A. Firm Information RoseRock Wealth Management, LLC (“RoseRock” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Texas. RoseRock was founded in February 2017 and is owned and operated by Ryan W. Huey (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by RoseRock. B. Advisory Services Offered RoseRock offers advisory services to individuals, high net worth individuals, trusts, estates, pensions and profit- sharing plans, and charitable organizations (each referred to as a “Client”). The Advisor acts as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. RoseRock’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services RoseRock provides customized wealth management services to its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Investment Management Services – RoseRock provides investment advisory solutions for its Clients based on model portfolios created by the Advisor. The Advisor primarily utilizes exchange traded funds (“ETFs”) and mutual funds to create proprietary model portfolios offered to its Clients. The Advisor may also utilize other investments to meet the model objectives. In certain cases, the Advisor may use margin to meet a Client’s goals or liquidity needs. RoseRock evaluates and selects investments for inclusion in model portfolios only after applying its internal due diligence process. The Advisor will work with the Client to identify their investment goals, objectives, and risk tolerance to construct a portfolio from the Advisor’s model portfolios. The Advisor may retain certain types of investments based on a Client’s legacy holdings, which will be maintained outside of the models. Additional information regarding the risks of these investment options, including margin, can be found in Item 8. RoseRock’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. RoseRock will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. RoseRock evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. RoseRock may recommend, on occasion, redistributing investment allocations to diversify the portfolio. RoseRock may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. RoseRock may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will RoseRock accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information. Please see Item 12 – Brokerage Practices. Participant Account Management- As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. The Advisor is not affiliated with the platform in any way and do not receive compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance, and changes in allocations will take into account current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction.

No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services RoseRock will typically provide a variety of financial planning services to Clients either as a component of its wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for or rendered to the Client as part of or in addition to the Client’s comprehensive wealth management services will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. RoseRock may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. RoseRock does not receive compensation for these referrals. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. Financial planning recommendations made in connection with the Advisor’s comprehensive wealth management services pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor. Retirement Plan Advisory Services RoseRock provides 3(21) non-discretionary retirement plan advisory services on behalf of the retirement plans (each referred to as a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Retirement Plan Advisory Services include the following: 1. Design of Investment Policy Statement (IPS). The Advisor will assist the Plan in designing an IPS, which will act as the framework for the Plan’s investment selection and monitoring process. These guidelines will be consistent with the regulations issued pursuant to ERISA § 404(c) dealing with participant- directed plans. 2. Investment Review and Recommendations. The Advisor will assist the Plan in the initial and ongoing monitoring and review of the Plan’s investment options and recommended changes/additions when appropriate. The Investment Committee will have the ultimate decision whether or not a fund change, deletion, or addition should be implemented. 3. Fee Analysis. The Advisor will assist the investment committee or other responsible fiduciary in understanding the investment fees that are charged to the Plan and how those fees compare to the fees other similar investment vendors charge for similar services and products. The Advisor will also assist the Plan Sponsor, when necessary, in producing participant notifications regarding fees. The responsibility for ensuring that participants receive any such notification, however, will reside exclusively with the Plan sponsor and not with the Advisor. 4. Participant Education Consulting. The Advisor will consult with the Plan on the effectiveness of the employee education program. The Advisor will conduct and coordinate education consulting efforts with the Plan’s current providers. 5. Fiduciary File. The Advisor will construct a Fiduciary File that will be used by the Plan to keep documentation related to the Plan. This documentation includes, but is not limited to, Investment Committee minutes, Investment Policy Statement, investment analysis, educational work, fee analysis, vendor analysis, 404(c) information notices (if applicable), and plan design/work analysis. The Plan assumes the responsibility of maintaining this file’s contents, including ensuring its accuracy and completeness. Certain of these services are provided by RoseRock serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of RoseRock’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging RoseRock to provide wealth management services, each Client is required to enter into a wealth management agreement with the Advisor that defines the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – RoseRock, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – RoseRock will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – RoseRock will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – RoseRock will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs RoseRock does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by RoseRock. E. Assets Under Management As of December 31, 2023, RoseRock manages $170,500,000 in Client assets, of which $163,600,000 are managed on a discretionary basis and $6,900,000 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.