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 C. MacPherson is the sole principal owner, Chief Compliance Officer, and Investment Adviser Representative of River Rose Financial LLC.

Types of Advisory Services

The Firm's core philosophy is rooted in rules-based, data-driven portfolio management. River Rose Financial's investment process is grounded in a written Investment Policy Statement and a quantitative analytical framework drawing on applied data science, modern portfolio theory, and macroeconomic analysis. This framework is designed to guard against impulsive, narrative-driven, or emotionally reactive decision-making. While disciplined adherence to this framework is the Firm's standard practice, the Adviser retains discretion to exercise professional judgment where circumstances warrant, including consideration of factors that may not be captured by quantitative criteria alone. When employed, tactical allocation adjustments and hedging strategies are generally guided by pre-defined criteria intended to reduce reactivity to short-term market movements. These criteria serve as a governing framework, and the Adviser retains discretion to adjust, override, or forgo any such action based on professional judgment and factors that may not be reflected in the pre-defined criteria.

The Firm serves clients across the full spectrum of wealth complexity, with a primary focus on high-net-worth individuals and families managing sophisticated, multi-sleeve portfolios. River Rose Financial also works with clients seeking to establish systematic investment habits for the next generation through custodial accounts on behalf of minor beneficiaries. The Firm believes that rules-based, transparent investing is not a privilege reserved for the largest accounts, but that it is a discipline that compounds most powerfully when started early. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values, beliefs, or individual circumstances. Such restrictions are subject to Firm approval and will be documented in the client's IPS.

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/or ETF universe selection
• Systematic, rules-based rebalancing (threshold- and/or calendar-triggered)
• Covered call overlay strategy management (where appropriate for the client's risk profile)
• Fixed income reserve management and systematic deployment of cash reserves
• 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, enabling efficient implementation consistent with the client's IPS. Non-discretionary arrangements are available at the client's election.

River Rose Financial may also provide advisory services with respect to assets held in accounts outside of the Firm's primary custodial relationship, including employer-sponsored retirement plans, equity compensation accounts, existing brokerage accounts, and other held-away assets. Advisory fees for held-away accounts are calculated on the same tiered AUM basis as custodied accounts, applied to the reported market value of those assets as provided by the client or third-party account statements. Held-away account management is documented in the client's Investment Policy Statement and Investment Advisory Agreement.

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 for young adults and families. Financial planning may be provided on an hourly 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. Services include business quality assessment, competitive moat analysis, financial statement modeling, IP and legal risk review, valuation relative to comparable transactions, and scenario-based price target development. All legal and IP risk assessments are limited to publicly available information and do not constitute legal advice. Research content is distributed based on the client's documented risk profile and suitability tier, as established in the client's Risk Profile and Suitability Assessment. Individual equity research does not constitute a solicitation to buy or sell any specific security and is provided for informational purposes within the advisory consulting relationship. Standalone equity research engagements require a signed engagement letter and completion of a Risk Profile and Suitability Assessment prior to delivery of any research content.

Educational Seminars and Workshops

River Rose Financial may offer educational seminars, workshops, and presentations to the general public, community groups, and professional organizations on topics including investment principles, financial planning, retirement readiness, and financial literacy for young adults and families. These events are educational in nature. They do not constitute personalized investment advice, do not create an advisory or fiduciary relationship between River Rose Financial and any attendee, and should not be relied upon as a substitute for individualized financial advice tailored to a person's specific circumstances. Attendance does not obligate any participant to engage the Firm's services. To the extent any seminar is offered without charge, it may serve as a means of introducing prospective clients to the Firm.

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.

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 the Internal Revenue Code 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, and River Rose Financial will provide a written analysis of the costs, benefits, and alternatives prior to making any rollover recommendation. Rollover advisory services are subject to the same fee structure as ongoing portfolio management (See Item 5).

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.

Standard Portfolio Management Fees (AUM-Based)

River Rose Financial charges an annualized 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.

River Rose Financial's advisory fee is a blended rate calculated on a marginal basis, similar to the U.S. federal income tax bracket system. Each rate applies only to the portion of assets within that tier, not to the entire account balance. 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 annualized rate of approximately 1.17% for that billing period.

Fees are generally negotiable and may be adjusted at River Rose's discretion based on client circumstances, relationship complexity, household AUM, or portfolio characteristics. Any negotiated arrangement is fully disclosed in the client's Investment Advisory Agreement. The final fee schedule is provided to each client as a standalone document and incorporated by reference into the advisory agreement.

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 collected for consulting or project engagements will not exceed $500 for work not reasonably expected to be completed within six months of collection. Any deposit collected in advance will be applied against hours billed and refunded on a prorated basis for any unrendered services upon termination.

Market Currents

Access to Market Currents does not constitute an investment advisory relationship.

Payment of Fees

AUM advisory fees are withdrawn directly from client accounts at the qualified custodian, pursuant to the client's written authorization, on a quarterly basis in arrears. River Rose provides the client a written invoice itemizing (i) the fee amount, (ii) the formula used to calculate the fee, (iii) the billing period covered, and (iv) the value of assets on which the fee is based. Additional information related to the direct withdrawal of fees can be seen in Item 15 below.

Payment of fees for hourly consulting can be paid via check or electronic transfer.

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. See Item 12 for information on brokerage practices.

Prepayment of Fees

River Rose does not collect AUM-based advisory fees in advance. 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.

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.

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: River Rose's primary analytical approach applies statistical modeling, macroeconomic factor analysis, and quantitative portfolio construction. The Firm's proprietary Market Currents platform aggregates FRED API data, equity market indicators, yield curve data, employment statistics, and inflation metrics into a structured analytical framework used to inform the Firm's long-term strategic portfolio positioning. Shorter-term tactical decisions remain subject to the Adviser's discretion and professional judgment as described above.

Modern Portfolio Theory (MPT): River Rose applies Markowitz mean-variance optimization to construct diversified portfolios targeting efficient risk-return tradeoffs calibrated to each client's risk tolerance tier. Portfolio construction incorporates volatility floor constraints by risk tier to prevent infeasible optimization outcomes in stressed market environments.

Macroeconomic Fundamental Analysis: River Rose continuously monitors GDP growth, labor market conditions, inflation trends (CPI, PCE, PPI), credit spreads, yield curve dynamics, and Federal Reserve policy. This macro framework informs longer-term strategic asset allocation positioning and fixed income deployment protocols.

Technical Analysis: Technical analysis of price trends and volume may serve as a supplementary input for rebalancing timing and options strategy management. River Rose does not rely solely on technical analysis for portfolio allocation decisions.

Investment Strategies

Strategic ETF-Based Asset Allocation: Portfolios are built primarily using diversified, low-cost ETFs spanning domestic equities, international equities, fixed income across the yield curve, and real assets including precious metals. River Rose's primary portfolio construction approach utilizes diversified, low-cost ETFs for strategic asset allocation. Where appropriate for the client's documented risk profile and suitability tier, the Firm may supplement portfolio management with fundamental equity research and individual security analysis, including quantitative valuation modeling, competitive analysis, and scenario-based price target development.

Systematic Rebalancing: Portfolio rebalancing is governed by threshold-based and calendar-based rules documented in each client's IPS. Rebalancing is never triggered by market predictions or emotional judgment.

Covered Call Overlay Strategy (Where Applicable): For eligible clients, River Rose may manage a covered call overlay on equity holdings. This strategy is not appropriate for all clients and is not employed in minor or custodial accounts.

Fixed Income Reserve and Drawdown Deployment: For qualifying clients, River Rose may maintain a systematic fixed income reserve designed for rules-based deployment during equity drawdown events. Deployment thresholds are pre-specified in the IPS, removing discretion from rebalancing decisions during periods of market stress.

Custodial and Minor Account Strategy: Custodial accounts are managed with a long-horizon, growth-oriented allocation emphasizing broad equity market exposure with systematic rebalancing. These accounts do not employ options overlays or complex derivatives strategies. Allocations are reviewed annually and adjusted as the beneficiary approaches the age of majority.

Long-Term Investment Orientation: River Rose's primary investment horizon is long-term. The Firm does not engage in short-term trading or market timing. Portfolio turnover is minimized to reduce transaction costs and tax drag, particularly in taxable accounts.

Material Risks Involved

Quantitative Model Risk: Quantitative strategies may perform differently than expected due to model assumptions, data limitations, parameter sensitivity, or structural regime changes that disrupt historical relationships. No model guarantees future performance.

Market Risk: Broad market declines may reduce portfolio values regardless of holdings quality. Equity markets are subject to volatility driven by economic, political, geopolitical, and macroeconomic factors outside River Rose's control.

Interest Rate and Inflation Risk: Fixed income securities are sensitive to interest rate changes; rising rates generally reduce bond prices. Inflation erodes the real value of investment returns over time. 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. Clients employing this strategy accept a defined limitation on return potential and a taxable event in exchange for premium income.

Concentration and Liquidity Risk: Clients who impose restrictions or hold concentrated positions outside the advisory relationship may face elevated concentration risk. ETF liquidity may be impaired during severe market stress.

Systematic Rules Risk: Rule-based strategies are designed to remove emotional decision-making. However, mechanical rule adherence may produce suboptimal outcomes in environments where human judgment may have performed better. River Rose's rules are disclosed to clients and applied consistently.

Artificial Intelligence and Quantitative Model Risk: River Rose Financial's investment framework incorporates quantitative analytical tools, data-driven models, and, where applicable, artificial intelligence and machine learning methodologies. While these tools are designed to improve consistency and analytical rigor, they carry inherent limitations. AI and quantitative models may produce anomalous or incorrect outputs due to flawed algorithms, insufficient or biased training data, model overfitting, or rapidly changing market conditions that fall outside historical parameters. The Firm also relies on third-party data providers including the Federal Reserve Economic Data (FRED) API and other market data services, whose own methodologies, data quality, and potential use of AI-assisted tools are outside the Firm's direct control. Errors or gaps in third party data may affect analytical outputs without immediate detection.

Furthermore, the broader investment landscape is subject to material disruption from the accelerating adoption of artificial intelligence across industries and markets. The full scope of AI's effect on corporate valuations, competitive dynamics, labor markets, and regulatory frameworks remains uncertain. National and international regulatory developments may seek to limit or govern AI use in ways that affect both the Firm's analytical tools and client portfolio holdings in AI-exposed sectors. Clients should understand that no quantitative model or analytical framework eliminates investment risk, and all model-driven outputs are subject to human review and override by the Firm's Investment Adviser Representative.

Risks of Specific Securities Utilized

Exchange Traded Funds (ETFs): Investing in ETFs carries the risk of capital loss, including up to 100% loss in extreme cases. ETFs are subject to market risk, tracking error, liquidity risk, and in the case of leveraged or inverse ETFs, volatility decay. River Rose generally utilizes plain-vanilla, non-leveraged ETFs tracking broad market indices.

Fixed Income Securities: Fixed income ETFs and instruments are subject to interest rate risk, credit risk, inflation risk, call risk, and liquidity risk. Longer-duration instruments carry greater sensitivity to interest rate changes.

Precious Metals and Real Asset ETFs: These instruments may be subject to commodity price volatility, regulatory changes, currency fluctuations, and supply-demand dynamics specific to physical commodity markets.

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.

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.

Material Affiliations and Potential Conflicts of Interest

River Rose Financial LLC does not have any material Affiliations or conflicts of interest.

Code of Ethics

River Rose Financial LLC has adopted a written Code of Ethics governing the conduct of all supervised persons. The Code of Ethics addresses:

• Fiduciary duties owed to all clients, including minor beneficiaries and their custodians
• Prohibition on insider trading and use of material non-public information
• Personal securities transaction reporting and pre-clearance requirements
• Identification, management, and disclosure of conflicts of interest
• Gifts and entertainment policies
• Client confidentiality and data protection
• Compliance with applicable federal and state securities laws
• Recordkeeping, annual review, and sanctions for violations

ALL PROSPECTIVE AND CURRENT CLIENTS HAVE A RIGHT TO RECEIVE A COPY OF THIS CODE OF ETHICS AT ANY TIME AND AT NO CHARGE.

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.

Investing Personal Money in the Same Securities as Clients

Thomas C. MacPherson's core personal portfolio is invested in the same ETFs and asset classes that form the foundation of client portfolios at River Rose Financial. This is intentional. It reflects the genuine belief in the systematic, rules-based investment framework that governs every client relationship. The adviser's own capital is managed under the same principles, the same asset allocation logic, and the same discipline that clients are paying for.

A separate, smaller portion of the principal's personal capital is allocated to River Rose Intelligence, LLC, a proprietary algorithmic trading entity that trades exclusively in futures contracts and operates independently of all client assets. Any overlap with securities held in client accounts arises only from the manual management of River Rose Intelligence's operating cash reserves; such overlapping positions are documented. River Rose Financial will never engage in personal or proprietary trading that precedes or disadvantages transactions in client accounts.

Trading Securities at or Around the Same Time as Clients

Supervised persons of River Rose 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. River Rose and it's supervised persons are prohibited from front running or engaging in any trading activity that would disadvantage the trading in client accounts.

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 and the most favorable transaction terms for clients under the circumstances. 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. Altruist is a registered broker-dealer and RIA-focused custodial platform offering commission-free trading, real-time account reporting, and full UGMA/UTMA account support. The recommended custodian is specified in each client's advisory agreement.

Soft Dollar Benefits

Altruist provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to retail customers. Altruist also makes available various support services. Some of those services help us manage or administer our Clients' accounts, while others help us manage and grow our business. Altruist's support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Altruist. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first.

Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor's choice of Altruist for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Altruist's support services:

• Services that benefit you. Altruist'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 Altruist include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our Clients. Altruist's services described in this paragraph generally benefit you and your account.
• Services that may not directly benefit you. Altruist also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients' accounts. They include investment research, both Altruist's own and that of third parties. We may use this research to service all or a substantial number of our Clients' accounts, including accounts not maintained at Altruist. In addition to investment research, Altruist also makes available software and other technology that:
  1. provide access to Client account data (such as duplicate trade confirmations and account statements)
  2. facilitate trade execution and allocate aggregated trade orders for multiple Client accounts
  3. provide pricing and other market data
  4. facilitate payment of our fees from our Clients' accounts
  5. assist with back-office functions, recordkeeping, and Client reporting
• Services that generally benefit only us. Altruist also offers other services intended to help us manage and further develop our business enterprise. These services include:
  1. Educational conferences and events
  2. Consulting on technology, compliance, legal, and business needs
  3. Publications and conferences on practice management and business succession
• Your brokerage and custody costs. For our Clients' accounts that Altruist maintains, Altruist generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Altruist account. Certain trades (for example, many mutual funds and ETFs) may not incur Altruist commissions or transaction fees.

Brokerage for Client Referrals

River Rose Financial LLC does not receive client referrals from any broker/dealer or third party in exchange for directing client brokerage to that firm.

Client-Directed Brokerage

River Rose Financial does not permit clients to direct brokerage (i.e., "trading away," where a client instructs the firm to execute a trade through another broker-dealer and then deliver the position to Altruist).

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 or more efficient execution. Block trades will be allocated among participating accounts on a fair and equitable basis. Non-discretionary accounts may not be able to participate in block trades.

Frequency and Nature of Periodic Reviews

All client advisory accounts are reviewed at least quarterly by Thomas C. 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. Custodial and minor accounts receive an additional annual review to assess whether the allocation remains appropriate for the beneficiary's age and evolving time horizon. Clients are invited to meet with the firm no less than once annually.

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; the minor beneficiary's approach to the age of majority; or at the client's request.

Client Reporting

Each advisory client receives: (i) quarterly account statements from the qualified custodian; (ii) a separate 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. Custodians of minor accounts receive all reporting covering the beneficiary's account consistent with the above schedule.

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.

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 and incorporated into this brochure.

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.

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.

Bankruptcy Petitions

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

Principal Executive Officers and Management Persons

As the sole employee of River Rose Financial, all professional background, disciplinary history, and other information regarding Thomas C. MacPherson is disclosed in the firm's Part 2B Brochure Supplement, delivered in conjunction with this Part 2A Brochure.

Other Business Activities

Other Business activities of Thomas C. MacPherson can be found in item 10 above, if applicable, and in Thomas C. MacPherson's Part 2B brochure supplement.

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 as described in item 6 above.

Material Disciplinary Disclosures

River Rose Financial and any Management person has never been the subject of any civil, administrative, or self-regulatory organization proceedings or arbitrations.

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.

Personal Information

Formal Education

Business Background

Aspen Dev Co

Thomas C. MacPherson serves as Chief Technology Officer of Aspen Dev Co, a private Colorado-based development company, in a limited advisory capacity. This role is administrative and technological in nature and does not involve investment advisory activity, client solicitation, or the management of investment assets. The time commitment to this role is limited to 20 hours per month and does not materially impair Mr. MacPherson's ability to fulfill his advisory obligations to River Rose Financial clients. River Rose Financial does not believe this relationship creates a material conflict of interest with its advisory business.