Clients will engage an independent broker-dealer/custodian to maintain their account(s) and, as such, RS Crum Inc. will not have physical custody of Client assets, monies or securities. However, RS Crum Inc. maintains a limited power of attorney over clients’ accounts when clients authorize us to deduct our

management fees directly from the client’s account. Since RS Crum Inc. may withdraw investment

advisory fees directly from Clients’ accounts, RS Crum Inc. is considered to have custody in a limited capacity. All checks or wire transfers for deposit to client accounts are required to be made out to or sent to the account custodian.

Clients will receive statements directly from their qualified custodian at least quarterly. The statements will reflect the client’s funds and securities held with the qualified custodian as well as any transactions that occurred in the account, including the deduction of our fee.

Clients should carefully review the account statements they receive from the qualified custodian. When clients receive statements from RS Crum Inc. as well as from the qualified custodian, they should compare these two reports carefully. Clients with any questions about their statements should contact us at the address or phone number on the cover of this brochure. Clients who do not receive a statement from their qualified custodian at least quarterly should also notify us.

RS Crum Inc. is deemed to have custody of clients’ funds or securities when clients have a standing letter of authorization (“SLOA”) with their custodian to move money from a client’s account to a third-party and, under that SLOA, authorize us to designate the amount or timing of transfers to those specifically authorized account(s) with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow.