Form ADV Part 2A

A. Description of the Advisory Firm

River Rose Financial LLC (hereinafter "River Rose" or the "Firm") is a limited liability company organized in the State of Colorado, with its principal place of business in Snowmass Village, Colorado. The Firm was founded to deliver institutional-quality, systematic investment management to high-net-worth individuals and families in the Roaring Fork Valley and greater Aspen area. Thomas MacPherson is the sole principal owner, Chief Compliance Officer, and Investment Adviser Representative of River Rose Financial LLC.

B. Types of Advisory Services

The Firm's core philosophy is rooted in rules-based, data-driven portfolio management. Every investment decision is governed by a written Investment Policy Statement and a quantitative analytical framework drawing on applied data science, modern portfolio theory, and macroeconomic analysis. River Rose Financial does not make ad hoc allocation decisions based on media narratives or emotional judgment. Tactical allocation adjustments and hedging strategies, when employed, are executed pursuant to pre-defined, written criteria — not reaction to short-term market noise.

Portfolio Management Services

River Rose offers ongoing discretionary portfolio management tailored to each client's goals, time horizon, risk tolerance, tax situation, and account type. Services include, but are not limited to:

• Risk tolerance assessment and financial goal documentation
• Development of a written Investment Policy Statement (IPS)
• Strategic asset allocation and ETF universe selection
• Systematic, rules-based rebalancing (threshold- and/or calendar-triggered)
• Covered call overlay strategy management (where appropriate)
• Fixed income reserve management and systematic cash deployment
• Quarterly performance reporting with benchmark comparison
• Annual IPS review and financial planning consultation

River Rose generally requires discretionary authority to execute transactions without prior client consultation for each trade. Non-discretionary arrangements are available at the client's election. The Firm may also provide advisory services with respect to held-away assets, including employer-sponsored retirement plans, equity compensation accounts, and other accounts outside the primary custodial relationship.

Rollover and Retirement Account Advisory Services

River Rose Financial may provide advice in connection with rollovers from employer-sponsored retirement plans, including 401(k) and 403(b) plans, to Individual Retirement Accounts (IRAs). When providing such advice, the Firm acts as a fiduciary within the meaning of IRC Section 4975 and applicable Department of Labor guidance. Clients should be aware that a rollover from an employer-sponsored plan may not always be in their best interest. River Rose Financial will provide a written analysis of the costs, benefits, and alternatives prior to any rollover recommendation.

Financial Planning and Consulting Services

River Rose provides standalone financial planning and consulting on a project or hourly basis. Engagements may include investment planning, retirement projections, tax-efficiency analysis, portfolio audit and review, asset allocation recommendations, and financial literacy education. Financial planning may be provided on a one-time or ongoing retainer basis and does not necessarily include discretionary portfolio management.

Individual Equity Research and Valuation Analysis

For eligible clients, River Rose provides fundamental equity research and valuation analysis as a supplement to ongoing advisory relationships or as a standalone project engagement. Research content is distributed based on the client's documented risk profile and suitability tier. Individual equity research does not constitute a solicitation to buy or sell any specific security.

Market Currents Platform

River Rose Financial operates a proprietary macroeconomic research platform (Market Currents) delivering institutional-quality briefings covering equity markets, interest rates, inflation, employment conditions, yield curves, and corporate valuations. The platform is powered by FRED API data and River Rose's internal quantitative research framework. Subscription access is complimentary to the general public. Subscription access does not constitute an investment advisory relationship, does not create a fiduciary duty between River Rose Financial and the subscriber, and does not include personalized investment advice. Subscribers should not rely on Market Currents content as a substitute for individualized financial advice tailored to their specific circumstances.

C. Client Tailored Services and Client Imposed Restrictions

River Rose tailors its advisory services to each client's specific circumstances through the Investment Policy Statement process. Clients may impose restrictions on investing in certain securities or types of securities. Such restrictions will be documented in the client's IPS. If imposed restrictions prevent River Rose from properly servicing the account or require material deviation from the Firm's systematic investment framework, River Rose reserves the right to decline or discontinue the advisory relationship.

E. Assets Under Management

River Rose Financial LLC is a newly registered investment adviser. Discretionary and non-discretionary assets under management will be reported in the Firm's annual Form ADV update. Current AUM figures are available upon request.

A. Fee Schedule

River Rose Financial charges an annual advisory fee calculated as a tiered percentage of assets under management, assessed quarterly in arrears using the client's average daily account balance for the quarter. Fees are calculated on a marginal basis — each rate applies only to the portion of assets within that tier, not to the entire account balance (similar to the U.S. federal income tax bracket system).

For example, a client with $1,500,000 in assets under management would be charged 1.25% on the first $1,000,000 and 1.00% on the remaining $500,000, resulting in a blended effective rate of approximately 1.17%.

Fees are generally negotiable and may be adjusted at River Rose's discretion based on client circumstances, relationship complexity, household AUM, or portfolio characteristics. Clients may terminate the advisory agreement without penalty within five business days of signing. Thereafter, either party may terminate upon 30 days' written notice, with fees prorated to the effective termination date.

Financial Planning and Consulting Fees

Hourly engagements require a signed engagement letter prior to commencement of services. For larger project engagements, River Rose Financial may require a deposit of up to 50% of the estimated project fee prior to commencement of services. Any advance deposit will be applied against hours billed and refunded on a prorated basis for any unrendered services upon termination.

Market Currents

Subscription access does not constitute an investment advisory relationship.

B. Discount and Household Policies

• Multi-Account Household Discount: Clients with aggregate household AUM exceeding $2,500,000 across multiple accounts may qualify for blended fee rates.
• Introductory Discount: First-time hourly consulting clients receive 20% off their initial engagement (maximum 2 hours).
• Negotiated Arrangements: River Rose reserves the right to negotiate fees on a case-by-case basis, fully disclosed in the client's advisory agreement.

C. Payment of Fees

AUM advisory fees are withdrawn directly from client accounts at the qualified custodian, with written authorization, on a quarterly basis in arrears. Where River Rose provides advisory services with respect to held-away accounts not custodied at Altruist, fees are invoiced directly to the client on a quarterly basis based on the account's reported market value.

D. Client Responsibility for Third-Party Fees

Clients are responsible for all third-party fees, including custodian charges, brokerage commissions, ETF expense ratios, transaction fees, and wire transfer charges. These costs are separate from and in addition to River Rose's advisory fees.

E. Prepayment of Fees

River Rose does not collect AUM-based advisory fees in advance. Fixed and hourly consulting fees collected in advance will be refunded on a prorated basis consistent with the work completed at the time of termination. Refunds will be processed within fourteen days via check or return deposit.

F. Outside Compensation for the Sale of Securities to Clients

Neither River Rose Financial LLC nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges, 12b-1 fees, or service fees from the sale of mutual funds or other securities. River Rose is a fee-only registered investment adviser.

A. Methods of Analysis and Investment Strategies

River Rose Financial employs a multi-layered, data-driven analytical framework integrating the following methodologies:

• Quantitative and Data Science Analysis: Statistical modeling, macroeconomic factor analysis, and quantitative portfolio construction via the Market Currents platform, which aggregates FRED API data, equity market indicators, yield curve data, employment statistics, and inflation metrics.
• Modern Portfolio Theory (MPT): Markowitz mean-variance optimization to construct diversified portfolios targeting efficient risk-return tradeoffs calibrated to each client's risk tolerance tier.
• Macroeconomic Fundamental Analysis: Continuous monitoring of GDP growth, labor market conditions, inflation trends (CPI, PCE, PPI), credit spreads, yield curve dynamics, and Federal Reserve policy.
• Technical Analysis: A supplementary input for rebalancing timing and options strategy management. River Rose does not rely solely on technical analysis for portfolio allocation decisions.

Key strategies employed include strategic ETF-based asset allocation, systematic rebalancing, covered call overlay (where applicable), fixed income reserve and drawdown deployment protocols, and long-horizon custodial account management.

B. Material Risks Involved

Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Past performance is not indicative of future results.

• Quantitative Model Risk: Quantitative strategies may perform differently than expected due to model assumptions, data limitations, or structural regime changes. No model guarantees future performance.
• Market Risk: Broad market declines may reduce portfolio values regardless of holdings quality.
• Interest Rate and Inflation Risk: Fixed income securities are sensitive to interest rate changes. Stagflationary environments pose particular challenges to balanced portfolios.
• Options Strategy Risk: The covered call strategy caps upside participation in strong equity rallies. Options positions may be exercised against the client, resulting in the forced sale of equity at the strike price.
• Custodial Account Legal Risk: Assets in UGMA and UTMA accounts are irrevocable gifts to the minor beneficiary, who gains full, unrestricted control upon reaching the age of majority.
• Concentration and Liquidity Risk: Clients who impose restrictions or hold concentrated positions outside the advisory relationship may face elevated concentration risk.
• Systematic Rules Risk: Mechanical rule adherence may produce suboptimal outcomes in environments where human judgment may have performed better.
• Artificial Intelligence and Quantitative Model Risk: The Firm's analytical framework incorporates quantitative tools and data-driven models that carry inherent limitations, including potential for anomalous outputs, data quality issues from third-party providers, and sensitivity to market regime changes outside historical parameters.

C. Risks of Specific Securities Utilized

• Exchange Traded Funds (ETFs): Subject to market risk, tracking error, and liquidity risk. River Rose generally utilizes plain-vanilla, non-leveraged ETFs tracking broad market indices.
• Fixed Income Securities: Subject to interest rate risk, credit risk, inflation risk, and liquidity risk. Longer-duration instruments carry greater sensitivity to rate changes.
• Precious Metals and Real Asset ETFs: Subject to commodity price volatility, regulatory changes, and currency fluctuations.
• Non-U.S. Securities: Introduces currency risk, geopolitical risk, and differing regulatory and accounting standards.

A. Broker/Dealer Registration

Neither River Rose Financial LLC nor its supervised persons are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer.

B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser

Neither River Rose Financial LLC nor its supervised persons are registered as, or have pending applications to become, a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser.

C. Material Affiliations and Potential Conflicts of Interest

Thomas MacPherson, the principal of River Rose Financial LLC, maintains the following outside business activities and prior affiliations:

• River Rose Intelligence, LLC — a separate Colorado LLC conducting proprietary algorithmic trading exclusively with the principal's personal capital. No client assets of River Rose Financial are involved. The Firm manages this conflict by maintaining complete legal and operational separation of client assets from all proprietary trading activity, and by ensuring that personal trading never disadvantages or precedes transactions in client accounts.
• Aspen Dev Co — Thomas MacPherson serves as Chief Technology Officer in a limited administrative capacity. This role does not involve investment advisory activity or client solicitation.
• TRI&TRI Coaching LLC — Thomas MacPherson is the Founder and Head Coach of an endurance sports coaching business. This activity is entirely unrelated to investment advisory services.
• The Aspen Triathlon Club — Thomas MacPherson served as Chairman of this 501(c)3 non-profit from January 2020 through December 2021. This role was voluntary and has concluded.

D. Selection of Other Advisers or Managers

River Rose Financial LLC does not utilize or select third-party investment advisers or sub-managers. All client assets are managed directly by the Firm.

A. Code of Ethics

River Rose Financial LLC has adopted a written Code of Ethics governing the conduct of all supervised persons, addressing: fiduciary duties, prohibition on insider trading, personal securities transaction reporting and pre-clearance, conflict of interest identification, gifts and entertainment, client confidentiality, and compliance with applicable securities laws.

All prospective and current clients have the right to receive a copy of this Code of Ethics at any time and at no charge.

B. Recommendations Involving Material Financial Interests

River Rose Financial LLC does not recommend that clients buy or sell any security in which River Rose or any related person has a material financial interest.

C. Investing Personal Money in the Same Securities as Clients

Thomas MacPherson's core personal portfolio is invested in the same ETFs and asset classes that form the foundation of client portfolios. Alignment of interest is structural. A separate, smaller portion of the principal's personal capital is allocated to River Rose Intelligence, LLC, a proprietary algorithmic trading entity operating independently of all client assets. Personal securities transactions are subject to pre-clearance and reporting requirements in the Firm's Code of Ethics.

D. Trading Securities At or Around the Same Time as Clients

Supervised persons may, from time to time, buy or sell securities for personal accounts at or around the same time as similar transactions are executed for clients. River Rose maintains policies to ensure fair sequencing and will never allow personal trading to precede or disadvantage client account transactions.

A. Factors Used to Select Custodians and/or Broker/Dealers

Custodians and broker/dealers are evaluated based on River Rose's obligation to seek best execution. Evaluation criteria include execution quality, commission and fee structure, platform reliability, reporting quality, breadth of available instruments, and custodial service standards. River Rose Financial recommends Altruist Financial Advisors LLC as its primary custodian — a registered broker-dealer and RIA-focused custodial platform offering commission-free trading, real-time account reporting, and full UGMA/UTMA account support.

B. Soft Dollar Benefits

River Rose Financial LLC does not receive research, products, or services other than execution from broker/dealers or custodians in connection with client securities transactions.

C–D. Brokerage for Client Referrals / Client-Directed Brokerage

River Rose Financial LLC does not receive client referrals from any broker/dealer in exchange for directing client brokerage. Clients may elect directed brokerage, acknowledging in writing that such direction may result in higher commissions, less favorable execution, or inability to participate in block trades.

E. Aggregating (Block) Trading

When River Rose buys or sells the same securities for multiple client accounts, it may aggregate orders to seek more favorable pricing. Block trades will be allocated among participating accounts on a fair and equitable basis.

A. Frequency and Nature of Periodic Reviews

All client advisory accounts are reviewed at least quarterly by Thomas MacPherson, Principal and Investment Adviser Representative. Reviews assess portfolio performance relative to benchmark, adherence to target allocation, rebalancing triggers, options positions where applicable, and alignment with the client's current IPS.

B. Triggering Events for Non-Periodic Reviews

Reviews may be triggered outside the quarterly schedule by: material changes in client financial circumstances (retirement, employment change, inheritance, divorce, relocation); significant market drawdowns exceeding defined IPS thresholds; changes in the interest rate or inflation environment; or at the client's request.

C. Client Reporting

Each advisory client receives: (i) quarterly account statements from the qualified custodian; (ii) a quarterly review from River Rose covering portfolio performance, benchmark comparison, fee summary, and portfolio activity; and (iii) complimentary access to the Market Currents research platform. Annual IPS review consultations are included.

A. Economic Benefits from Third Parties

River Rose Financial LLC does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to its clients.

B. Compensation to Non-Advisory Personnel for Client Referrals

River Rose Financial LLC does not currently maintain any solicitor or third-party referral fee arrangements. Should any such arrangement be established in the future, it will be fully disclosed to clients as required by applicable law.

A. Balance Sheet

River Rose Financial LLC neither requires nor solicits prepayment of more than $500 in fees per client six or more months in advance. The Firm is therefore not required to include a balance sheet with this brochure.

B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments

Neither River Rose Financial LLC nor its management has any financial condition that is reasonably likely to impair the Firm's ability to meet its contractual commitments to clients.

C. Bankruptcy Petitions

River Rose Financial LLC has not been the subject of a bankruptcy petition.

A. Principal Executive Officers and Management Persons

Business Background (Five Years)

*River Rose Financial LLC was established in February 2020 as a personal investment research and portfolio management framework, operating exclusively with the principal's personal capital. The Firm did not manage client assets or hold itself out as an investment adviser prior to initiating the registration process. Client advisory operations will commence upon effective registration with the Colorado Division of Securities.

Thomas MacPherson's investment philosophy is grounded in applied data science and systematic portfolio construction. He holds a Series 65 license and completed coursework for a Master of Applied Data Science from the University of Michigan with a specialization in Data Analytics, with coursework applied directly to portfolio construction methodology, risk modeling, time-series modeling, and investment analytics.

B. Other Business Activities

See Item 10.C for a full description of Thomas MacPherson's outside business activities, including River Rose Intelligence, LLC, Aspen Dev Co, and TRI&TRI Coaching LLC.

C. Performance-Based Fees

River Rose Financial LLC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of client assets.

D. Material Disciplinary Disclosures

There are no civil, administrative, or self-regulatory organization proceedings or arbitrations to report for any management person of River Rose Financial LLC.

E. Material Relationships with Issuers of Securities

Neither River Rose Financial LLC nor its management persons have any material relationship or arrangement with any issuer of securities.