Understanding Your Brokerage and Investment Advisory Relationships

Depending on your needs and your investment objectives, RIA may assist you with brokerage services, investment advisory services or both. There are important differences highlighted below between brokerage and advisory accounts, including their costs, the services we provide and the rules that govern them. You should carefully consider these differences when deciding which type, or combination of types, of services and accounts are right for you. RIA is registered as both a broker-dealer and as an investment adviser under federal and state securities laws, and we provide services in both capacities. In accordance with the rules of the Financial Industry Regulatory Authority (FINRA), whether acting in a brokerage or advisory capacity, RIA observes high standards of commercial honor and just and equitable principles of trade.

What are Brokerage Accounts and Services?

When we act as a broker-dealer in connection with your brokerage account, we will facilitate the execution of transactions based on your instructions. In addition, when we act as a broker, we also offer investor education, research, financial tools and personalized information about financial products and services, including recommendations about whether to buy, sell or hold securities. We do not charge a separate fee for these services because these services are part of, and incidental to, our brokerage services. When we act as your broker-dealer, we do not have discretion to buy and sell securities for you (except in limited circumstances). Therefore, you will provide approval for each trade before it is executed and you will make individual buy, sell and hold decisions rather than us making those decisions.

What Is RIA’s Role When Handling A Brokerage Account?

When recommending securities transactions or investment strategies involving securities while providing brokerage services to you, we must act in your best interest,1 which requires that we do not put our interest ahead of yours. However, we generally do not have a fiduciary obligation to you nor do have an investment advisory relationship with you. Please note the “best interest” obligation described herein applies only to Retail Customers, as defined in regulations issued, particularly, “Regulation Best Interest” by the SEBI. A Retail Customer is defined as a natural person, or the legal representative of such natural person, who (A) receives a recommendation of any securities transaction or investment strategy involving securities from a broker, dealer or a natural person who is an associated person of a broker or dealer, and regulations, the Employee Retirement Income Security Act of 1974, as amended, or “ERISA”, and any applicable professional conduct standards.

What are Investment Advisory

Accounts and Services?

In addition to brokerage services offered to clients, RIA offers a variety of investment advisory programs and services, including comprehensive financial planning, non-discretionary and discretionary portfolio management, and advice on the selection of professional asset managers and securities. We must enter into a written agreement with you that describes our advisory relationship and our obligations to you before we can act as your investment adviser. You also will receive a disclosure document about our advisory services, called a Form ADV Brochure, that describes, among other things, our business, the services we provide, our advisory fees, our personnel, and potential conflicts between our interests and yours. Investment Advisers are governed by the Investment Advisers Act of 1940 and applicable state securities laws. When acting as your investment adviser, we have a fiduciary relationship with you. In addition, for advisory retirement accounts,2 we act as a fiduciary under the Employees’ Provident Fund (EPF) and Pension Scheme (EPS), governed by Indian laws (EPF Act, 1952) and/or under Income-tax Act, 1961.

What is Your Financial Advisor’s Role When Handling an Investment Advisory Account?

Your Financial Advisor’s authority over the activity in your account will differ, depending on the nature of the investment advisory account you choose. For example, in our Portfolio Management program, your Financial Advisor will have discretionary authority to execute investment decisions on your behalf. In our Consulting Group Advisor program, your Financial Advisor will work with you to make investment recommendations, but you will maintain discretion over all the investment decisions made in your account. In other advisory account types, your Financial Advisor will select or recommend investment products or third- party managers.

How You are Charged for Brokerage

and Investment Advisory Accounts?

BROKERAGE ACCOUNTS

In a brokerage account, you generally compensate RIMS and your Financial Advisor through a commission for each equity transaction, a mark-up/ mark-down for bond transactions and a sales charge for mutual fund transactions. Therefore, in a brokerage account your total costs will generally increase or decrease depending on the frequency of transactions in the account and the type of securities you purchase. Additional costs will also apply to your account.

INVESTMENT ADVISORY ACCOUNTS

In an investment advisory account, you generally compensate RIA and our Financial Advisor through an annual fee, payable monthly, in advance based on the total value of the assets in your investment advisory account at the end of the previous month. This RIMS Advisory fee (“Advisory Fee”) typically covers our investment advisory services, trade execution through RIA, custody of securities at RIA, reporting, and compensation to your Financial Advisor. Depending upon the investment advisory program you select, you may also be charged a professional money manager’s (“Manager”) fee, as well as additional fees for platform maintenance. RIMS or the Manager may determine that best execution is more likely to be achieved by having an external broker-dealer other than RIA execute the transaction, even if such broker-dealer requires payment of a fee or other charges. This applies to certain transactions, including, without limitation, block trades in which RIA or the Manager aggregates securities purchases or sales for the account with those of one or more of its other clients. In such instances, your account will be charged a commission or commission equivalent. These costs are in addition to the Advisory Fee you pay to RIA and will be included in the net price of the security but will not be reflected as a separate charge on your trade confirmations or account statements.

In evaluating which broker or dealer will provide the best execution, RIA, or the Manager, in its sole discretion and in accordance with applicable law (including the obligation to seek best execution), will consider the full range and quality of a broker’s or dealer’s services, which may include,

among other things, the value of research provided, as well as, execution capability, commission rate, financial responsibility and responsiveness. These entities

may select broker-dealers that provide RIMS and/or the Manager research or other transaction-related services. This may result in a charge to you for broker-dealer commissions for effecting transactions that ends up being more expensive than the commission that other broker- dealers may have charged. Research and other services may be used for RIMS’s or for the Manager’s own or other client accounts to the extent permitted by law.

Our services and responsibilities, as well as, the applicable fees charge to your account, are described in detail in the investment advisory agreement that

we enter into with you, the playback letter provided to you after account opening, and in the Form ADV Brochure applicable to the program you have selected.

BOTH BROKERAGE AND ADVISORY ACCOUNTS

In both brokerage and investment advisory accounts which include products such as mutual funds or exchange traded funds, additional expenses will be charged to you, including investment management fees of the fund, as well as operating expenses that are reflected in the funds’ share price. These expenses are not included in RIA’s fees. Additional fees and expenses that are not outlined above, may apply as described in our agreements with you.

When We Act as Both Your Broker‑Dealer and Your Investment Adviser

We may act as investment adviser and as broker-dealer to you at the same time. This does not mean that our brokerage relationships are advisory ones. For example, you may maintain multiple accounts (some brokerage accounts and some investment advisory accounts) with RIMS at the same

time. Although we may consider your brokerage account assets in preparing guidelines or determining appropriate investments for your investment advisory accounts, our brokerage relationship only covers your brokerage assets.

For More Information

We encourage you to carefully consider the differences between brokerage and investment advisory services, particularly in terms of our obligations to you, the services we provide and the costs of those services. You should consider your existing and anticipated level of trading activity, the types of investments you wish to hold and the level of discretion you wish to retain over security selection when determining which account type is right for you. If you have additional questions, please contact a member of your RIMS team for more information.