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. Stark or the integrity of RS Crum Inc.’s management.

Not applicable; Mr. Stark 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.

In addition to Mr. Stark’s time spent on the activities of RS Crum, he also serves as a Personal Financial Counselor for Zeider’s Enterprises Inc, providing financial counseling to military personnel. Mr. Stark spends approximately 1 to 5 hours per month on the activities of Zeider’s Enterprises Inc.

Neither RS Crum Inc. nor Mr. Stark 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. Stark 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. Stark receives no other compensation besides his salary, bonus, and other customary employment benefits. Mr. Stark also receives an hourly fee for his time working for Zeider’s Military Financial Counseling.

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.