individually tailored investment advice and advisory services: • Portfolio Management Services* Traditional Portfolio Management Services Program - IAR Client Investment Portfolio Non-Wrap Fee Program (hereafter “CIP Program”) - - Wrap Fee Portfolio Management Services Programs IAR Client Investment Portfolio Wrap Fee Program (hereafter “CIP Program”), or - 5  - Third-Party Manager Wrap Fee Program (hereafter “TPM Wrap Fee Program,” with RMR as investment adviser and the TPM as sub-adviser) • Annuity Management Services • Digital Asset Management Services • Financial Planning Services - Single Engagement - Ongoing Planning • Retirement Plan Services • Educational Seminars Services • Pontera Services (*Portfolio Management Services are offered to prospective and existing advisory clients with the option to make investment management services and transaction/commission costs available via a convenient single "Wrap Fee,” in conjunction with RMR as Wrap Fee Program Manager and Sponsor for the CIP and TPM Wrap Fee Programs. Please see RMR’s Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for complete details.) RMR’s advisory services are designed and aimed to complement each client's specific needs, as described within its written Advisory Agreement that discloses, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to us - either discretionary or non-discretionary. (Refer to Item 16: Investment Discretion for complete details on the kinds of discretionary authority clients may choose.) All advisory clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create this customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, and realistic and measurable goals are set based on the disclosed information and objectives to define those goals. According to the selected service(s), the client’s written Agreement will document the details of the advisory relationship and final advisory fee structure. Following the Agreement's provisions, fees are calculated via BlackDiamond, RMR’s online electronic trading and reporting system. According to the client’s Agreement, custody of client assets will be held by one of RMR’s chosen independent and separate Qualified Custodians who will take possession of the cash, securities, and other assets within the client's portfolio account. RMR delivers a report to the Qualified Custodian, and fees are then automatically directly debited from the client's account. RMR urges clients to review Qualified Custodial account statements received promptly upon receipt and compare them against the client’s executed Advisory Agreement, the appropriate benchmark for their portfolio, and any periodic portfolio report, data or statement they may request from us to ensure the accuracy of account transactions. (See Item 5: Fees & Compensation for further details on advisory services fees and Item 16: Investment Discretion for more information about account management styles.) IARs are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in RMR's advisory services, and clients may engage the Adviser for additional services at any time. Revisions to existing Advisory Agreements will be made following the terms of the existing Agreement. Following is a summary description of advisory services covered by this Brochure. Clients should consult with their IAR and the applicable Client Agreement and Disclosure Brochure fee schedules for additional details regarding each service. Wrap Fee Program services clients should refer to RMR’s Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for additional details. 6  Portfolio Management Services RMR’s portfolio management services, available as Traditional or Wrap Fee Program options, are personalized and designed to accommodate diverse investment philosophies and objectives while intending to complement each client's specific needs, as described in each Advisory Agreement. After completion of the initial client suitability profile (as previously detailed), if requested for use with the client’s investment management program, we will develop an Investment Policy Statement (“IPS”) for the portfolio using the client’s identified and approved investment parameters and other relevant information. We will then consider the information gathered and the approved IPS to recommend the portfolio management service believed to be in the client’s best interest. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their IAR. Clients are ultimately responsible for establishing their investment policy. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. After clients have received and reviewed their IAR’s recommendation(s) and have agreed to proceed, their IAR will work with them to implement the portfolio management services they approved. RMR does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from advisory accounts. According to the client’s Agreement, custody of client assets will be held by one of RMR’s chosen independent and separate Qualified Custodians who will take possession of the cash, securities, and other assets within the client's portfolio account. Fidelity Investments Institutional Services Company, Inc. (“Fidelity”), or Charles Schwab & Co., Inc. (“Charles Schwab”), both independent and separate registered Broker-Dealers, Members of The Financial Industry Regulatory Authority (“FINRA”) and The Securities Investor Protection Corporation (“SIPC”), will take possession of the cash, securities, and other assets within the client's portfolio account unless the client directs otherwise. While Fidelity and Charles Schwab are RMR’s preferred Qualified Custodians, RMR has relationships with various mutual fund custodians who may also be used if appropriate for the type of account opened. These relationships are disclosed to the client before any investment is made. (For example, certain 529 Plan accounts are held with American Funds. Contact us directly for a current list of additional Custodians used.) Digital Asset services clients will maintain their assets with an available custodian offered through Securitize, a platform solution RMR engaged to deliver these services. Available custodians include, but are not limited to, Gemini, Coinbase, Anchorage Digital, Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under these services. (See Item 12: Brokerage Practices and Item 15: Custody for additional information on our preferred Qualified Custodians and custodial practices.) RMR will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS as applicable to the type of account opened and according to the Adviser’s standard Fee Schedule as reflected herein and more fully explained in each client’s executed Agreement. Clients should consult their Agreement for complete details. (See Item 5: Fees & Compensation for additional information.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and IAR review their financial situation and portfolio through regular contact and annual meetings to determine fluctuations in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Model Portfolio Selections Under RMR’s portfolio management services option, when customizing an investment portfolio and if appropriate for the client’s situation, IARs can recommend one or more of RMR’s Model Portfolio Selections in which the IAR, as Investment Manager, will make appropriate changes to the allocation, investments, and holdings to align the Model Portfolio with each client’s stated investment criteria, written restrictions or other instructions received. 7  Clients can choose from the three Model Portfolio options that RMR manages and/or sponsors: 1. CIP Non-Wrap Fee Program, 2. CIP Wrap Fee Program, or 3. TPM Wrap Fee Program. A description of each Model Portfolio follows: IAR Client Investment Portfolio (“CIP”) Non-Wrap Fee Program - RMR’s CIP Program is offered to prospective and existing advisory clients following our customary interview and discussion process. Client investment management services and transaction costs will be assessed separately (i.e., in a “non-Wrap Fee” manner). IAR Client Investment Portfolio (“CIP”) Wrap Fee Program - RMR’s CIP Program is offered to prospective and existing advisory clients following our customary interview and discussion process. However, with this option, clients can elect to have their investment management services and transaction/commission costs made available via a convenient single "Wrap Fee.” (See “Wrap Fee Program” within this section and RMR’s Form ADV 2A Appendix I - Wrap Fee Program Brochure for additional details.) The Third-Party Manager (“TPM”) Wrap Fee Program - under RMR’s TPM Program, RMR retains the ability to select, recommend and provide access - after appropriate due diligence, to independent third-party manager advisers from the group of approved managers participating in its TPM Program service option, with whom RMR has entered a written agreement to make their sub-advisory services available, to guide and administer clients' accounts. The minimums for unaffiliated referred manager accounts generally range between $25,000 and $1,000,000. RMR will refer only those individuals or entities suitable for its TPM Program services, offered as Wrap Fee Accounts. RMR carefully selects the TPMs it deems suitable for this Program based on the client’s investment objectives and other specified account parameters. Typically, to enroll in this Program, Clients will sign an Agreement with RMR to select the TPM Program. Occasionally, an agreement between the client and the TPM is required. In such instances, the additional contract requirement will be explained to the client at the time of relationship inception. The client will receive copies of all material operative documentation and disclosures related to such arrangements detailing the nature of the relationship, compensation to RMR, and other general terms of the referred manager’s contract. RMR's role in the relationship is to verify that clients are appropriate to become TPM clients, determine if the potential referred client has assets to invest in, and confirm that they have a minimum understanding of financial investing. IARs will assist clients in completing their investor profile to aid the TPM in determining the appropriate account allocation strategy and help with any questions they may have about the manager or Program. Clients who elect to participate in the TPM Program are offered a selection of Model Portfolios with varying levels of risk using various investment strategies as described in each independent manager’s Form ADV. The type of contract will dictate specific account management, authority, and any limitations therein the client enters and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The client's investor profile will also determine any adjustments made. RMR and the referred manager will provide all investment advice to the client, bear fiduciary responsibility, and maintain responsibility for these items. TPM accounts will typically be placed at RMR’s Qualifying Custodian, who will take possession of the account's cash, securities, and other assets. The TPM is required to have the ability to access the account. While RMR will have discretion, it will not trade the client’s account but can decide to hire or fire the TPM from providing services. According to the referred manager's review parameters, client accounts will be reviewed within the context of the client's stated investment objectives and guidelines. The client’s IAR will monitor the TPM to ensure the TPM’s selections and account strategy maintain consistency with the client’s investment objectives. The TPM will also be replaced to align with portfolio parameters and objectives as necessary. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for communicating to their referred manager and RMR all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship promptly and as they occur. (Please refer to Item 15: Custody for additional details on custodial practices.) 8  RMR does not maintain the authority to accept any client on behalf of any referred manager, and referred managers are not responsible for accepting any prospective investor (and possible future client) referred to them by RMR. Each manager has the right to reject any referred client for any reason or no reason at all. It is the client’s responsibility to review and understand all applicable disclosure brochures before participating in any TPM Program. TPM Program advisers are subject to review by RMR's standards for inclusion and subject to future change from time to time. Clients should refer to their referred manager’s contract for complete details. Further, clients should be aware that the referred third-party managers we recommend receive their compensation directly from RMR according to our business arrangment with that particular TPM. Depending on the compensation arrangements, a conflict of interest can exist if we have a strategy benefit to recommend the services of the referred manager. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended managers. Annuity Management Services RMR offers annuity management services for a flat advisory fee not to exceed the guidelines reflected within the Adviser’s Disclosure Brochure and IRS Private Letter Ruling Number 202104001. To participate in this service, following our customary interview, discussion and analysis process, clients will execute RMR’s Annuity Management Services Agreement to appoint RMR as Adviser and their appropriately licensed IAR as Investment Manager to review, recommend and service their annuity contracts, including but not limited to Fixed, Variable, and Indexed annuities, and effect investment transactions believed to meet fiduciary, best interest, and impartial conduct standards for the annuity contract assets. With this service, clients will authorize and appoint RMR and its IAR as attorneys and agents-in-fact for their annuity contract assets and grant full discretionary authority to buy, sell, or otherwise effect investment transactions for the assets in their name and annuity contract. Clients will authorize RMR to instruct the Insurance Company product provider holding each of their annuity contracts of focus to liquidate investments and mail or wire specific monies to the client’s address of record - or another pre- designated bank account, according to the client’s written instructions. At the Insurance Company product provider’s request, clients may also be required to execute additional documentation to grant this discretionary authority to RMR and their Investment Professional. For annuity contracts recommended or serviced that are subject to security buy, sell, or hold recommendations, investment allocations will be selected based on the available investments specified in the annuity contract issued by the Insurance Company. RMR will not maintain custody of any of the assets associated with the client’s annuities; the client, at all times, will retain complete ownership rights to all assets held in their Insurance Company annuity contract. However, clients should be aware that recommendations related to annuity sub-account holdings of securities subject RMR and IARs to potential conflicts of interest, which can subject recommendations involving securities to require the pre-approval of any Broker-Dealer with which RMR and their IAR are licensed or affiliated in any capacity. It is the client’s responsibility to have received, read, and understand all additional and other applicable fees and charges separately disclosed by the Insurance Company, any insurance-related entity, or unrelated third-party entities that provide services and receive compensation arising from or related to the annuity contracts recommended by RMR, which fee schedules and charges are provided directly to the client by the Insurance Company before or upon delivery of the Annuity Contract and are in addition to, separate, and distinct from RMR’s advisory Fees. (For example, the client may incur other charges imposed by the Insurance Company, including, but not limited to, mortality and expense (“M&E”) fees, annuity contract rider charges, and other expenses disclosed in the client’s Annuity Contract). Digital Asset Management Services Digital Assets, a new technology that generally refers to an asset issued and/or transferred using distributed ledger or blockchain technology (including virtual/cryptocurrencies, “coins,” and “tokens”), is recommended to clients, as appropriate, through RMR’s Digital Asset management services option. Clients wishing to participate in this service will execute RMR’s standard Advisory Agreement and a separate and additional contract (an “Advisory Agreement Digital Investment Management Experience (“DIME”) Agreement) to authorize the activity, select RMR as their Investment Adviser, and designate their IAR as Investment Manager. 9  Due to the volatile nature of the digital assets market, clients are required to grant full discretionary authority within the Agreements to RMR and their IAR to execute the transactions deemed to be in their best interest. The authorization will also allow RMR to assist them with account registration, provide access to the Adviser’s Model Portfolio recommendations to construct and manage a customized Digital Assets investment portfolio and execute transactions, as necessary, to strive to achieve the client’s investment objectives while observing any noted account restrictions. Additionally, it is essential to note that while the digital assets market is open 24/7 for 365 days each year, RMR will be available to execute transactions between the hours of 9:30 a.m. - 4:30 p.m. Eastern time. Digital Assets management services accounts are held with an available custodian offered through Securitize, a platform solution RMR engaged to deliver these services. Available custodians include but are not limited to, Gemini, Coinbase, Anchorage Digital, and Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under the DIME Agreement. Digital Assets accounts offered by RMR may incur additional charges, expenses, and miscellaneous fees separate from the client's Annual Advisory and Administrative Fees. It is the client’s responsibility to have received, read, and understand all documents and any additional fees and charges disclosed by their account custodian, which are separate and distinct from the RMR’s advisory Fees. (See Item 5: Fees & Compensation and Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Financial Planning & Consultation Services RMR offers financial planning and advisory consulting services individually tailored to each client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. In offering these advisory services, RMR will make certain assumptions for interest and inflation rates and use past trends and market and economic performance. Past performance does not indicate future results, and we do not offer any guarantees or promises that clients' financial goals and objectives will be met. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Service scope, as determined between the client and IAR, is available via the following personalized options: 1. Single Engagement 2. Ongoing Planning A more detailed description of each service option follows: Single Engagement – Single Engagements for Financial Planning services are available to Clients as either a Comprehensive Financial Plan or an a la carte menu of Financial Planning services offered by RMR. The a la carte menu of services available includes, but is not limited to, Cash Flow Analysis, College Planning, Insurance and Needs Analysis Review, Investment Review, Tax Planning, and Estate Planning. A Comprehensive Financial Plan will include but not be limited to each planning service offered on the a la carte menu by RMR. Clients also have the option to build their package of services from the a la carte menu. The fee for providing services under a Single Engagement is based on the cost of the services selected from the menu of services available. RMR charges a flat fee for a Comprehensive Financial Plan. Ongoing Planning - beyond a single engagement, we provide our clients with the option of Ongoing Planning assistance. RMR has set a minimum asset on the platform threshold of $250,000, including ongoing planning services, which is negotiable. We also offer ongoing planning services for $1,500, charged annually, or $150/month, charged monthly. Fees for continuing planning are negotiable. To participate in any of the above options, clients will execute a Financial Planning & Consulting Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and fees due before RMR commences services. The final fee structure will be documented within the executed contract. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning and consulting services 10  can take approximately one week to six months. If services are not delivered within six months, any unearned revenue is pro- rated and refunded to the client following the terms and conditions of the executed Financial Planning Agreement. Financial plans are based on the client's financial situation when the plan is presented according to the financial information disclosed by the client to RMR at the time of Agreement execution. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Any subsequent financial planning services require the execution of a new Financial Planning & Consulting Agreement. Updating financial plans may be subject to an additional fee, which the client must approve in writing before further services commence. (See Item 5: Fees & Compensation for complete details.) As with all RMR advisory services, the client is expected to promptly notify us in writing of any material changes in assets, net worth, indebtedness, or planning objectives that RMR would not otherwise know. The client or their successor shall also promptly notify us in writing of (1) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (2) the occurrence of any other event that might affect the validity of their executed Agreement or RMR's authority thereunder. RMR reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning & Consulting Agreement for complete details. Financial planning services may be the only service provided to the client. Executing a Financial Planning & Consulting Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by RMR, or any insurance or other products or services provided by any RMR IAR as a result of any business activities in which they may participate outside their advisory activities with RMR. Neither RMR nor the client’s IAR will have discretionary investment authority when offering financial planning or consulting services. This service does not include implementing or monitoring IAR’s recommendations to the client. Further, written financial plans typically do not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Clients are not obligated to act on any RMR financial planning or consultation recommendations or implement any financial plan or recommendation through our firm. Clients may act on recommendations by placing securities transactions with any brokerage firm they choose. Retirement Plan Services As part of its portfolio management services, RMR also offers retirement plan services, wherein various levels of advisory and consulting services, investment due diligence, education, and other investment advisory services are provided, as described herein, to clients with employee benefit plans or other retirement accounts for a fee. These services are designed to assist Plan sponsors in meeting their management and fiduciary obligations to Plan Participants under the Employee Retirement Income Securities Act (“ERISA”). Under this service option, clients can participate in the following: 1. Plan Fiduciary Education Services 2. Participant Education Services 3. Service Provider Search Support 4. Plan Design Support Services 5. Plan Operation Support 6. 7. Investment Adviser Services - 3(21) (i.e., Investment Policy Statement, investment selection, performance monitoring and reporting and additional services as specified from time to time within the client’s Agreement.) Investment Manager - 3(38) (Investment Selection, performance monitoring and reporting, and additional services, if any, as specified from time to time within the client’s Agreement.) 11  RMR is considered a fiduciary under ERISA and regulations under the Internal Revenue Code of 1986. In this capacity, our status is as an investment advisor registered under the Investment Advisers Act of 1940 and a fiduciary under ERISA Part 4 Title 1. In performing these services, RMR acts either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA or as a discretionary fiduciary of the Plan defined in Section 3(38) under ERISA. RMR is not subject to any disqualification under Section 411 of ERISA. In connection with such accounts and pursuant to adopted regulations of the U.S. Department of Labor (“DOL”), we are required to provide the plan’s Responsible Plan Fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) and clients with a written statement of the services we provide to the Plan, the compensation we receive, any conflicts of interests present, our status as an ERISA fiduciary, and the following notice: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. How we are compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: follow policies and procedures designed to ensure that we provide advice that is in your best interest, 1. meet a professional standard of care when making investment recommendations (give prudent advice), 2. never put our financial interests ahead of yours when making recommendations (give loyal advice), 3. avoid misleading statements about conflicts of interest, fees, and investments, 4. 5. charge no more than is reasonable for our services, and 6. give you basic information about conflicts of interest. RMR benefits financially from the rollover of a client’s assets from a retirement account to an account that we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Our policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are not obligated to have their retirement assets managed by RMR. If a client or a prospective client receives a recommendation to leave their plan assets with their old employer, RMR will receive no compensation. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, RMR will have discretionary account Plan Fiduciaries evidence of their authority to retain our advisory services and appoint us as an "Investment Manager" within the meaning of Section 3(38) of ERISA for those Plan assets that comprise the client's account. The Plan Fiduciary will confirm that RMR's Agreement services are consistent with Plan documents and furnish true and complete copies of all Plan governing documents. The Plan Fiduciary will provide us with a copy of all relevant documents requested, confirm, and agree that their selected advisory program is consistent with those documents, and will notify us, promptly in writing, of any changes to any of the Plan's investment policies, guidelines, restrictions, or other related documents regarding Plan investments. If the assets in the account constitute only a part of the Plan’s assets, the Plan Fiduciary will provide us with documentation of all Plan investment guidelines or policies that affect the account. Under ERISA requirements, the client will acknowledge that RMR has no responsibility for the overall diversification of all the Plan's investments and no duty, accountability, or liability for any partial Plan asset not under RMR’s advisement. The compliance of any recommendation or investment RMR’s IARs make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. RMR is not responsible or liable for Plan administration or the performance of any other duties not expressly outlined in the Agreement. Further, the client must obtain and maintain - at their own expense, any insurance or bonds they deem necessary 12  to cover themselves and any of their affiliates, officers, directors, employees, and agents concerning RMR’s Agreement. Plan fiduciaries will promptly provide appropriate documents evidencing such coverage upon request. If ERISA or other applicable law requires bonding for the account's assets, RMR will ensure bonding is in place to satisfy the obligation to cover RMR and all Associates whose inclusion is expected by law. ERISA & Retirement Plans Special Disclosures In this Brochure’s Section 5: Fees & Expenses, RMR has disclosed potential conflicts of interest, such as receiving additional compensation from third parties (e.g., 12b-1 fees) for marketing, recordkeeping, or other services connected with certain investments. RMR has adopted policies and procedures designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. (For example, RMR has taken several steps to address the potential conflict of interest of IARs, who receive compensation for services provided to ERISA Plans. First, an IAR negotiates the compensation with ERISA Plan sponsors or participants (“ERISA clients”), and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate.) As a covered service provider to ERISA plans, RMR will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). RMR does not allow IARs to provide advice or manage ERISA client assets if conflicts of interest exist that RMR believes are prohibited by ERISA. Thus, RMR’s practice is to disclose (1) direct compensation received from ERISA clients, (2) indirect compensation received from third parties, and (3) transaction-based compensation (i.e., commissions) or other similar compensation shared with related parties servicing ERISA plans. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending an ERISA client’s advisory service Agreement. RMR also provides participant and fiduciary education, vendor selection, reporting and technology services support, and other non-investment-related assistance for ERISA, retirement, and other qualified account clients. Retirement Account Rollover Considerations Individual participants in corporate Plans advised by RMR who are retiring or changing jobs can request that RMR provide additional educational information concerning tax-free transfer options and details on the benefits of keeping assets in the Plan as long as they remain eligible. RMR will not solicit Plan Participants to retire or change jobs. For Plan Participants who decide to leave the Plan of their own accord due to retirement or change to a new employer, we can be separately engaged to provide recommendations on the advisability of taking retirement Plan distributions. Any Plan Participant services that include discussions about individual distributions or how to invest distribution proceeds will be performed separately with the Plan Participant. In determining whether to make a retirement account rollover to RMR, Plan Participants and clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company Plans. Further, current employees can sometimes move assets from their company Plan before retiring or changing jobs. RMR will consider various factors before recommending retirement plan rollovers, including the investment options available in the Plan versus others available, the rollover options available, each individual's age, personal circumstances, investment options, Plan fees and expenses versus those of alternative account types, services, conflicts of interest, penalties, protections from creditors and legal judgments, required minimum distributions and employer stock tax consequences, the services and responsiveness of the Plan's Investment Professionals versus those of RMR, and employer stock tax consequences (if any), among others. To the extent the following options are available, clients should carefully consider the costs and benefits of the following: • leaving the funds in the employer's/former employer's Plan, • moving the funds to a new employer's retirement Plan, • cashing out and taking a taxable distribution from the Plan, and • rolling the funds into an IRA rollover account. 13  Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for RMR to manage are encouraged to speak with their CPA or tax attorney before taking any action or changing. The following is also offered for your consideration before making a change: 1. Determine whether the investment options in your employer's retirement Plan address your needs or whether you might wish to consider other investment types: - - Employer retirement Plans generally have a more limited investment menu than IRAs. Employer retirement Plans may have unique investment options, such as employer securities or previously closed funds, unavailable to the public. 2. Consider Plan fees & expenses - your current Plan may have lower fees than RMR’s. - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement Plan and how the share class costs compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. RMR’s strategy may have a higher risk than your Plan's option(s). 4. Your current Plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. - Generally, federal law protects assets in qualified Plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so consult an attorney about protecting retirement Plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed anytime; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your Plan, you may be able to liquidate those shares at a lower capital gains tax rate. 9. 10. Your Plan may allow you to hire RMR as the manager and keep the assets in the Plan name. Educational Seminars Services RMR provides complimentary investment educational seminars and workshop services and can speak at community events and conferences on various investment topics on an "as-announced" basis for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content will vary depending upon the attendees' needs and are purely educational – they do not involve selling any investment products. The information presented will not be based on any individual’s needs. RMR does not provide personalized investment advice to attendees during such events. RMR will only provide investment advice if engaged independently and only where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes and do not deliver specific accounting, investment, legal, tax, or professional advice. Attendees have no obligation to schedule a consultation, purchase services from RMR, or become clients. Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access plan participants' accounts where we do not have custody but can provide advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. RMR and its IARs will review these accounts at least annually and determine if any changes to the allocation are necessary. Available investment options are considered each time the account is reviewed. RMR and its IARs are not affiliated with Pontera in any way, and we do not receive any compensation from Pontera for using their platform. Clients who engage RMR and its IARs for this service will connect their account to the Pontera platform using a link provided to the client. Once the account is connected to Pontera, RMR and its IARs will have access to view account information, including but not limited to the allocation and available investment options. (See Item 5: Fees & Compensation.) 14  This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to provide advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans that RMR and its IARs are the advisors of record. Wrap Fee Program Services As indicated within the preceding “Portfolio Management Services Model Portfolio Selections” section, RMR provides investment and portfolio management services via a Wrap Fee Program, a transaction fee rebate program that differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Clients will choose from RMR’s CIP Program or TPM Program. The assets in each Program are regularly monitored, and investment strategy purchases and sales transactions are based on the client’s specific needs and investment goals. Before participating in either of RMR’s Wrap Fee Program options, clients will be required to enter into a separate written Wrap Fee Program Agreement that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, and fees to be paid. Under our management, the annual “Wrap-Fee" for each Program participation depends upon the market value of the client’s assets. Clients will invest in the Wrap Fee Program by establishing one or more accounts (the "separately managed account" or "accounts") with the Wrap Fee Program’s Qualified Custodian, each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Wrap Fee Program's cost-effectiveness to the client, and RMR will receive a portion of the single Wrap Fee clients pay to participate in our Wrap Fee Program services. The SEC rules require that a Wrap Fee Program Brochure be provided to clients before or when entering a Wrap Fee Program Agreement. This Brochure provides clients with important information about the Wrap Fee Program, including further information about the services and fees participating clients will pay. The overall costs clients will incur if they participate in one of our Wrap Fee Programs can be higher or lower than they could incur by separately purchasing the types of securities available in our Wrap Fee Program. (Please refer to the adviser's Form ADV Part 2A - Appendix I, the Program Brochure, for a complete description of the Wrap Fee Program, fees, and services.) Clients should be aware that a conflict of interest exists whenever RMR recommends participating in its Wrap Fee Program services because RMR and its IARs could be financially incentivized to recommend services as non-Wrap Fee services. RMR could have a disincentive to purchase or sell securities in the client’s account because we pay the transaction costs associated with trades directed at the custodian. (For more information, see Item 5: Fees & Compensation and RMR’s Form ADV Part 2A Appendix 1 – Wrap Fee Program Brochure.) Client Tailored Services & Imposed Restrictions Client Tailored Services RMR offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at RMR's discretion, as detailed herein and defined in each client's written Agreement. (For more information, see Item 5: Fees & Compensation.) Client Imposed Restrictions Portfolio management services clients who engage RMR on a discretionary basis may, at any time, impose restrictions on RMR's discretionary authority. Clients may impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to RMR in writing. Clients may also amend/change such limitations by once again providing written instructions. Reasonable efforts are used to comply with client investment guidelines, including any client's reasonable limits by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client imposed restrictions within their account, and variations could result in positive or negative performance differences for the account compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. 15  Upon receiving a client's written restrictions, RMR will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the possible outcomes of the imposed restriction. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, RMR reserves the right to end the client relationship. In no event and regardless of the advisory service provided is RMR obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Clients may restrict TPM Program accounts according to the referred manager’s Wrap Fee Program Agreement. Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. RMR will generally provide investment advice and money management for a varied range of product offerings and securities including, but not limited to, business development companies, commercial paper, certificates of deposits, derivatives, digital assets, equities, exchange-traded funds (“ETFs”) exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships in real estate, oil, and gas, load and no-load mutual funds, options, real estate investment trusts, private placements, bonds (treasury inflation protected/inflation-linked), unit investment trusts, warrants, and non-U.S. securities. RMR typically avoids market timing but will increase cash holdings when necessary. When recommending investments in mutual funds, it is RMR’s policy to consider all available share classes and select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically have a lower cost than other share classes. Generally, institutional class shares do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost. Although RMR provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. (For additional information, see Item 8: Methods Of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Conflicts of Interest Clients should be aware that the specific advisory program selected by the client and the compensation to RMR and their IAR will differ according to the chosen advisory program. The compensation we received can be greater than the amounts otherwise received had the client participated in another program or paid separately for investment advice, brokerage or other relevant services. Due to the differences in fee schedules among the various advisory programs and services offered by RMR and the client’s IAR, a conflict of interest exists when there is a financial incentive to recommend a particular program or service over others. Factors that bear upon the cost of a specific advisory program in relation to the price of the same services purchased separately include but are not limited to, the type and size of the account, the historical and expected size or number of trades for the account, and the number and range of supplementary advisory and client-related services provided to the account. Clients are under no obligation to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through RMR or any recommended third party. The client may act on recommendations received by placing their business and securities transactions with any brokerage of their choice. RMR does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how RMR mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). RMR's Code is available for review free of charge to any client or prospective client upon request. If you have questions regarding this Brochure’s content or any RMR Agreement, document, statement, or other firm material received from us or do not understand an explanation, please ask your IAR or contact our Compliance Department at 201-836- 2460 for assistance. 16  Assets Under Management As of December 31, 2024, RMR’s assets under continuous management total $2,199,565,329. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $ 2,139,602,190 $ 59,963,139 $ 2,199,565,329 ITEM 5: FEES & COMPENSATION ____________________________________________________________________________________________________ Advisory Services Fees & Compensation RMR’s advisory clients agree to pay an asset-based advisory fee calculated according to the schedules indicated herein and within RMR’s Form ADV 2A Appendix 1 - Wrap Fee Program Brochure for those services offered through the Adviser’s Wrap Fee Program. Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisors must provide written disclosure statements to their clients. A copy of RMR's Form ADV Part 2A Brochure, Form ADV 2A - Appendix 1 Wrap Fee Program Brochure, and Form ADV Part 3 (the "Client Relationship Summary" or "Form CRS") disclosure brochures, as applicable for the type of account opened, and the Part 2B Brochure Supplement for the IAR assigned to the client’s account will be provided to clients before or upon execution of an RMR Advisory Agreement. Unless a client has received these important disclosure documents at least 48 hours before signing their Advisory Agreement, clients may terminate their Agreement with RMR within five (5) business days of Agreement execution without incurring any advisory fees. Advisers offering impersonal investment advice paid less than $500 annually do not have to adhere to the client Brochure Rule. Fee Negotiation Availability Under certain circumstances, all advisory fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by RMR. The Adviser, in its sole discretion, may charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as pre-existing client relationships, the number of related investment accounts, inception date, total account assets under management, expected additional assets, anticipated future earning capacity, account composition, and client negotiations, among others. At RMR’s discretion, certain accounts for members of a client's family or otherwise may be assessed fees based on the total balance of all accounts. While RMR seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients may pay higher (more) or lower fees (less) than other clients for services than if they had contracted directly with another provider. According to the selected advisory services, the final fee structures will be reflected in each client's written Agreement. Lower fees for comparable services can sometimes be available from other sources. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay an RMR advisory fee more than six months in advance, in excess of $1,200. Legacy Fees Since RMR began providing investment management services, it has had other legacy advisory fee schedules, which can differ from those described herein. As new advisory fee schedules are implemented, they apply only to new clients, and existing clients' fees are not affected. Therefore, some existing clients pay different advisory fees than those shown herein. The following describes how RMR is compensated for each of its advisory services: 17  Advisory Services Fees Annual Account Administration Fee Effective April 1, 2024, RMR increased its annual Administrative Fees for accounts billed directly from $52 to $80 for non-Wrap- Fee and Wrap Fee investment advisory fee-based services Programs. In return for such fees, which are prorated daily and charged quarterly based on the number of days in the quarter x 365 (same as below), they are assessed to RMR fee-based Program clients according to their executed Advisory Agreement. Regardless of the number of assets under management and as illustrated in the Advisory Agreement, clients receive access and use of the BlackDiamond Wealth Platform, an online trading and reporting system that provides them with direct login and access to their portfolio information, wherein they – either independently or with the assistance of a Dedicated Service Team Member, can review their holdings, obtain account summaries, reports, education and training materials and other forms of client communications and support intended to aid clients in monitoring their investments. Portfolio Management Services Fees RMR’s portfolio management services fees generally use a tiered or “blended” annual fee calculation. Based on the account's value at the end of the last billing period, the fee schedule identifies specific portions of the account value to be charged at different rates. The account's total value is compared against this schedule, and based on the account size, the separate fee rates are blended to determine the total quarterly account fee for that period according to the following schedule: Annual Advisory Fee Schedule Assets Under Management (“AUM”) First $0 - $250,000 Next $250,001 - $500,000 Next $500,001 - $1,000,000 Next $1,000,001 - $2,500,000 Next $2,500,001 - $5,000,000 Next $5,000,001 + Maximum Annual Fee 2.65% 2.50% 2.00% 1.75% 1.50% 1.25% *Lower fees for comparable services can sometimes be available from other sources. The annual account management fee is billed quarterly based on the number of days in the quarter divided by 365 multiplied by the AUM fee. The first quarterly fee will be prorated based on the number of billing days in the initial quarter. Subsequent fees will not be prorated unless additional funds or securities are added to the account or the Client Agreement is terminated. Fees are negotiable based on account value and type but will not exceed the maximum Annual Fee indicated above. The final fee schedule is documented in the client’s executed Agreement. Additional funds and/or securities deposits during a particular calendar quarter will be subject to billing on a pro-rata basis. Clients who withdraw funds from a managed account during a billing period are not generally entitled to a pro-rata refund unless they terminate their Client Agreement or it is otherwise stated in the Client Agreement. Portfolio Management Services advisory management fees are as follows: IAR Client Investment Portfolio (“CIP”) Non-Wrap Fee Program - clients who select RMR’s Traditional Portfolio Management Services Program will pay an ongoing asset management services fee based on the above Annual Advisory Fee Schedule. The maximum annual account management fee charged in any RMR Managed Account Program is 2.65%. IAR Client Investment Portfolio Wrap Fee Program Services Fees - clients who elect to receive asset management services through RMR’s CIP Program will pay for the services according to our Form ADV Part 2A Appendix 1 -Wrap Fee Program Brochure with an ongoing asset management fee based on a schedule of percentage of assets under management (“AUM”), according to the above Annual Advisory Fee Schedule. The maximum annual account management fee charged in any RMR Managed Account Program is 2.65%. Third-Party Manager Wrap Fee Program Services Fees - clients participating in RMR’s TPM Program services will pay Program fees according to our Form ADV Part 2A Appendix 1 -Wrap Fee Program Brochure, based on a percentage 18  of assets managed within the TPM Program. Clients are informed of the amount to be received by RMR via the Form ADV disclosure documents, Agreement, and Fee Disclosure Statement they receive/accept at the time of relationship inception. The fee arrangement is also detailed within each referred manager's Form ADV Part 2A disclosure brochure and the separate manager’s contract the client enters with the manager. Fees can be structured in one of the following ways and are disclosed in each client's Agreement:  RMR receives a split of management fees with the TPM,  a fixed flat percentage fee on total assets in the account,  a tiered fee schedule calculated by applying different rates to different levels of assets, or  a linear fee schedule where a breakpoint percentage fee is assessed to the total account assets. The first pay period's fees will be calculated pro rata at the account's inception. The fee is calculated via Black Diamond and debited from the custodian. While RMR generally remits payment to the TPM, the TPM will sometimes directly bill the client’s account, resulting in the client seeing two line items for the single fee they pay for this service. Fees will be paid to referred managers according to Agreement provisions. RMR’s fees are charged in addition to each referred third-party manager's fee. RMR’s portion of the total management fee represents the maximum fee we may earn under the TPM Program and will not exceed the limits imposed by any regulatory agency. It is important to note that the client's TPM can charge fees in addition to those reflected in RMR’s Annual Advisory Fee Schedule and will typically reserve the right to reduce or waive the fee at their sole discretion. Added fees and expenses can also be charged by investments within the portfolio's model(s). Each month, clients participating in the TPM Program will receive either a written statement or electronic notice via established secure online access from their TPM custodian, alerting them to statement availability and detailing all account activity. The client is encouraged to promptly review their account statement(s) upon receipt to verify the accuracy of all information. Fee payment in full is expected for fees upon invoice presentation. Clients should refer to their respective RMR Advisory Agreement and the referred manager’s contract for complete details on services, costs, and fees. Note: RMR may change its standard Annual Advisory Fee Schedule at any time by providing the client with 30 days advance written notice. Annuity Management Services Fees Annuity management services fees are reflected herein and as more fully set forth in “Appendix A” of the Client’s Annuity Management Services Agreement. Fees paid to the Insurance Company, any related entity, or an unrelated third-party entity providing services to the Client will be paid directly from the Client to the Insurance Company; RMR is not responsible for such fees. The client will authorize the fees for annuity management services according to “Appendix A” of the executed Annuity Management Services Agreement and understands and will acknowledge their responsibility to verify the accuracy of the fee calculation. If the Client discovers a discrepancy with any of the fees calculated pursuant to the Agreement, it is their responsibility to notify RMR and their Insurance Company in writing promptly. The fees charged to the client in connection with the services provided under the Agreement are billed in arrears. If an Agreement is terminated in the middle of a billing period, clients will not pay a prorated fee to RMR for services provided during the billing period in which the Agreement terminates. RMR works with multiple annuity providers, and as a result, the calculation methods and forms of payment for fees charged can vary depending on the available calculation methods and forms of payment with the annuity provider used in each Client’s circumstances. These calculation methods and forms of payment will be fully described in “Appendix A” of the Client’s Annuity Management Services Agreement. In cases where an Annuity Contract does not have a sufficient cash balance to cover such payment on the date due, RMR may sell additional securities in the Annuity Contract without client notice to generate sufficient funds to pay such fees. As fees are negotiable, this will result in accounts of similar size and make-up being charged different Management Fees. 19  In addition to the fees described herein and in “Appendix A” of this client’s Annuity Management Services Agreement, the client may incur other charges imposed by the insurance company, including, but not limited to, mortality and expense (“M&E”) fees, annuity contract rider expenses, and other expenses disclosed in client’s Annuity Contract. Digital Asset Management Services Fees Digital asset management services clients will pay a negotiated annual advisory fee based on their investment account’s assets under management, as reported by their Qualified Custodian. Digital Investment Management Experience (“DIME”) services fees accrue and are prorated daily, debited quarterly in arrears, and paid to RMR directly from the client’s custodial account upon the client’s written permission. Accrual occurs and is calculated daily at 4:00 p.m. EST as follows: Client Account AUM x Fee Rate by 365 days. ÷ With this service, clients will also incur fees for transaction execution and custodial services provided for their Digital Assets, fees from Equity Trust for related services, and additional fees, costs and expenses from other third parties in connection with the use of the asset management platform, including, but not limited to, electronic fund fees, exchange fees, intermediary fees, network fees, transaction fees, and wire transfer charges, among others. These fees are separate and distinct from - and in addition to, RMR’s Digital Asset management services fees. If the client’s Gemini Account does not hold sufficient funds to pay the applicable fees, clients will authorize RMR to enter into transactions on their behalf for the sale of Digital Assets to generate sufficient currency (USD) to remit the fees incurred and due on their account timely. Financial Planning & Consulting Services Fees Clients can engage RMR for financial planning and advisory consulting services through a Single Engagement or Ongoing Planning. Fees for these services are outlined below: Single Engagements for Financial Planning services are available to Clients as either a Comprehensive Financial Plan or an a la carte menu of Financial Planning services offered by RMR. A Comprehensive Financial Plan will include but not be limited to each planning service offered on the a la carte menu by RMR. • Comprehensive Financial Plan: The fee for a Comprehensive Financial Plan is charged as a flat fee • Build Your Own Package: Each planning service on the a la carte menu is charged a flat fee. This service will be a flat fee determined by the planning services selected. Ongoing Planning for Financial Planning services are available beyond a single engagement to Clients who engage RMR for Investment Management Services. • RMR has set a minimum asset on the Platform threshold of $250,000, including ongoing planning services, which is negotiable. We also offer ongoing planning services for $1,500, charged annually, or $150/month, charged monthly. Fees of continuing planning are also negotiable. Clients will pay a retainer not to exceed 50% of the total fee upon Agreement execution. The remaining balance is due within thirty (30) days of project completion and/or delivery of the financial plan. If the Agreement is terminated before project completion, RMR will refund any unearned fees on a prorated basis. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Any subsequent financial planning services for Clients who do not fall under the Ongoing Planning service above will be required to execute a new Financial Planning & Consulting Agreement, subject to RMR’s then-current fee schedule, which the client must approve in writing and before any work commences. Retirement Plan Services Fees RMR retirement plan services are available on a client account assets under management basis, as a flat, one-time, and/or ongoing fee basis, or at an hourly rate for one-time projects or ongoing work. The scope of the services, fees and terms are negotiated on a case-by-case basis with each client and vary depending on the size, complexity and needs. Ranges, in general, are as follows: 20  • AUM Fees - are charged according to RMR’s standard Annual Advisory Fee Schedule and as indicated in the client’s executed advisory Agreement, • Flat, One-Time & Ongoing Fees – are determined according to the client’s scope of work, and • Hourly Fees – will not exceed $500/hr. Fees outside the above ranges are subject to RMR's review and approval. Upon termination, clients will receive a pro-rated refund of any pre-paid advisory fees not yet earned by the Adviser. Pontera Services Fees RMR’s Pontera Services fees are asset-based fees charged as a flat percentage of the total assets in the client account. Fees are calculated based on the number of days in the calendar quarter for services to the client. The Fee charged to the client for the initial period is prorated daily and charged in advance based on the number of days remaining in the billing cycle after the billing start date. For all future periods, the fee will be prorated daily and charged quarterly, in advance, based on the number of days in the billing period using the balance of the client’s account at the end of the prior billing period. Pontera charges RMR a percentage fee based on the total assets managed using Pontera’s platform. The initial fee charged by Pontera to RMR is prorated daily and charged in arrears at the end of the billing period. As a result, RMR reserves the right to adjust the initial fee to cover the fee charged by Pontera to us for the initial billing period. Wrap Fee Program Services Fees RMR’s Wrap Fee Program fees are asset-based fees that will include most transaction costs and fees to a Broker-Dealer with custody of these assets and, therefore, are higher than a typical asset-based advisory fee. RMR will receive a portion of the Wrap Fee for our services. Managed account clients will pay these fees quarterly, in advance, based on the specific program selected. For complete details, clients should refer to RMR’s Form ADV Part 2A – Appendix 1 Wrap Fee Program Brochure and any respective Wrap Fee Program Agreements. Educational Seminars & Workshop Fees Educational seminars and workshops are complimentary – they are provided free of charge. Fees & Fee Billing Clients have two options to pay their RMR advisory fees, either via (1) direct debit or (2) billed, and will select their chosen method by indicating their preference in the Agreement they execute with RMR. As authorized by the client, RMR or its administrative agent typically requests that for discretionary accounts, the Qualified Custodian directly debits account management fees from the client’s account automatically. For non-discretionary accounts, the client will be contacted to provide consent. Clients may also be billed fees by directly writing a check to RMR or its administrative agent for the fee amount. For all advisory services, fee payment in full is expected promptly upon invoice presentation. The exact process for fee payment is as follows: Directly Debited Fees - for directly debited fees, clients will authorize RMR in writing to directly deduct advisory fees due from their custodial account and provide the custodian with authorization to deduct such fees and instructions to remit them straight to RMR.   For this type of fee payment, when fees are due, RMR will provide the Qualified Custodian with an advisory fee calculation based on the terms of the client's Agreement and direct the Qualified Custodian to remit the client a statement of the activity to the client's address of record - or another authorized address, as otherwise designated in writing by the client, reflecting the fee amounts paid to RMR for the quarter in question. If paid directly, the Qualified Custodian will automatically deduct the client's advisory fees due, as instructed by RMR, at the end of each calendar quarter, regardless of the market performance of the portfolio during the quarter just ended. The account management fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings, according to the discretionary authority granted by the client to RMR, IAR and referred third-party manager, as applicable for the type of account established. 21  When authorized by the client to debit advisory fees from client accounts, RMR is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct the fees. RMR urges clients to compare their custodial account statements with any periodic portfolio report or date they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us may vary based on accounting procedures, reporting dates, or valuation methodologies. If a client is not receiving statements directly from their custodian, in addition to advising their IAR promptly, RMR also recommends contacting their custodian directly. Billed Fees - clients who wish to be directly billed by RMR for their advisory services fees will authorize this payment in writing on their advisory services contract and request that RMR invoice them directly quarterly for any fees due. Clients will then make their fee payments to RMR by separate check or credit card, and under no circumstance will any RMR advisory fees be deducted from amounts they hold within their custodial account(s). Other Fees & Expenses With the exception of the securities execution transaction costs and commissions associated with RMR’s Wrap Fee Program services paid from the asset management fee agreed to in the client’s Agreement and compensation for the sale of securities or other investment products, including asset-based sales charges or service fees as disclosed herein or other charges that can be required by law, the fees clients pay for RMR’s investment advisory services are separate and distinct from administrative fees, annual custody fees, brokerage costs, commissions, debit and credit interest, default charges, direct investments (such as limited partnerships, and limited liability companies), margin and trade extensions, mailgrams, money market fees, physical reorganization costs, renege assessments, legal return/bounced check/stop payment/transfer and ship or safekeeping fees, transfer and sub-transfer agent and distributor fees, and other miscellaneous charges when purchasing or selling securities or for products and services customarily assessed by product manufacturers (which include, but are not limited to, insurance companies, mutual or exchange-traded funds, real estate, oil and gas, and other providers of direct investments, as described in each product sponsors product prospectus to their shareholders) and the client’s account Broker-Dealers/Qualified Custodians. RMR does not share in any portion of such additional fees or expenses imposed. Additional details on some of the above-mentioned and other customary fees and expenses clients may pay to other parties in connection with their portfolio accounts and investments follow: Margin Interest - is the interest the client pays to a Broker-Dealer/Qualified Custodian on loans made to finance the purchase or sale of securities or securities in the client’s investment account. The interest rate charged and other information about the loan, including how interest is calculated and other disclosures of risk and liability, will be described to the client in the margin agreement the client executes with their Broker-Dealer/Qualified Custodian. Fees for advice and execution on these securities are based on the total asset value of the account, which includes the value of the securities purchased on margin. While a negative amount may show on a client's statement for the margined security due to a lower net market value, the fee amount is based on the absolute market value. This could create a conflict of interest where RMR may have the incentive to encourage using margin to create a higher market value and, therefore, receive a higher fee. Using margin may also result in interest charges and all other costs and expenses associated with the security involved. Securities Execution Transaction Fees - fees charged by a clearing Broker-Dealer to an introducing Broker-Dealer and passed through to the client for payment relating to the purchase and sale of securities in their investment account. A schedule of charges relating to the purchase and sales by type of security is provided to the client by each account’s Broker-Dealer/Qualified Custodian of record, as will any changes or updates to such fee schedules. As noted previously, third-party managers responsible for managing a portion of or all of a client’s account can also receive a portion of the advisory fees clients pay RMR, depending on the specific third-party manager disclosure and agreement. Clients should be aware that sharing in a portion of any fee or transaction charges presents a potential conflict of interest because IARs will have a greater incentive to recommend - or make investment decisions regarding investments that provide additional compensation to RMR and your IAR. Any mutual fund share class that pays 12b-1 fees received by RMR will be credited back to the client. Further information regarding fees and charges assessed by a mutual fund is available in the appropriate prospectus. Revenue Sharing & Other Considerations RMR recommends a broad selection of investment products and mutual funds. Some of the investment products and mutual funds we endorse have marketing and distribution agreements with third parties designed to help facilitate the distribution of 22  such investment products. As a result of these arrangements, RMR’s IARs can attend educational sessions, seminars, due diligence presentations, and conferences that provide education and training on various industry topics, including, but not limited to, securities markets, regulations, and company-specific products. Clients should be aware that different products charge different commissions, and our IARs do not receive a greater or lesser percentage of the commission for sales of these products. Regardless, the marketing and educational activities paid for by a product sponsor could lead to a potential conflict where IARs focus more on such offerings. Clients are under no obligation, contractually or otherwise, to purchase insurance or securities products through any person affiliated with RMR. Clients can purchase recommended investment products through other brokers or agents not affiliated with RMR. Further, clients are encouraged to consider and speak to their IAR, tax, and other Investment Professionals regarding the following before transferring securities into an account with our firm: • whether a commission was previously or will be paid pursuant to a previously disclosed deferred compensation agreement, if you want the security to be managed as part of an account subject to an advisory fee, and if you prefer to hold the security in an unmanaged brokerage account not subject to an advisory fee. • • To fully understand the total account costs they will pay, the client’s responsibility is to read and understand RMR’s advisory Agreement and those of any referred third-party manager and the prospectus, disclosures, and legal documentation provided that explains the difference in the fees, costs, expenses, commissions and other matters for securities purchased or sold in their investment account as well as the disclosures made regarding all fees charged by our firm, their Broker-Dealer/Qualified Custodian, and others, as applicable for the type of account established. Clients are again encouraged to contact their IAR, tax, and other Investment Professionals to help resolve any questions. (See Item 12: Brokerage Practices for more information on these practices.) Account Additions, Withdrawals, Terminations & Assignments Clients may make additions to their RMR accounts in cash or securities at any time. RMR reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If RMR liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level such as contingent deferred sales charges, and tax ramifications. Clients may make withdrawals from their RMR accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Additions or withdrawals within a client account over $10,000 monthly will incur additional prorated fees or a prorated refund. Generally, terminations can be made to an RMR services Agreement by written notice without penalty within five (5) business days after the Agreement execution date. After that, the Advisory Agreements between RMR and the client will continue in effect until either party terminates the Agreement following the terms of the Agreement, which state that Agreements may be terminated by either party upon at least thirty (30) days written notice to the other party. A "business day" shall be any day when the New York Stock Exchange is open for trading. Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's obligation to pay management and other fees due, pro-rated through the termination date. • • • For RMR's portfolio management services, RMR will refund any unearned fees resulting from client advance payments to the Adviser. Likewise, if RMR bills the client in arrears for services that have already been rendered, RMR will prorate those fees up to the termination date of the Client Agreement. Specifically, at termination, after the prior full billing quarter, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing quarter before termination. Any pre-paid, unearned fees will be promptly refunded to the client pro-rata based on the termination date. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of written notice of the client's death. 23  The disability or incompetency of the client will not terminate or change the terms of this Agreement; however, the client’s executor, guardian, attorney-in-fact, or other authorized representative may terminate this Agreement by giving written notice to RMR. Before termination, all directions given or actions taken or omitted by RMR before the effective Agreement termination shall be binding upon the client and any successor or legal representative. The Adviser will no longer be entitled to receive fees from the termination date and has no obligation to recommend or act concerning an account's securities, cash, or other investments on the terminated Agreement. RMR shall have the right to amend the annuity management services fee schedule reflected in “Appendix A” of the Annuity Management Services Agreement upon thirty (30) days prior written notice to the client. RMR shall have the right to amend the provisions of that Agreement by modifying, rescinding, or adding a new provision upon thirty (30) days written notice to Client. The client may amend the Agreement only with RMR’s express written consent. The executed Advisory Agreement will govern additions, withdrawals, and terminations to third-party manager services. According to each third-party manager's Program Agreement, the contract will continue until the client or third-party manager is terminated by written notice to the other. The third-party manager is responsible for refunding unearned fees per their contract terms. If the total value of the client's account or aggregated accounts falls below the TPM’s minimum account size because of a withdrawal or other reasons, the TPM may terminate the Program Agreement. Before participating in any TPM offering, clients should review all applicable disclosure brochures, investor profiles, and third-party manager contracts. Finally, no RMR Agreement may be assigned - within the meaning of the Investment Advisers Act of 1940, as amended, by the Adviser - without the client's prior consent. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Investment Advisers Act of 1940, as amended, shall not be considered an assignment.) ITEM 6: PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT ____________________________________________________________________________________________________ Performance-based fees are fees based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. RMR does not accept performance-based fees or participate in side-by-side management. (See Item 5: Fees & Compensation for fee details.) ITEM 7: TYPES OF CLIENTS ____________________________________________________________________________________________________ Types of Clients RMR primarily provides investment advisory services to individuals, high-net-worth individuals, partnerships, trusts, corporations, retirement/pension and profit-sharing plans, charitable organizations, and other institutions and business entities. Minimum Account Size There is no account minimum for RMR’s services and no ongoing contribution requirements for client accounts, although this practice is highly recommended for continuing savings, asset allocation, and tax efficiency. Clients participating in RMR’s third-party portfolio management services will be subject to the independent third-party manager’s account minimums (typically between $25,000 and $1,000,000), as disclosed in each referred manager's Program Agreement. In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they execute with their referred third-party manager. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, TYPE OF INVESTMENTS & RISK OF INVESTMENT LOSS ____________________________________________________________________________________________________ Methods of Analysis RMR provides customized investment recommendations and portfolio investment advice based on, but not limited to, each client's distinct circumstances, investment objectives, and needs, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan designed to assist the client in striving to meet their expressed personal short and long-term financial goals and objectives, among other factors. 24  Reviews may include but are not limited to cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s IAR will rely upon the accuracy of data furnished by the client or on their behalf without further investigation - RMR is not required to confirm the information obtained from clients or their other professional advisors. As RMR’s Investment Professionals have the independence to take the approach they believe to be the most appropriate when analyzing investment products and strategies for clients, there is a potential conflict that IARs will provide different clients with dissimilar advice regarding the same securities. Several sources of information are used as part of the investment analysis process. These sources include, but are not limited to: financial publications, research materials prepared by others, corporate rating services, company press releases. • • • • SEC filings (such as annual reports, prospectus, 10-k, etc.), and • RMR does not favor one specific method of analysis over another and, therefore, does not have one “significant strategy” for client investments. Instead, several standard approaches will generally be used individually or collectively when advising clients, which approaches may include one or more of the following methods of analysis or investment strategies: Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. With this type of analysis, economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions, and the lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. Fundamental Analysis - a security evaluation method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This security analysis method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Quantitative Analysis - an analysis technique that seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Technical Analysis (“Charting”) - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that the performance of the stock, rather than the performance of the company itself, has more to do with the company’s future stock price. Some risks of this type of analysis include biased opinions or indicators that – while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. Our investment strategies and advice will vary depending on each client's financial situation. Therefore, it is essential that clients notify us immediately regarding any material changes to their financial circumstances, including, for example, a change in their current or expected income level, tax circumstances, or employment status. While RMR’s IARs may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. Additionally, when balancing portfolios, IARs will consider only the account’s managed assets, not other investments the client may hold elsewhere. 25  Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation as we determine investments and allocations based on their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in their best interest objective. Client restrictions and guidelines will also affect the composition of their portfolio. In addition to the “Risks of Loss & Other Types of Risks” provided for review herein, the following are other items can also be items for consideration when determining investment strategies and practices: Asset Allocation - an investment strategy that aims to balance risk and reward by allocating assets among various asset classes. At a high level, there are three main asset classes - (1) equities (stocks), (2) fixed income (bonds), and (3) cash and cash equivalent, each with different risk and reward profiles and behaviors. Asset classes are often further divided into domestic and foreign investments. Equities are often divided into small, intermediate, and large capitalization and fixed income into short, intermediate, and long-term durations. The general theory behind asset allocation is that each asset class will perform differently from others in changed market conditions. By diversifying a portfolio of investments among various asset classes, advisors seek to reduce a portfolio's overall volatility and risk by avoiding overexposure to any asset class during different market cycles. Asset allocation does not guarantee a profit or protect against loss. Capital Growth and/or Income Strategy - a“growth and income strategy” often invests in companies with earnings growth and those that pay dividends. Risks associated with a capital growth and income strategy are similar to those experienced with income and growth strategies. For example, bonds can be called when interest rates drop, and replacing a called bond with another paying the same interest may be impossible or companies can suspend dividends for certain stocks if they experience financial problems. A growth investing strategy includes the search for stocks that have growth potential. The latter means that the stock price will rise at a certain point in time. As a result, growth investors may target young companies that have the potential to exceed their peers in the industry or sector. By its very nature, growth investing implies risk because some of the young companies may fail. Dollar Cost Averaging - the technique of regularly buying a fixed dollar amount of a particular investment, regardless of the share price (“DCA”). More shares are purchased when prices are low and fewer when prices are high. This investment strategy is believed to lessen the risk of investing a large amount at a single investment at a higher price. DCA strategies are ineffective and do not prevent loss in declining markets. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Short-Term Purchases - securities are purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Buying on margin means borrowing money from a Broker-Dealer to purchase stock. Margin trading allows investors to buy more stock than they would typically be able to buy normally. An initial investment of at least $2,000 is required for a margin account, although some brokerages require more. This deposit is known as the minimum margin. Once the account is operational, the holder can borrow up to 50% of the stock purchase price. This portion of the deposit purchase price is the initial margin. Investors can be required to deposit more than 50% of the purchase price. Not all stocks qualify to be bought on margin. When selling the stock in a margin account, the proceeds go to the Broker-Dealer against the repayment of the loan until it is fully paid. A maintenance margin restriction also exists - the minimum account balance that must be maintained before the Broker-Dealer forces the deposit of additional funds or sell stock to pay down the loan (when this happens, it is known as a “margin call.”) If for any reason, a margin call is unmet, the Broker-Dealer has the right to sell account securities to increase the account equity until above the maintenance margin. Additionally, the Broker-Dealer may not be required to consult the account holder before selling. Under most margin agreements, a firm can sell the account securities without waiting for the account holder to meet the margin call, and the account holder cannot control which stock is sold to cover the margin call. Interest on the loan must also be paid. The interest charges are applied to the account unless separate payments are made. Over time, the debt level increases as interest charges accrue. As debt rises, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer an investment is held, the greater the return needed to break even. In volatile markets, prices can fall quickly, and more money can be lost than invested. (Note: RMR requires the pre-approval of a designated Home Office Principal before implementing any margin strategy.) 26  Options Writing - a securities transaction that involves selling options, which are the right, but not the obligation, to buy or sell a particular security at a specified price before the option's expiration date. When an investor sells an option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. The buyer pays the seller a premium (the option's market price at a particular time) for the seller to write the option. Short Selling - clients participating in these portfolios will receive additional disclosure information regarding the risks of short-sale investments. Unhedged, short selling is very risky. Unlike a straightforward investment in stocks, where shares are purchased with the expectation that their price will increase to sell at a profit, in a "short sale," stock is borrowed from a brokerage firm and then immediately sold in hopes that the price will have dropped when they are required to be purchased at a later date. Thus, a short seller hopes a stock's price will decrease in the future to use market declines to their advantage. Short sellers make money when the stock prices fall and lose money when prices increase. The SEC has strict regulations regarding short selling. No ceiling exists on how much a short seller can lose in a trade - if the share price keeps increasing, the short seller must pay the prevailing stock price to buy back the shares. However, a ceiling exists on gains that can be made because a stock’s price cannot fall below zero. In addition, a short seller must undertake to pay the earnings on their borrowed securities as long as they choose to keep their short position open. If a company declares huge dividends or issues bonus shares, the short seller must also pay that amount to the lender. Any such occurrence can skew the entire short investment and make it unprofitable. Finally, a broker can use the funds in the short seller's margin account to buy back the loaned shares or issue a “call away” to require the short seller to return the borrowed securities. If this call is made by the broker when the stock price is significantly higher than the price at the time of the short sale, the investor can suffer tremendous losses. Tax Considerations RMR’s strategies and investments can have unique and significant tax implications. However, unless expressly agreed upon otherwise and in writing, tax efficiency is not the primary consideration in managing client assets. Regardless of client account size or any other factors, RMR strongly recommends our clients continuously consult with a tax professional before and throughout investing their assets. Qualified Custodians will typically default to the FIFO (“First-In, First-Out”) accounting method for calculating portfolio investment cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If a client or their tax advisor believes another accounting method is more advantageous, immediately notify our firm and the account Qualified Custodian of the selected accounting method in writing. (Note: Decisions about cost-basis accounting methods must be made before trades settle, as the cost-basis method cannot be changed after settlement.) Types of Investments RMR’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. Clients have access to a wide selection of product offerings and securities, including, but not limited to, bonds (treasury inflation-protected and inflation-linked), business development companies, certificates of deposits, commercial paper, derivatives, digital assets, equities, exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”), fixed income securities, hedge funds, insurance products including annuities (fixed, indexed, and variable), limited liability companies, limited partnerships (real estate, oil, and gas), mutual funds (load and no-load), non-U.S. securities, options, private placements, real estate investment trusts, unit investment trusts, and warrants, among others, as appropriate and suitable for each account’s goals. Cash Management As indicated below, RMR usually invests clients' cash balances in Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts, money market funds, or certificates of deposit. In managing the cash maintained in client accounts, we will typically utilize the sole exclusive cash vehicles made available by the custodian, according to their parameters. Other cash management and money-market options may be available away from the custodian with higher yields or safer underlying investments. In most cases, at least a partial cash balance will be maintained in a money market or FDIC-insured deposit account to allow for the debit of advisory fees or anticipated cash distributions to clients. We will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: This type of investment product is usually not FDIC insured, insured by any Federal government agency, a deposit, other obligation, or guaranteed by the adviser.) 27  Federally Insured Cash Account (FICA®) Program RMR makes available and refers clients to the FICA® | For Advisors Cash Management Program sponsored by StoneCastle Cash Management, LLC (“StoneCastle”). The Federally Insured Cash Account Program offered by StoneCastle allows clients the ability to protect their money by placing it in deposit accounts at banks, savings institutions and credit unions in a manner that maintains full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of insured depositories. StoneCastle requires a minimum deposit of $100,000 to open a FICA account, and RMR earns a referral fee from StoneCastle if clients participate in this program. RMR’s referral fee starts at 20 basis points and can increase if the interest rate the client receives increases. Clients' interest rates from the FICA program are net of all fees, including the fee RMR receives for client referrals to the program. RMR will assist clients in signing up for this program and facilitating funds transfer between the client’s like-named accounts. Clients participating in the program receive a copy of StoneCastle’s Form ADV. The above cash management program creates a potential conflict of interest between clients who choose to participate and our firm, as by recommending this type of program, RMR receives Promoter referral compensation if clients decide to engage in the services of StoneCastle. RMR addresses this conflict of interest by advising clients of the nature of the conflict whenever any referral is made. Clients are under no obligation to participate in the program. Risks of Specific Securities Utilized While RMR seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. IARs will recommend various types of securities, as indicated herein and deemed appropriate for each client’s situation, restrictions (if any) and goals. Although advice is provided predominantly on the products listed within this Brochure, RMR reserves the right to advise on any suitable investment product for a client's specific circumstances, needs, and individual goals and objectives. We will use other securities to help diversify a portfolio when applicable and appropriate. Investing also risks missing more favorable returns that could be achieved by investing in alternate securities or commodities. Any of the above investment strategies may lead to a loss of investments, especially if the markets move against the client. Additionally, we may advise on other assets held in the portfolio at the inception of the advisory relationship. Since investment strategies and advice are based on each client's financial situation, the advice we provide to one client may differ or conflict with that provided for the same security or investment for another, as each client's needs and risk tolerance differ. Clients should be aware of the material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Recommendation of Particular Security Types RMR recommends various types of securities and does not primarily recommend one type over another since each client has different needs and risk tolerance. As each security type has its unique set of associated risks, it would be impossible to present every specific risk of each investment type. Even within the same kind of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. A description of some of the security types we may recommend and some of their inherent risks follow: Annuities - annuities are financial products that pay out a fixed stream of payments to an individual, primarily used as an income stream for retirees. The period when an annuity is funded before the payouts begin is called the accumulation phase. The annuitization phase begins once payments commence. Annuities can be structured as fixed or variable. Fixed annuities provide regular periodic payments to the owner/annuitant. Variable annuities allow the owner/annuitant to receive larger periodic payments if the investments in the annuity do well; however, if the investments do poorly, the owner/annuitant will receive smaller payments. In addition, the annuity services offered by RMR will incur additional charges, expenses, and miscellaneous fees that are separate and distinct from the Advisory 28  fee charged by the Adviser. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default when the bond is set to mature; and, whether the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character, paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Certificates of Deposit - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Corporate Bonds - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but 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 higher its interest rate risk. Digital Assets - As used herein, “Digital Assets” refers to an asset issued and/or transferred using a distributed ledger or blockchain technology. The investment objective of RMR’s Digital Asset Account allocation is to offer interested clients exposure to the Digital Assets market via a portfolio comprised of Digital Assets available through our Gemini Trust Company, LLC custodial relationship. An investment in Digital Assets is appropriate only for clients who (1) understand the speculative nature of such securities, (2) can bear the economic risk of the investment, (3) have no urgent need for liquidity with the assets committed to this type of investment, and (4) and are willing to accept the risks of loss of their entire investment in exchange for the potential benefits and returns Digital Assets may offer. Given the complexity of this product, investment decisions made for the allocation of any portfolio of Digital Assets are expressly subject to various potential risks, including but not limited to the following: Custody Risk - under the Advisers Act, SEC-registered investment advisers must hold securities with “Qualified Custodians,” among other requirements. Certain Digital Assets may be deemed to be securities. Some Digital Assets do not currently fall under the SEC definition of security. Therefore, many companies providing Digital Assets custodial services fall outside the SEC’s definition of “Qualified Custodian.” Accordingly, clients seeking to purchase actual digital coins/tokens/currencies may need to use non-Qualified Custodians to hold all or a portion of their Digital Assets. Further, Digital Asset holdings are not considered legal tender or insured by the government like U.S. bank deposits. Therefore, investors do not have the same protections as a bank account can offer. Unlike most traditional currencies, such as the U.S. dollar, the value of a Digital Asset is not tied to promises by a government or a central bank - Digital Asset investments are uninsured. Exchange & Business Hours Risk - exchanges can stop operating due to security breaches, fraud, insolvency, market manipulation, market surveillance, KYC/AML procedures, non-compliance with applicable rules and regulations, technical glitches, hackers, malware or other reasons. Blockchain technology is a relatively new and untested technology that operates as a distributed ledger. Blockchain systems could be subject to internet connectivity disruptions, consensus failures or cybersecurity attacks, and the date or time an investor initiates a transaction may differ from when the transaction is recorded on the blockchain. Digital Asset prices can fluctuate, sometimes heavily, after traditional market hours. RMR accepts no responsibility for being unable to buy or sell Digital Assets outside of standard industry trading hours. 29  Government Oversight of Digital Assets Risk - regulatory agencies and/or the constructs responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and subject to change. Regulators may adopt laws, regulations, policies or rules directly or indirectly affecting Digital Assets, their treatment, transacting, custody, and valuation. Liquidity Risk - any liquidity may be limited or disrupted, and there can be no guarantees of the ability to sell or exchange Digital Assets at any price. There is a possibility that trades cannot be settled, may be challenging to settle, or can be traded only at significantly adverse prices depending on the market situation or market volume. Loss of Confidence Risk - Digital Assets are part of a new and rapidly evolving “Digital Assets industry,” subject to high uncertainty. For a relatively small use of Digital Assets in the retail and commercial marketplace, online platforms have generated a large trading activity by speculators seeking to profit from the short-term or long-term holding of Digital Assets. Most Digital Assets are not backed by a central bank, national or international organization, assets or other credit. Their value is strictly determined by the value that market participants place on them through their transactions, which means that a loss of confidence may bring about a collapse of trading activities and an abrupt drop in value. Peer-to-Peer Transaction Risk - Digital Assets can be traded on numerous online platforms through third- party service providers and through peer-to-peer transactions between parties. Many marketplaces bring together counterparties without providing clearing or intermediary services or being regulated. In such a case, all risks (such as double-selling) remain between the parties directly involved in the transaction. Price Volatility of Digital Assets Risk - a principal risk in trading Digital Assets is the rapid market price fluctuation. The value of client portfolios relates in part to the value of the Digital Assets held in the client portfolio; fluctuations in the price of Digital Assets could adversely affect the value of a client’s portfolio. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex factors such as supply and demand, availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Digital Assets users and market participants; perceived or actual security vulnerability; and traditional risk factors including inflation levels; fiscal policy; interest rates; and political, natural and economic events. Protocol & Governance Risk - Digital Assets are a relatively recent technological innovation. Bitcoin, invented in 2009, is widely considered to be the first popular Digital Asset. Other Digital Assets in which we may invest were created after Bitcoin. There can be no assurance that the Digital Asset industry will continue in its current form. Digital Assets are generally created and supported by an underlying blockchain or protocol, such as the Bitcoin Protocol or the Ethereum Protocol. Any malfunction, malicious attack, breakdown or abandonment of the network may have an adverse effect on the Digital Asset’s protocol or network, which could lead to loss of value of the Digital Asset. Moreover, advances in cryptography, or technical advances such as quantum computing, could present risks to Digital Assets by rendering the cryptographic consensus mechanism that underpins a Digital Asset’s protocol ineffective. There can be no assurance that changes or developments in Digital Asset protocols will not adversely impact your Account. Regulatory Risk - regulatory uncertainties surrounding blockchain and distributed ledger technologies abound. Because global and national standards are far from being fully established, fund managers face the heavy disclosure obligation to disclose existing regulatory considerations and the potential outcome of various regulatory issues that have yet to be decided. The comprehensive regulation facilitating institutional investment will require coordinating global standards, particularly for the exchanges. For U.S. governance, regulatory standards will likely be set not by a single authority but by a combination of state, national, international and industry bodies, judicial precedent, international agreements, and industry associations. Service Providers Risk - service providers that support Digital Assets and the Digital Asset marketplace(s) may not be subject to the same regulatory and professional oversight as traditional securities service providers. Further, there is no assurance that the availability of and access to virtual currency service providers will not be negatively affected by government regulation or the supply and demand for Digital Assets. Accordingly, companies or financial institutions currently supporting virtual currency may not do so. Taxation Risk - it should be noted that there is substantial uncertainty concerning the tax treatment of an investment in Digital Assets. Digital Assets may be considered assets in certain jurisdictions and currency in 30  others. Sales or value-added taxes may be imposed on purchases and sales of Digital Assets. Based on their home jurisdiction, the investors may require specific tax advice regularly to ensure the tax treatment of their investments in Digital Assets. Technology & Security Risk - Digital Assets are computer-coded entries on a digital ledger, or blockchain, visible to and verifiable by nodes. Ownership is reflected in a string of numbers on a distributed ledger, accessible only by a public and private key in “wallets.” A custodian could hold a “private key” and a “public key” to the Digital Asset to satisfy regulatory requirements. A custodian can maintain private keys in digital form on a computer hard drive unconnected from the internet and protected by layers of cybersecurity. The custodian can also maintain and secure the private key in a “cold wallet” by, for example, locking it in a physical vault. In any event, the technology used for safeguarding Digital Assets is emerging. Digital Assets are essentially bearer assets. In general, anyone who obtains possession of the private key can, in theory, misappropriate the asset, no matter where the private key is maintained. Unanticipated Risks - Digital Assets are new and still largely untested. In addition to the risks disclosed, there are other risks associated with purchasing Digital Assets that RMR cannot anticipate. Such risks may further materialize as unanticipated variations or combinations of the risks discussed. Digital Asset investments are inherently global; therefore, exchange platforms, custodians, counterparties, and issuers are rarely located within a single jurisdiction. Currently, the industry does not have a standard regulation or auditing practice for accounts holding Digital Assets to verify ownership. The Investment has counterparty and custody risks, including loss or theft of the Digital Asset Itself. Valuation Risk - the valuation of Digital Assets can differ significantly depending on the price source or otherwise due to factors including, but not limited to, market fragmentation, unregulated markets, illiquidity and volatility. There is no guarantee that a client will achieve a better-than-average market price for Digital Assets or purchase Digital Assets at the most favorable price available. Volatility & Loss Risks - Digital Assets are highly speculative and involve high risk. Prices of Digital Assets are incredibly volatile and can have higher volatility than other traditional investments such as stocks and bonds, and market movements can be challenging to predict. If the value goes down, it is not guaranteed to rise again. As a result, there is a significant risk of losing the entire principal investment. Gains or losses are unpredictable, and there can be no guarantee of returns. Interests should not be purchased by anyone who cannot afford the loss of their entire investment. Transactions in Digital Assets may be irreversible, and losses due to fraudulent or accidental transactions may not be recoverable. There are counterparty and custody risks associated with Digital Assets, including loss or theft of the Digital Asset. Exchange-Traded Funds (“ETFs”) - are typically investment companies classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, particularly when ETF shares are listed on a securities exchange. An ETF is designed to track the price of an index or a collection of underlying assets as closely as possible. Shares can be bought and sold like shares of publicly traded companies throughout the day and may trade at a discount or premium to their NAV. This difference between the bid and ask prices is often called the "spread." The spread varies over time based on the ETF's trading volume and market liquidity. It is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, like traditional mutual funds, some ETFs (particularly those that invest in commodities such as gold and precious metals) are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged ETFs, in particular, present distinct risks and are not appropriate for all investors. Leveraged ETFs should be utilized only by those investors who understand the risks of seeking daily leveraged and inverse investment results, generally for short- term active trading in an actively monitored and managed investment program. Investors must be aware of the daily nature of the leveraged and inverse investment strategies employed, high expense ratios, and lack of guarantee of long-term inverse returns, among other considerations, before participating in this type of investment. Exchange-Traded Notes (“ETNs”) - an ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to various assets, such as commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption depends on the ETN issuer's ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if 31  the issuer's credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may carry particular risks. ETNs may be closed and liquidated at the discretion of the issuing company. Fixed Income Call Options - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Limited Partnerships, Limited Liability Companies & Business Development Companies - limited partnerships, limited liability companies and business development companies represent different forms of ownership of investment assets. These entities are investment vehicles that may own full or partial interest in various operating businesses. The types of operating companies may include but are not limited to equipment leasing, oil and gas, alternative energy, and real estate. Managed Futures Funds - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that trade various derivative instruments, including options, futures, forwards, or spot contracts, which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds. It may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and costs. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission notes, "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long- term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds - mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. Mutual funds can also be "closed-end" or "open-end." So-called “open-end” mutual funds allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their 32  availability to new investors. Some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund; others charge such fees, which can also reduce returns. Mutual funds are sold with different share classes and will offer investors discounts on sales charges, as described and explained in each fund's prospectus. Funds will have a manager who trades the fund's investments following the fund's investment objective. Mutual fund shares held in client accounts may also be subject to 12b-1 fees, short-term redemption fees, and other fund annual expenses. No-load or load waived mutual funds used in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Non-advisory accounts typically have upfront or back-end charges. Each fund's prospectus fully describes these fees and costs. If clients have mutual funds in their portfolio, they will pay their adviser and any third-party manager, custodian, and mutual fund manager to manage their assets and other fund expenses paid by the fund's shareholders. If clients transfer in particular share classes of mutual funds and liquidate the shares after the transfer, those shares can also incur contingent deferred sales charges (“CDSCs”) from the mutual fund company if they are within the CDSC holding period. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. In short, all these costs of managing the funds can reduce the fund’s returns. Options - options are complex securities involving risks that are not necessarily in everyone’s best interest. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: 1. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. 2. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. The option trading risks of options buyers are the risk of losing your entire investment in a relatively short period. This risk increases if, as expiration nears, the stock is below the call's strike price (for a call option) or if the stock is higher than the put's strike price (for a put option). European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. In addition, specific exercise provisions of a specific option contract may create risks, and regulatory agencies may impose exercise restrictions, which stop you from realizing value. Selling options is more complicated and can be even riskier. The option trading risks for options sellers include but are not limited to: options sold may be exercised at any time before expiration, covered call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock, the sale, - - writers of naked calls risk unlimited losses if the underlying stock rises, writers of a naked put are exposed to a maximum loss of the strike price less the premium received from - - writers of naked positions run margin risks if the position goes into significant losses, and such risks may include liquidation by the broker, - writers of call options can lose more money than a short seller of that stock on the same rise on that - underlying stock - an example of how the leverage in options can work against the options trader, writers of naked calls must deliver shares of the underlying stock if those call options are exercised, call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions, - - writers of stock options are obligated under the options that they sold even if a trading market is not - available or they cannot perform a closing transaction, and the value of the underlying stock may surge or drop unexpectedly, leading to automatic exercises. - 33  Other option trading risks include the complexity of some option strategies carrying a significant risk on their own, option trading exchanges or markets and options contracts are open to changes at all times, options markets have the right to halt the trading of any options, thus preventing investors from realizing value, there is a risk of erroneous reporting of exercise value, investors trading through that firm may be affected If an options brokerage firm goes insolvent, and Internationally traded options have unique risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Options Contracts - Options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Put buyers hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Real Estate - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and growing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs must declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations. Hence, cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Securities Futures Contracts - a futures contract (on tangibles and intangibles) is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a specific commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance is not indicative of future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. RMR cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, each client may view financial loss differently and may depend on many distinct risks, each affecting the probability and magnitude of potential losses. The following risks, which are not all- 34  inclusive, are additional risks provided for careful consideration by a prospective client before retaining our services. (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - the Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by RMR. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and RMR investment decisions will not always be profitable. Artificial Intelligence - we may leverage artificial intelligence ("AI") to enhance operational efficiency and improve client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment advice. Instead, our AI applications are primarily focused on automating administrative and client service-related tasks, including meeting preparation, note-taking, CRM updates, task management, and generating meeting recap notes. We believe AI streamlines client engagement, reduces administrative burdens, and ultimately enhances the overall client experience. It is essential to recognize that AI models are inherently complex, and their outputs may sometimes be incomplete, inaccurate, or biased. While AI serves to augment our operations, its use introduces certain risks, such as the potential for inaccuracies, decision-making errors, and challenges related to the effective deployment of the technology. Additionally, AI usage may pose risks to the confidentiality of client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both client and proprietary information. We continuously evaluate the performance of AI technologies to ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance. Business Risk - is the risks associated with a specific industry or company. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and a Code of Ethics to strive to ensure that the client's interest is always held above that of the firm and its associates. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be 35  repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non- U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, such as losing your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax 36  treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Market Timing Risk - The risk of market timing based on charting and technical analysis is that charts may not accurately predict future price movements. Current securities prices may reflect all information known about the security. Daily changes in market prices of securities may follow random patterns and may not be predictable with reliable accuracy. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. The risk of cyclical analysis is that economic/business cycles may not be predictable and have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict accurately. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is 37  expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks - a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same kind of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stock Risk - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Fund Risk - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - a stock's market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. 38  Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always insured by the Federal Deposit Insurance Corporation; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrant Risks - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. 39  RMR attempts to address the above risks by diversifying among multiple asset classes and asset strategies, creating different portfolio segments. Any security eligible for inclusion in a portfolio with low or no liquidity may be removed and replaced by the next highest-ranked security in the same asset segment. Due to the fluctuating nature of security prices, the weighting of an individual security or sector in the portfolio may change after the portfolio is established. RMR does not represent or guarantee that the services provided or any analysis methods provided can predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including those noted above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Before acting on RMR’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, and other financial Investment Professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable IAR. ITEM 9: DISCIPLINARY INFORMATION ____________________________________________________________________________________________________ Legal or Disciplinary Event Disclosure Registered investment advisers are required to disclose all material facts concerning any legal or disciplinary events that may be relevant to a client's or prospective client's evaluation of the adviser or its management’s integrity. A state regulatory agency took disciplinary actions against certain members of RMR's management for violations of securities regulations, rules, and/or statutory provisions. These matters have since been resolved. For complete details on our disciplinary history and full disclosure documents, please visit the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov and search for our firm name or CRD #169005. Beyond these matters, neither the Adviser nor its management has any additional disciplinary or legal proceedings to disclose that would be material to a client’s evaluation of this advisory practice. RMR has no outstanding issues, and the firm, along with all Control Persons, is appropriately registered without restriction. You may also view information about any affiliated person who is registered or required to be registered as an Investment Adviser Representative of the firm by similarly searching their name or CRD # on the same IAPD website. Copies of this information can also be obtained by contacting us directly. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ____________________________________________________________________________________________________ RMR is an independent registered investment advisory firm that provides the investment advisory and other services indicated within this Form ADV 2A Disclosure Brochure. The firm does not engage in business activities or offer services other than those described herein. Certain RMR Associates may sell additional products or provide services outside their roles with the Adviser, as indicated in their Form ADV 2B Brochure Supplements and below. Broker-Dealer & Registered Representatives of A Broker-Dealer RMR is not registered and does not intend to register as a Broker-Dealer. From time to time and in connection with their approved outside business activities, certain of RMR’s Investment Professionals can also be Registered Representatives (“RRs”) of non- affiliated Broker-Dealers, Member FINRA and SIPC. When acting in the capacity of RRs of such unaffiliated Broker-Dealers, these Associates will sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, variable annuity, or others to clients and receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. (See “Conflicts of Interest” at the end of this section for additional important information.) 40  Investment Advisor Representatives of Other Unaffiliated Investment Advisory Firms Certain RMR IARs are also registered IARs of other non-affiliated registered investment advisory firms. IARs who maintain outside business activities with such firms are required to provide the disclosure documents of outside investment adviser’s disclosure brochures and documentation. RMR clients should understand that any assets they place under the management or within any other outside investment advisory firm’s programs are separate and distinct from their Agreement and assets managed by RMR. Further, a conflict of interest exists to the extent that while the services offered by RMR and another unaffiliated adviser may be similar, clients' fees and other costs for such services may differ. RMR does not share any portion of the investment advisory fee a client will pay for another firm due to an RMR Associate’s outside business activity. Commissions or other compensation earned by RMR Associates in their capacities as employees of unaffiliated firms are separate and in addition to the advisory fees paid to RMR under our Agreements. (See “Conflicts of Interest” at the end of this section for additional important information.) Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither the Adviser nor any management persons are registered or intend to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an Associated Person of the preceding entities. Insurance Sales & Services Affiliated & Unaffiliated Insurance Agencies RMR Wealth Builders, Inc., the investment adviser, is affiliated with RMR Wealth Builders, Inc., a New Jersey Insurance Producer of a similar name (Insurance Producer License # 8729246). RMR’s insurance-licensed Investment Professionals will offer variable life, variable annuity, accident & health, sickness and life or other insurance products from time to time and when appropriate to their RMR advisory clients in connection with their approved outside business activities for these products and recommend advisory clients consider either insurance products and services. Insurance company personnel also retain the discretion to introduce non-advisory clients to the investment adviser for advisory services. In this capacity, in addition to their compensation from RMR, insurance-licensed Investment Professionals can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of insurance products from the insurance agencies with whom they are presently or with whom they may become appointed in the future. The insurance commissions earned by these individuals are separate from and in addition to RMR’s advisory fees. Commissions are based on the standard commission schedule of the insurance products provider and are generally not negotiable. This presents a conflict of interest since, to the extent that clients of the investment adviser can also use an insurance company’s services, the activities and fees of such companies are essential to understand. RMR Associates, licensed as Insurance Agents, are incentivized to effect suitable insurance transactions based on the potential for commission compensation received rather than the client’s best interests. Advisory clients should be aware that when using the services of any such insurance entity, such services are not provided by RMR, the investment adviser. Any insurance services offered are separate and distinct from the client's relationship, Advisory Agreement and services provided by RMR (the investment adviser). The insurance commission paid to licensed Insurance Agents will be based on the standard commission schedule of the insurance products provider and are generally not negotiable. Insurance commissions are separate from RMR’s advisory fees. The services of companies other than the Adviser are also subject to separate and distinct contractual arrangements. Further, the protections afforded to clients under applicable investment advisory laws and regulations generally do not apply to those provided by any RMR affiliate or an unaffiliated company. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Adviser or utilize the services of any affiliate or other industry relationship. Advisory clients maintain complete discretion regarding whether to use the services of RMR, RMR-affiliated entities, or other industry relationships that may be recommended. (See “Conflicts of Interest” at the end of this section for additional important information.) Designations & Other Outside Business Activities Our IARs can, with approval, operate their own independent companies outside of RMR. These unaffiliated companies include, among others, accounting and tax practices and insurance services. As such, there is a potential conflict of interest because RMR’s Investment Professionals can earn compensation from RMR and the unrelated business activity. In addition, RMR 41  Associates hold various other designations in connection with these approved outside business activities, separate from their role as IARs with RMR. RMR does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from RMR’s advisory services and fees. (See “Conflicts of Interest” at the end of this section for additional important information.) Recommendation of Other Advisers & Third-Party Money Managers RMR may allocate all or a portion of client assets to a third-party adviser or manager. RMR receives compensation from the third-party referred managers and advisers, who we recommend that you use their services, and, in such instances, the fees can be shared between RMR and the third-party adviser or manager. Before selecting any outside manager, RMR will review the manager to ensure they fit the adviser’s models' criteria and conduct initial background due diligence. Referred managers must be registered with an appropriate regulatory body and enter RMR's Terms and Conditions Agreement before being included as a potential client referral. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which clients are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style, will be disclosed in each contract between the RMR, the third-party money managers, and the client. RMR reserves the right to add or delete managers as deemed necessary. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the third party. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. Beyond the information disclosed herein, RMR has no other business relationships with the recommended referred managers. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Pontera Services RMR engaged Pontera to provide advisory services to plan participants. Pontera allows RMR and its IARs to access accounts of plan participants to provide advisory services, make recommendations, and allocate accounts on a discretionary basis based on the available investment options in the plan. This service does not fall under the Retirement Plan services already provided by RMR, where RMR and its IARs are the advisors to retirement plans. Pontera allows RMR and its IARs to provide advice to plan participants who engage us for these services without maintaining custody of client funds. Under the existing Retirement Plan Services, RMR does not provide advice to plan participants of Retirement Plans that RMR and its IARs are the advisors of record. Future Clients RMR may provide investment advisory services to other clients in the future. Other future clients may have investment objectives, programs, strategies and positions that are similar to or may conflict with those of our current clients or may compete with or have interests adverse to our current clients. This conflict could affect the prices and availability of financial instruments in which the current clients invest. However, there can be no assurance that other future clients with similar investment objectives, programs or strategies will hold the same positions or perform substantially similar to our current clients. Furthermore, our activities with respect to other future clients could conflict with our activities relating to our current clients. RMR may give advice or take action for the investments and transactions in one client account that may differ from the advice given or the timing or nature of action taken for financial instruments and transactions for other client accounts due to a variety of factors such as regulatory and tax issues and differences in investment programs. As a result, even though our clients may have similar investment objectives and pursue similar investment strategies, they may have substantially different portfolios and investment returns. Conflicts of interest may also arise when we make decisions on behalf of clients where the interests of some clients differ from the interests of others. (See “Conflicts of Interest” at the end of this section for additional important information regarding this activity.) Other Business Relationships RMR uses third-party resources to help run its business and provide services to its clients, mostly back-office related. RMR sources these professionals striving to act in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither RMR nor its Associates receive compensation for such use or referrals. 42  Conflicts of Interest The practice of making clients aware of the above other financial activities, affiliations, designations, and relationships and the services discussed above presents a conflict of interest since RMR’s Investment Professionals may have a financial incentive to submit advisory clients to certain companies or services over others due to potential compensation received in connection with the transaction. This can incentivize them to introduce their clients to the professionals or services based on their compensation rather than client needs. Likewise, persons associated with the affiliated companies or outside relationships may refer their non-advisory clients to RMR. RMR addresses this conflict of interest by requiring Associates to always act in each client's best interests. Before the transaction, RMR’s Investment Professionals must fully disclose such relationships when making recommendations. If offering clients advice or products outside of RMR, they satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid/received before transaction execution. When acting in this capacity, RMR’s Investment Professionals are not acting on behalf of RMR, the investment adviser, concerning the client's services under an RMR Advisory Agreement. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. Further, they are not obligated to place the transaction through RMR if they elect to act on any recommendation received. The client may act on recommendations received by placing their business and securities transactions with any brokerage firm or third party. RMR makes no assurances that another entity's products or services are at the lowest available cost. Clients may obtain the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMRs Code is available for review free of charge to any client or prospective client upon request. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. ITEM 11: CODE OF ETHICS, PARTICIPATION, OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ____________________________________________________________________________________________________ Description of Our Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt a Code of Ethics that sets forth standards of conduct and requires compliance with federal securities laws. RMR takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Personnel who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, RMR has adopted a Code of Ethics (“Code”) that sets forth the firm's conduct standards in keeping with its fiduciary obligation. RMR strives to comply with applicable laws and regulations governing our practices. The adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all RMR Associates, including individuals registered with the adviser as IARs or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. RMR's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates that they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Associates are required to attest no less than annually to their compliance with and understanding of the above matters - including confirmation and acknowledgment by every licensed IAR of the firm’s expectations regarding their conduct, given the duties, 43  responsibilities, and principles required. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMR's Code is available for review free of charge to any client or prospective client upon request. An electronic copy of our Code of Ethics is also available for your review at www.rmrwealth.com. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm have any material financial interests in client transactions beyond the provision of investment advisory services as disclosed herein. Further, RMR’s policy is that neither the firm nor any Associates may share in the gains and losses associated with any purchase or sale of a security on your behalf. Personal Trading Practices RMR or persons associated with our firm may buy or sell securities that we recommend to you or securities in which you are already invested; at the same time, we buy or sell such securities for our account. This act can allow them to buy or sell the same securities before or after, suggesting them to clients and profiting from the recommendations provided. RMR’s policy is that neither our firm nor persons associated with our firm shall have priority over client accounts in the purchase or sale of securities; we will always transact client business before their own when similar securities are being bought or sold and document any transactions that could be construed as a conflict of interest, per firm procedures. Regardless, a conflict of interest exists in such cases because we can trade ahead of clients and potentially receive more favorable prices than they will receive. RMR recognizes that the individual investment transactions of members and Associates of the adviser demand the application of a high Code of Ethics and require all such transactions to be carried out in a way that does not endanger the interest of any client. At the same time, RMR believes that if the investment goals of clients and firm members are similar, having common ownership of some securities is logical and desirable. RMR has instituted within its Code of Ethics (“Code”) a Personal Securities Transactions & Trading Policy, which consists of personal trading and pre-clearance procedures for Associate account transactions and a transaction reporting system to monitor compliance with this policy. The firm’s Code also includes policies and procedures to address insider trading, other personal securities transactions, and many other essential safeguards required of its Associates. Upon employment or affiliation and at least annually after that, Associates must sign an acknowledgment stating they have read, comprehend, and agree to comply with its Code. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. RMR does not permit insider trading and has implemented procedures to ensure that Associates observe its insider trading policy. Associates know the rules regarding material non-public information and insider trading and seek to ensure they do not benefit personally from the short-term market effects of their client recommendations. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client by contacting us directly. Conflicts of Interest RMRs policy prohibits the firm, its Associates, and any related person from participating in trading that may be detrimental to any advisory client or in conflict with the Adviser's written supervisory compliance policies and procedures, Code of Ethics, or any applicable rules of state and federal securities laws, including prohibitions on personal and insider trading. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures, including maintaining transaction records, to ensure that no Associate receives preferential treatment over advisory clients or affects the markets. RMR performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm that no conflicts have occurred. Additional details of how RMR mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. RMR's Code is available for review free of charge upon request by any client or prospective client contacting us directly. 44  ITEM 12: BROKERAGE PRACTICES ____________________________________________________________________________________________________ Preferred Custodians & Brokers-Dealers RMR does not maintain custody of the assets we manage on your behalf. Client assets must be held in an account at a "Qualified Custodian," generally a Broker-Dealer or bank. RMR’s preferred Qualified Custodians are Fidelity Investments Institutional Services Company, Inc. (“Fidelity”) and Charles Schwab & Co., Inc. (“Charles Schwab” or “Schwab”), both independent and separate registered Broker-Dealers, Members of FINRA and the SIPC, who will take possession of the cash, securities, and other assets within the client's portfolio account and buy and sell securities upon our instructions, as indicated within each client’s written Agreement and the documents they execute to establish their custodial account with each Qualified Custodian unless the client directs otherwise. Digital Asset services clients will maintain their assets with an available custodian offered through Securitize, a platform solution RMR engaged to deliver these services. Available custodians include but are not limited to, Gemini, Coinbase, Anchorage Digital, and Equity Trust Company (“Equity Trust”), which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves, which serves as the third-party custodian for IRA Digital Assets accounts but will not be the custodian of the Digital Assets themselves. RMR may also approve IRA account custodians other than Equity Trust in connection with services provided under these services. RMR does not open custodial accounts on the client’s behalf. RMR is independently owned and operated and not affiliated with its preferred Qualified Custodians. Factors Considered in Selecting/Recommending Broker-Dealers For Client Transactions & Determining Compensation Reasonableness Broker-dealers and third-party Qualified Custodians are in the business of serving independent investment advisory firms like RMR and provide advisers and their clients with access to institutional brokerage, trading, custody, reporting, and related services – many of which are not typically available to retail customers. However, certain retail investors may be able to obtain institutional brokerage services from Broker-Dealers and Qualified Custodians without going through us. The various support services that help an adviser oversee and administer client accounts and manage and grow their advisory business are typically available at no charge if qualifying amounts of client account assets are maintained with the custodian. In recognition of the value of the custodian's services, clients may pay higher commissions and/or trading costs than those available elsewhere. RMR reviews broker selection annually at a minimum and, in making its preferred Broker-Dealer/Qualified Custodian selection, seeks to recommend firms in this role that will hold client assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. RMR’s selection process is based on many factors. When considering whether the terms provided are advantageous to clients, we take into account a wide range of factors, including but not limited to the following: • • • • • • • • • • the combination of transaction execution and asset custody services, capability to execute, clear, and settle trades (i.e., buy and sell securities for client accounts), capability to facilitate transfers and payments to and from accounts (i.e., wire transfers, check requests, bill payments, etc.), availability of investment research and tools to assist in making investment decisions, best execution and the competitiveness of the price of those services (i.e., commission rates, margin interest rates, other fees, etc.), the custodian’s reputation, financial strength, security and stability, the prior and existing relationship with our firm and our other clients, research or other products or services delivered or paid for by the approved custodian, the overall quality of services, and availability of other products and services that benefit us, as discussed below. Qualified Custodian Brokerage & Custody Costs The client accounts maintained at our preferred Broker-Dealers/Qualified Custodians are generally not charged separately for custody services but are compensated by charging clients commissions or other fees on trades that execute or settle into the custodial account. Certain trades, such as mutual funds and ETFs, do not incur commissions or transaction fees. Instead, the Qualified Custodian is compensated by earning interest on the uninvested cash in the client’s Cash Features or similar account programs. RMR is not required to select the broker or dealer with the lowest transaction cost, even if that broker provides 45  execution quality comparable to other brokers or dealers. (For example, Schwab charges clients a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a different Broker-Dealer but where the securities bought or the funds from the securities sold are deposited/settled into the Schwab account. These fees are in addition to the commissions or compensation clients pay the executing Broker-Dealer. Because of this, we have Schwab execute most client account trades to minimize client trading costs. Although we are not required to execute all trades this way, we have determined that having Schwab execute most trades is consistent with our duty to seek "best execution" of client trades - the most favorable terms for a transaction based on all relevant factors, including those listed above. Clients may pay lower transaction costs by using another broker or dealer.) Our preferred Broker-Dealers/Qualified Custodians also make various support services available. Some help us manage or administer our clients' accounts; others help us manage and grow our business. These custodial support services are generally unsolicited; advisers do not have to request them. The following provides a more detailed description of these support services: Services That Benefit Clients Our Qualified Custodian’s Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through them include some to which we might not otherwise have access or would require a significantly higher minimum initial investment by our clients. The services described in this paragraph benefit our clients and their accounts. Services That May Not Directly Benefit Clients Our Qualified Custodians also make available other products and services that benefit us but may not directly benefit our clients or their accounts. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the Qualified Custodian’s own and that of third parties. We may use this research to service all or a substantial number of our clients' accounts. In addition to investment research, they also make available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple client accounts, facilitate payment of our fees from our client accounts, and  provide access to client account data (such as duplicate trade confirmations and account statements),   provide pricing and other market data,   assist with back-office functions, recordkeeping, and client reporting. Services That Generally Benefit Only Us Other services to help us manage and further develop our business enterprise include: consulting on technology, compliance, legal, and business needs,  educational conferences and events,   publications and conferences on practice management and business succession,  access to employee benefits providers, human capital consultants, insurance providers, and  marketing consulting and support. Our preferred Qualified Custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services to us. They can also discount or waive their fees for some of these services to us or pay all or a part of a third party's fees. We are also provided other benefits, such as occasional business entertainment for our personnel, which we would be required to pay for from our resources if client accounts are held elsewhere. RMR regularly uses most of these services, some affecting our daily operations, while others are used less frequently, as described herein. Research & Soft-Dollar Benefits An investment adviser receives custodial soft dollar benefits when the firm obtains custodial research or other products and services related to client securities transactions. RMR may receive certain benefits from our Broker-Dealers/Qualified Custodians. These benefits include but are not limited to electronic access and download of trades, balances and positions, confirmation and statements in the Broker-Dealer or Qualified Custodian's portfolio management software and access to related blotters, duplicate and batched client statements, confirmations and year-end summaries. RMR also receives a dedicated trading desk and service group that assists our clients, an account services manager dedicated to our accounts, access to a 46  real-time order matching system, mutual funds with no transaction fees, and select institutional money managers. In addition, we can receive discounts on compliance, marketing, research, technology and practice management products or services provided to us by third-party vendors and the ability to have advisory fees directly debited from client accounts following applicable federal and state requirements. Our approved, Qualified Custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services, discount, or waive fees for some of these services or pay all or a part of a third party's fees. In effect, the fees paid by our clients generate the soft dollars used to pay for such administrative services. The Adviser will not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. The availability of the above services, commonly called "soft dollars," benefits us because we do not have to produce, purchase, or pay for them as long as our clients collectively keep a minimum amount of assets in our Qualified Custodian accounts. Beyond that, these services are not contingent upon us committing any specific amount of business in trading commissions or assets in custody. A conflict exists in such situations because RMR can be incentivized to select or recommend a Broker-Dealer based on the Adviser’s interest in receiving research or other products or services rather than the Adviser’s clients’ interest in receiving the best value in custody services and most favorable execution of their transactions. While the conflict of interest exists, our clients also measure our overall performance; the cost of these services necessarily reduces portfolio performance. It is in our best interests to minimize these costs to improve the overall performance of client portfolios. Furthermore, we believe that selecting any Qualified Custodian and Broker-Dealer is in the best interests of our clients. The scope, quality, and price of services received primarily support our selection, not services that benefit only us. (Please contact us directly for the most current qualifying amount of client assets numbers.) Brokerage for Client Referrals RMR and its Associated Persons do not receive client referrals from broker-dealers or third parties when selecting or recommending brokers for client accounts. Directed Brokerage Clients are free to use the Broker-Dealer/Qualified Custodian or financial institution of their choice for any recommendation. However, clients who select RMR as their investment manager must maintain their accounts at one of our approved Broker- Dealers/Qualified Custodians. Clients should be aware that not all advisers require their clients to direct brokerage. Clients who wish to direct brokerage will do so in writing and shall be responsible for negotiating the terms and arrangements with the Broker-Dealer/Qualified Custodian of their choosing. RMR will not be obligated to seek better execution services or prices or aggregate client account transactions for execution through other custodians with orders for different accounts we manage. As a result, a disparity in commission charges can exist between those charged to clients who do not direct brokerage and those who do, resulting in potentially higher trading expenses, costs, and less favorable transaction execution for clients with directed brokerage transactions. Directing brokerage may cost the client money. Clients wishing to direct brokerage should consider the costs or disadvantages of such requests, including paying higher commissions or other transaction costs and greater spreads, being unable to aggregate orders to reduce transaction costs, or receiving less favorable prices on transactions for the account that would otherwise be the case. Accordingly, clients should satisfy themselves that their designated broker can provide adequate prices and execute their transactions. Subject to its duty to seek best execution, RMR may also decline a client's request to direct brokerage if, at our discretion, such brokerage arrangements would result in operational difficulties. Directed Brokerage - Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted if the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. (Note: ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan.) 47  Best Execution RMR conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, directed brokerage and best execution as a matter of policy and practice. The Adviser seeks to ensure compliance with clients' Agreements and IPS documents if prepared for the type of account established and observe best practices. RMR acts on its duty to seek best execution. However, a client may pay a higher commission than another Qualified Custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable about the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the full range of services available, including, among others, the value of research provided, execution capability, financial strength, commission rates, and responsiveness. While RMR will seek competitive rates, they may not obtain the lowest commission rates for client transactions. Trade Aggregation RMR combines multiple orders for shares of the same securities purchased for the advisory accounts we manage ("aggregated trading"). The trade aggregation practices observed under each advisory offering are as follows: 1. 2. 3. CIP (Accounts not invested in an RMR Model Portfolio) - When these accounts are traded, they are not included in any block trades because these are not invested in an RMR model. CIP (Accounts invested in an RMR Model Program) - When these accounts are being traded, they are included in the block trades processed to rebalance model accounts. If we are trading a one-off position to raise cash, they are not traded. TPM Wrap Fee Program - As RMR does not trade these accounts, trade aggregation will occur according to the third-party manager’s direction. The costs of not aggregating orders when the opportunity exists include the inability to facilitate best execution, potentially increasing brokerage commissions or other costs. Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, RMR’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages and restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the facts and circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an RMR trade error and be made whole. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. RMR is not responsible for account errors or losses wherein we have used our best efforts to execute trades promptly and efficiently or for trades improperly executed by any clearing firm, custodian, mutual fund, or insurance company when we correctly submit an order. If a trade or some portion of a trade is not effected or an electronic glitch occurs and the client’s account is not traded at the same time or price as others, a like occurrence or error does not result from our failure to execute or follow appropriate trade procedures correctly; the resulting loss will not be considered a trading error for which RMR is accountable. Further, clients are reminded that - as disclosed in their prospectuses, virtually all mutual funds reserve the right to refuse to execute trades if, in a fund's sole judgment, the trade(s) would jeopardize its value. RMR has no authority to change, alter, amend, or negotiate any provision outlined in any mutual fund prospectus or for any unilateral adverse decisions by a mutual fund or insurance company to restrict/prohibit their asset management programs. In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. RMR’s Director of Compliance and Operations is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 48  ITEM 13: REVIEWS OF ACCOUNTS ____________________________________________________________________________________________________ Client Account Reviews - Frequency, Nature & Oversight Initial Client Agreements are reviewed and approved by the Director of Compliance and Operations, their Designee or another firm Principal, as appropriate. Designated Supervisors will also periodically review ongoing client account transactions and oversee IAR annual account review obligations. Reviews for RMR’s specific advisory services occur as follows: Portfolio Management Services Accounts IARs will review the portfolio management services client accounts they manage directly quarterly, periodically, and as needed as part of the reporting process. No less than annually, as indicated herein and within each client's executed Advisory Agreement, IARs will meet with clients to review their investment objectives and financial situation to determine the suitability of investments, financial plans, and portfolio exposures. Such reviews can also include addressing the following considerations: • How did the portfolio perform on a nominal and relative basis over the last reporting period? • Did the portfolio meet its benchmark and objective(s)? • What parts of the portfolio/investments performed well or poorly? • Is the current portfolio allocation aligned with the target allocation outlined in the client’s IPS? If not, what changes are required? Does the target portfolio continue to make sense? Have changes in personal circumstances or the broader world occurred that suggest a need to change target allocations? • Have any other material events occurred to suggest an investment change be made at this time? Additional reviews are conducted based on various circumstances, including, but not limited to, changes in client risk/return objectives, contributions and withdrawals, market-moving events, security-specific events and/or year-end tax planning. Accounts may also be examined based on other triggering events, such as: • new cashflow of funds for investment, • significant portfolio liquidation and disbursement requests, • a substantial change in the client's financial circumstances, and • a considerable difference in financial market status. According to each referred third-party manager’s contract, CIP and TPM portfolio management services Wrap Fee Program account managers have internal procedures in place, as described within each manager’s client account contract and other account opening documents, to conduct periodic reviews of client accounts to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Annuity Management Services Accounts Annuity management services accounts are reviewed no less than annually, following the above review parameters as applicable to the account type established. Digital Asset Services Accounts Digital asset services accounts are reviewed no less than annually, following the above review parameters as applicable to the account type established. Financial Planning & Consulting Services Financial planning services documents are reviewed prior to service delivery. No account is required to be established to partake in this advisory service. Additional reviews will be conducted upon client request. We recommend that clients contact us for reviews, at a minimum, based on changes in their circumstances, which may include but are not limited to marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability, among others. We recommend meeting with clients more frequently as they approach a job transition or retirement to review and update their plans if needed. Written updates to the financial plan may be provided in conjunction with the review. Updates to a financial plan may be subject to our then-current hourly rate, which the client must approve in writing before the update. 49  Factors that will trigger a non-periodic review of client accounts include material market, economic or political events, client complaints, transactions flagged by a Designated Supervisor, and changes in the client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Financial plans are reviewed upon completion and before delivery to the client. Retirement Plan Services Retirement plan services accounts are reviewed no less than annually, following the portfolio management services account review parameters as applicable to the account type established. Content & Frequency of Regular Reports Provided to Clients Firm Statements & Reports RMR client communications occur at several levels. Client meetings will generally be held annually to review the client’s account and the appropriateness of its holdings. Meetings, telephone calls, emails, and letters will provide information from time to time as circumstances warrant. Market commentaries, articles and newsletters on investment and financial planning topics can also be provided to all clients throughout the year. While clients will not receive additional reviews, statements, and reports outside of those required under Rule 206(4)-2 of the Adviser’s Act or beyond the services contracted for in the client’s Agreement, additional reporting may be made available on an ad-hoc basis as agreed to between RMR and the client. Custodial Statements & Reports At the time of account inception, clients will direct their Qualified Custodian to send them statements at least quarterly, (1) reflecting all account transactions that occurred during the previous reporting period, the funds, securities, and other property in the account at the end of the period, and (2) provide RMR duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. The client’s Qualified Custodian will then provide quarterly account statements describing all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the period beginning and ending. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Clients may also receive trade confirmation documents for all transactions by their custodians for each buy or sell transaction within their account. Client statements will be sent to the address provided by the client to the Adviser or such other address to which the client may request in writing that they be sent. RMR urges clients to promptly review any statements they receive from their custodian upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate blended benchmark applicable to the type of investments held in the account and any periodic report or information from us. The information obtained from RMR may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodology of particular securities. RMR encourages clients to ask us any questions about the custody, safety, or security of their assets or any statements received. If a client believes there are any inaccuracies or discrepancies in any reports received, or if they do not understand the information reflected in any document received, they should promptly, and in all cases before the next statement cycle, report their concerns to RMR. Unless the client indicates otherwise, by promptly notifying us in writing of concerns regarding statements received or specific investment restrictions on the account(s), investments made in line with the client's stated investment objectives RMR recommends or makes on behalf of a client shall be deemed to conform with the client's investment objectives. ITEM 14: CLIENT REFERRALS & OTHER COMPENSATION ____________________________________________________________________________________________________ Preferred Qualified Custodians As indicated in Item 12: Brokerage Practices, RMR receives an economic benefit from our preferred Qualified Custodians through the support products and services available to us and other independent investment advisers who also recommend their clients maintain accounts with the Qualified Custodians. Because of such arrangements, we benefit from referral arrangements because the cost of these services would otherwise be borne directly by our firm. While clients do not pay more for assets maintained at our preferred Qualified Custodians, clients should consider these conflicts - the products and services provided by each custodian, their benefits to us, and any related conflicts of interest described 50  herein, when making a custodian selection. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account custodian.) Economic Benefits Provided by Third Parties Custodians and certain mutual funds participate in activities designed to help facilitate the distribution of their products by providing RMR’s Investment Professionals with sales awards and other prizes, instruction about their products, and through marketing activities or instructive programs including, but not limited to, fund representative conference attendance, one-on-one marketing efforts and/or due diligence presentations. When RMR participates in these activities, the Adviser receives additional compensation such as 12b-1 fees disclosed in a fund’s prospectus fee table and expense reimbursements. These payments are generally paid from the fund or fund affiliate’s assets. Therefore, certain expenses not paid out of fund assets would not appear in a fund’s expense table. No portion of these payments to RMR or an IAR is made using brokerage commissions generated by the fund. It is important to understand that no payments other than 12b-1 fees received by RMR are paid or directed to any IAR recommending these funds. RMR IARs do not receive a greater or lesser percentage of the commission for sales of mutual funds. You should be aware that different funds charge different commissions. Because RMR IARs receive no direct increase or change in the percent of commissions they are paid for selling shares of one fund over another, we do not believe that they are subject to a conflict of interest based on the percent of commission each IAR receives when recommending one fund’s shares over another’s. However, the marketing and educational activities paid for by a fund could lead our IARs to focus more on those funds. Promoter Relationships RMR has entered into solicitor (“Promoter”) relationships with qualified individuals who are paid to refer clients to the Adviser, which can result in the provision of investment advisory services. When engaging Promoters, RMR will ensure all are licensed and otherwise qualified as required. Unlicensed Promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all Promoter arrangements are defined by a contract between the Promoter and RMR, which sets forth the terms of the Agreement and form of compensation to the Promoter, a percentage of the advisory fees received from referred clients. As a consultant and independent contractor, and not an employee of Advisor, the Promoter will use its best efforts to solicit and refer as clients to Advisor those individuals or entities which it believes are in the best interest of the client to be introduced to the investment advisory services provided by Advisor. The Promoter has no authority to accept any client(s) on behalf of the Adviser, and the Adviser has no responsibility to accept any prospective client referred by the Promoter. The Promoter’s primary role is to introduce and assist each prospective client in establishing a relationship with the Adviser, including introducing prospective clients and providing information about RMR. The Promoter’s services may also include periodic contacts to update client information on behalf of the Adviser. The Promoter will keep confidential any client information obtained in connection with this arrangement, which will not be disclosed without the appropriate consent obtained. For the solicitation services the Promoter provides, RMR will either pay a flat one-time fee for any solicited client or a percentage of investment advisory fees received from any solicited client over a period agreed upon in the Promoter’s contract with RMR. This fee is not passed on to the client. RMR will also make available and refer clients to the FICA® | For Advisors Cash Management Program sponsored by StoneCastle Cash Management, LLC and earn a referral fee from StoneCastle if clients participate. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss” for complete details.) Conflicts of Interest Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the Promoter's referral. Additionally, Promoters that refer business to more than one investment adviser could be financially incentivized to recommend advisers with more favorable compensation arrangements; comparable services and/or lower fees may be available through other firms. Accordingly, RMR requires its Promoters to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and 51  compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. RMR satisfies similar requirements when serving as a StoneCastle Cash Management, LLC Promoter. Besides our clients' fees and those disclosed herein, RMR does not receive any other additional economic benefits. Further details of how we mitigate conflicts of interest can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. A copy of RMR's Code of Ethics is available for free review to any client or prospective client upon request. ITEM 15: CUSTODY ____________________________________________________________________________________________________ Custodial Practices RMR does not have physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts. The Adviser prohibits the firm or its Associates from obtaining, accepting, or maintaining custody of client funds, securities, or assets in any manner. Clients will keep all account cash, securities and other assets with a Qualified Custodian governed by a separate written brokerage and custodial account agreement between the Qualified Custodian and client. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. RMR is not authorized to withdraw any money, securities, or other property from any client custodial account, in the client's name or otherwise. The independent Qualified Custodian will typically directly debit the client’s account(s) to pay RMR’s Advisory Fees. To authorize this, the client will directly provide written limited authorization instructions and request their Qualified Custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. The client will provide these instructions separately on the Qualified Custodian's form. Although RMR does not have physical custody of client funds or securities, the ability to deduct advisory fees from client accounts causes our firm to exercise limited custody over these assets. Wire Transfers, Check-Writing Authority & Standing Letters of Authorization RMR or persons associated with our firm may affect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, or we may have signatory and check-writing authority for client accounts if the client has provided us with written authorization to do so. Such written authorization is known as a “Standing Letter of Authorization” (or “SLOA”). An adviser with authority to conduct third-party wire transfers or sign checks on a client's behalf has access to the client's assets and, therefore, has custody of the client's assets in any related accounts. However, RMR is not required to obtain a surprise annual audit, as otherwise would be necessary by reason of having custody, as long as we meet the following criteria: 1. the client provides a written, signed instruction to the Qualified Custodian that includes the third party's name and address or account number at a custodian, 2. the client authorizes us in writing to direct transfers to the third party either on a specified schedule or from time to time, 3. the Qualified Custodian verifies the client’s authorization (i.e., signature review) and promptly provides a funds transfer notice to the client after each transfer, 4. the client can terminate or change the instruction, 5. RMR has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party, 6. we maintain records showing that the third party is not a related party to us or located at the same address, and 7. the client’s Qualified Custodian sends them, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Annuity management services and TPM Program services clients will follow their third-party Program manager's custody and SLOA procedures. Clients should refer to the third-party manager’s contract for exact details. Custodial Account Statements Clients will receive account statements at least quarterly from the Qualified Custodian(s) holding their funds and securities to their e-mail or postal mailing address of record as provided to the Qualified Custodian. The reports will reflect all account 52  positions, transactions, and disbursements made, including the amounts of any assessed advisory fees deducted from their account(s) during each billing period. Clients should review statements provided by their custodian promptly upon receipt. RMR urges clients to compare the statements they receive directly from their custodian with the information outlined in any reports or periodic portfolio statements received from the adviser to ensure the accuracy of all account transactions. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. RMR encourages our clients to promptly raise any questions with us about the custody, safety, or security of their assets. Clients should carefully review account statements for accuracy. We will also provide statements to clients reflecting the amount of the advisory fee deducted from their accounts. Clients should also compare our statements with their account custodian(s) statements to reconcile the information reflected on each report. Clients should contact their IAR or RMR immediately if they have questions regarding their account statement(s) or did not receive a statement from their Qualified Custodian. ITEM 16: INVESTMENT DISCRETION ____________________________________________________________________________________________________ Account Management Style RMR advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for account management style. Discretionary Authority Under discretionary account management authority, RMR will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting RMR complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as RMR deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their IAR may agree to from time to time - collectively, the “Investment Guidelines.” We will not wire or transfer funds to third parties without your written approval. Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and RMR will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Some clients may engage their IAR to manage securities on a non-discretionary account management authority. Non- discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by RMR or their custodian to establish the account trading authorization. RMR will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as 53  the client and their IAR may agree to from time to time. Under this management style, RMR must receive approval from the client before placing any trades in the client's account. As a result, until RMR reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and RMR engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with the jointly agreed upon investment objectives, RMR reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, RMR will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. RMR seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Third-Party Manager Annuity Management Services Third-party manager annuity management services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. TPM investment accounts are offered only on a discretionary basis. RMR has the discretion to select and replace the investment manager, and the investment manager has the discretion to choose and manage the assets in the client’s investment account. Discretionary authority is typically granted by the investment management agreement you sign with our firm, a power of attorney, and/or trading authorization forms. If you enter into non-discretionary arrangements with our firm, we will obtain your verbal approval before executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any recommendation provided by our firm on a non-discretionary basis. ITEM 17: VOTING CLIENT SECURITIES ____________________________________________________________________________________________________ Proxy Voting RMR will not ask for or accept voting authority for client securities and is not obligated to forward proxy notices to clients or their agents. Clients will receive proxy material directly from the security issuer, their Qualified Custodian, or the Insurance Company and/or Insurance Company’s approved Custodian(s). Clients are responsible for exercising their right to vote for proxies. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the Plan Fiduciary holds proxy voting authority and responsibility for the Plan account in accordance with the requirements of Plan documentation. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the Plan document. RMR may recommend and refer certain clients to third-party asset allocation or managed account programs. Depending on the referred manager’s proxy voting policies and procedures - and as disclosed within the TPM’s Form ADV 2A and separate advisory contract, clients participating in one of these programs may appoint the referred manager as their agent and attorney- in-fact with discretion to vote proxies for securities held in their account. Clients should carefully review the TPM’s disclosure brochures and advisory contract to understand the referred manager’s proxy voting policies and procedures. While RMR will assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because it supplies client information about a particular proxy vote in any of the above situations. It is the client's obligation to vote for their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. RMR has no duty or obligation to evaluate a client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, 54  determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client’s account or securities issuers. RMR does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client’s account or the issuers of such securities. RMR is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client’s responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. ITEM 18: FINANCIAL INFORMATION ____________________________________________________________________________________________________ Balance Sheet RMR does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this Brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither RMR nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. RMR has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years RMR has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of RMR's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's website at www.adviserinfo.sec.gov for a free and simple search tool to research RMR and its Investment Professionals, Management Members, Officers, and firm Principals. ITEM 19: REQUIREMENT FOR STATE REGISTERED ADVISERS ____________________________________________________________________________________________________ RMR’s registration with the Securities and Exchange Commission became effective on October 14, 2014; therefore, the requirements for Item 19 do not apply to the firm. ITEM 20: ADDITIONAL INFORMATION ____________________________________________________________________________________________________ Business Continuity Plan Securities industry regulations require that investment advisers inform their clients of their plans to address the possibility of significant business disruption ("SBD") from unexpected events such as power outages, natural disasters, or other such occurrences. Firms must be able to provide continuous and uninterrupted services to their clients, and critical systems must function during such incidents so that the firm can resume operations as quickly as possible, given the SBD's scope and severity. Firms must meet their obligations to clients, counterparties, and others during any emergency or SBD. Since the timing and impact of disasters and disruptions are unpredictable, firms must be flexible in acting. Well thought out, advanced preparations and effective procedures can significantly minimize downtime in the face of a disaster or outage. To satisfy this requirement, RMR has developed a comprehensive Business Continuity Plan ("BCP" or "Plan") to detail how it will react when faced with such conditions. While no contingency plan can eliminate all service interruption risks, RMR's BCP strives 55  to set forth the firm's policies and practices under various SBD situations and mitigate all credible threats while keeping up with changes to the Adviser's business, structure, operations, and location. Firm Policy RMR's guiding principle is that protecting clients, employees/Associates and family members always takes precedence over preserving business assets. Accordingly, RMR's policy is to respond to an SBD by first safeguarding the lives of its clients, employees (Associates), family members, and others, and then firm property. In the event of an SBD, RMR intends to make a quick financial and operational assessment, protect and preserve all advisory books and records, and promptly recover and resume business operations. If it is determined that the firm cannot continue its business, we will assure customers prompt access to their funds and securities. Recovery times may vary depending on the nature and severity of the disruption; however, the objective of restoring mission-critical operations is 0-72 hours. BCP Summary RMR's BCP - reviewed, tested regularly, and updated no less than annually, anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the firm's ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and may include terrorist attacks, floods, or wide-scale regional disruptions. RMR's BCP addresses all mission-critical systems, office closing and relocation procedures, and employee alternative physical locations. Regulatory reporting/alternate communications between the Adviser and its clients, Associates, critical business constituents, banks, counterparties, regulators, and others are detailed to preserve uninterrupted communication. The BCP also defines data backup and recovery procedures (hard copy and electronic) and succession planning in the event of crucial personnel absence. Further, RMR requires its primary internal and external vendor systems providers to periodically verify and test their backup capabilities to promptly provide the necessary information and applications to continue or resume business in emergencies and other SBD situations. RMR carries out its BCP under the direction of the Disaster Recovery Executive Coordinator (the "DREC"). The DREC is responsible for making an immediate preliminary assessment of the nature and extent of any disruption and communicating the firm's BCP to employees, clients, critical business constituents, and regulators. When an internal or external event, either minor or significant, occurs or appears to be developing, RMR's DREC will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement the Adviser’s BCP emergency procedures, secure the headquarters as much as possible, and advise all employees to contact the firm @ 201.836.2460. If the firm’s primary telephone line is disrupted, the lines will be forwarded to an alternative line with this information provided. If a business disruption affects only the Adviser or a specific area within the firm and the primary office is inaccessible, RMR will transfer its operations to a local worksite and advise of the location. If a disruption affects our business district, city, or region, operations will be transferred to an alternate worksite outside the affected area. Telephone service will continue, and regular work processes will resume at its alternate location(s). RMR will continue conducting business in either situation and notify its clients about maintaining contact through a message recorded on its main phone number and website posting. RMR does not maintain custody of client funds or securities; clients maintain all account assets at an independent Qualified Custodian with whom they can always communicate and access assets directly, with or without the Adviser's intervention. In the event of an SBD, RMR will help facilitate client access to these external accounts by resolving client questions, providing status updates, and offering up-to-date contact information to assist clients in reaching their custodians and – if applicable, for the type of account opened, any third-party advisers who manage their accounts ("TPAs") directly. RMR will also relay communications to custodians and TPMs on the client's behalf. 56  If you cannot reach us after an SBD as you usually do, please check your email. We will attempt to provide a status update along with updated contact information. If our office number is unavailable and you have questions about your account(s), please contact the Qualified Custodian using the number listed on your account statements. If it is determined that the firm cannot continue its advisory business, clients will be assured swift access to their funds, securities, and prepaid fees by direct contact with their respective Qualified Custodians and TPAs, as applicable for the type of account established. Contact Us RMR's BCP is designed to allow the firm to continue to provide the quality service its clients have come to expect. Please contact us at 201.836.2460 with any questions about our practices for this topic or to request a complete copy of our BCP document. A copy of our BCP disclosure is also posted on our website and available for review at www.rmrwealth.com. Information Security Program RMR maintains a Written Information Security Program (“WISP”) to reduce the risk of clients' personal and confidential information breaches. Please contact us directly at 201.836.2460 with any questions about this topic. Privacy Practices Your relationship with us is based on trust and confidence. This privacy policy ("Privacy Policy" or “Policy”) describes the ways RMR collects, stores, uses, discloses, and protects the privacy of the personally identifiable and non-personally identifiable information we may collect from you or that you may provide. Our goal is to treat the information you furnish us with the utmost respect following this Policy and safeguard and protect the information you have provided securely and professionally. We remain committed to this objective. What is Personally Identifiable Information? Personally identifiable information ("PII") describes the information associated with you. It can be used to identify you and includes your name, address, phone number, zip code, e-mail address, and other similar data. Non-personally identifiable information (“Non-PII”) does not identify a specific person or is publicly available. Non-PII may include, for example, your IP address, browser type, domain names, access dates, and similar information. Categories of Information We Collect The personal information we collect and share will depend on the product or service. Confidential personal data collected about you can include but not be limited to: • • • information we receive from you via applications or other forms, such as your name, address, phone or social security number, occupation, assets, income, investment experience and other financial and family information, and information about your transactions with us or the brokerages, banks, and custodians with whom you hold investment or cash accounts, including account numbers, holdings, balances, transaction history, and other financial and investment activities. How We Collect Your Information We collect your personal information; for example, when you seek investment advice, tell us about your investment portfolio(s), open an account, make account deposits or withdrawals, or provide your income details. We also collect your personal information from others, such as other companies. We do not knowingly solicit information from or market our products or services to children. How We Use Your Information We may use information that we collect about you or that you provide to us, including any personal information, for any purpose, including but not limited to: compare information for accuracy and record verification, improve, modify, customize, and measure our services, • personalize our contact with you, or verify your identity when accessing our services, • • provide information, materials, products, or the services you request, • 57  • develop new products and services, • send you administrative messages, content, and other services and features in which we believe you may be interested, • provide you with information about our products and services, including while you are on our website online services or after you visit such online services, contact you for the potential purchase of insurance or other financial products, • • operate, provide, improve, and maintain our website to prevent abusive and fraudulent use of our website or enforce our Terms of Use and any other agreements between you and our firm, and for any other administrative and internal business purposes permitted by law. • Sharing Non-Public Personal & Financial Information Financial companies must share customers' personal information to run their everyday business and provide services. Even when required to do this, we are committed to the protection and privacy of your personal and financial information. We will share your personal information with only those non-affiliated third-party service providers authorized to use your data as necessary to support our business operations, such as: for marketing services, to our attorneys, accountants, or compliance consultants, to provide customer service or resolve customer disputes, to provide data storage, payment, or technology support and services, or for risk solution provisions, analytics, or fraud prevention, in connection with a sale or merger of our business, or in any circumstance that has your instruction or consent. • when necessary to complete an account transaction, such as with the clearing firm or account custodians, • when required to maintain or service an account, • • when requested by a fiduciary or beneficiary on the account, • when required by a regulatory agency or for other reasons required or permitted by law, • • • • • • The personal information we share for business purposes may include any categories of personal information identified in this Privacy Policy that we may collect. Protection of Personal Information We maintain various security measures to protect against the loss, misuse, and alteration of the information under our control. We restrict access to personal and account information to only those employees who need to know the information to provide products or services to you. Physical, electronic, and procedural safeguards are in place to guard client data using security measures that comply with federal law, such as computer protection, secured files, and buildings. Finally, although no business can wholly guarantee that information will remain free from unauthorized access, use, disclosure, or alteration, we make consistent, diligent, and good-faith efforts to maintain information security, utilizing safety measures designed to prevent unauthorized access or usage. Internet Use You can visit us on the Internet at www.rmrwealthbuilders.com without telling us who you are or revealing any information about yourself, including your e-mail address. In this case, our web servers may collect the domain name you used to access the Internet, such as www.aol.com, the website you came from and visited next, and other data. We use this data to monitor site performance and make the site more accessible and convenient. Sharing Information & Consumer Choice When you provide information to us, we may share your information, to the extent provided by applicable law, with any affiliated companies and third parties to fulfill your requests and offer you other services that may interest you. Your information is not shared with any third party unless you request it or it is legally permitted. Under no circumstance will we sell or transfer your information to any ad network, ad exchange, data broker, or other advertising or monetization-related service. We may also aggregate statistics about our customers, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, the statistics will exclude any personal information that identifies individuals. We will not provide your personal information to mailing list vendors or Promoters. We require strict confidentiality in our agreements with unaffiliated 58  third parties that need access to your personal data, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your records as the law permits. Federal law allows you to limit sharing information about your creditworthiness for affiliates' everyday business purposes, affiliates from using your information to market to you, and sharing for non-affiliates to market to you. State and international laws and individual companies may provide additional rights to limit sharing. (Please contact us directly for specific state and residence privacy requirements.) Notification In the Event of A Data Breach Although we make reasonable faith efforts to maintain your information securely, no firm or individual can guarantee that shared information will remain free from unauthorized access, use, disclosure, or alteration. If an unauthorized party breaches your personally identifiable information, we will comply with applicable state laws in notifying you of the breach. Former Customers Personally identifiable information about you will be maintained while you are a client and for the crucial period after that, as federal and state securities laws require if you close your account(s) or become an inactive customer. After that time, information may be destroyed. Accessing or Correcting Your Information You may access the data collected by us by sending a request to the below address. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the person's identity seeking the correction. If you wish to access, remove, or correct any personally identifying information you have supplied to us or have any questions about this Privacy Policy, you may contact us by sending a letter to the address on the cover of this Brochure. Changes to Our Privacy Policy We reserve the right to modify or supplement RMR's Privacy Policy statement at any time. If we make any material changes, we will notify our existing clients and update our website to reflect such changes, including disclosing the Policy's last revised date. Questions Please contact us as follows if you have any questions or concerns regarding our privacy business practices: RMR WEALTH BUILDERS, INC. 111 Grove Street Suite 203 Montclair, New Jersey 07042 Telephone: 201.836.2460 www.rmrwealthbuilders.com 59