Registered investment advisers and their supervised persons are required to disclose material facts regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr. Papa or the integrity of RS Crum, Inc.’s management. Not applicable; Mr. Papa has no legal or disciplinary action applicable to his status and / or registration.

RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of compensation are fees paid to the Firm directly by the client. Neither RS Crum, Inc. nor Mr. Papa accepts commissions. Therefore, they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading adviser. Although Mr. Papa is a member of several industry trade associations, he does not have any affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients.

Mr. Papa receives no other compensation besides his salary, bonus, and other customary employment benefits.

RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling 949-428-9696. Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of others will exercise reasonable supervision over those subject to their supervision or authority to prevent violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to them. RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and allocate resources for client care, services, and business priorities. In addition, the Firm requires Supervised Persons and employees to complete regular financial disclosures and review, at least annually, the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility.