Clarfeld

Clarfeld Financial Advisors, LLC, a subsidiary of Citizens Bank, N.A., is a registered investment adviser specializing in investment advisory services since 1981. The firm offers high net worth individuals and families access to skilled professionals through discretionary and non-discretionary investment management. Their open-architecture platform selects investment managers based on merits and alters asset allocation tactically when needed. The firm also offers services through Richter Bober Asset Management for fixed income investments and the Large Cap Strategy for US large cap equity investments. Additionally, services include Retirement Plan Consulting, Sub-Advisory Engagement, and Short-Term Asset Management. Clients may engage in socially responsible investing and are informed about cybersecurity risks. The firm's fee structure ranges from 0.25% to 1.00% for individual clients and 0.10% to 0.50% for institutional clients. The Registrant does not accept performance-based fees and primarily recommends Schwab, TD Ameritrade Institutional, Fidelity, or Pershing for brokerage services. The firm may receive benefits from TD Ameritrade Institutional and pays referral fees in compliance with regulations. Clients are encouraged to review financial planning issues annually, and the firm does not vote client proxies except for assets in the Large Cap Strategy. The Registrant has no financial conditions impairing its commitments and has not been subject to bankruptcy. For further details or inquiries, clients can contact Briana Rende, Deputy Chief Compliance Officer of Clarfeld.