RCM Robinson Capital Management LLC

Fees and Compensation

                                                                                                       Form ADV Part 2A, Item 5

A. Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether
the fees are negotiable.

RCM charges a fee of up to 125 basis points (1.25 percent) of the value of assets under management. A standard
institutional fixed income client is billed a negotiated fee of approximately 10 basis points (1/10 of 1 percent). This rate is
due to the large portfolio balances and nature of the investments, which are primarily short to medium-term government
fixed income securities. Fees are payable monthly in arrears based on either average market balance or ending month
balance, as selected by client. Accounts opened mid-month will be assessed a pro-rated management fee for the first
month. RCM also offers these services at a flat annual fee assessed and payable monthly. Clients shall pay all advisory
fees directly to RCM due upon receipt of a fee invoice. Clients in the Health Benefits program are charged a fee of up to
35 basis points (1/35 of 1 percent) of the value of assets under management and may have fees deducted directly from plan
assets. At no time will RCM have access to clients' funds or securities maintained in an account, nor will RCM maintain
custody of any client holdings. Fees will be negotiable depending on the amount of assets under management. Either party
may terminate services at any time by submitting written notice to the appropriate parties. Termination will be effective
upon receipt of such notice. If notice of termination is received within five (5) business days of signing the client
agreement, the contract will be terminated without penalty and no fees due. If termination is requested after the initial five
(5) business days, fees will be prorated based on the number of days of services provided for the calendar quarter or
month depending on billing method.

B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients may select
either method, disclose this fact. Explain how often you bill clients or deduct your fees.
Please see above, Item 5 A

C. Describe any other types of fees or expenses clients may pay in connection with your advisory services,
such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other
transaction costs, and direct clients to the section(s) of your brochure that discuss brokerage.
Assets held in custody by a Designated Trustee in the Health Benefit Trust Program will be charged a custody fee. Clients
in this program and assets held with Matrix Trust Company will be charged up to 6 basis points (6/10 of 1 percent), plus
$500 annually. Separate from fees charged by RCM, Health Benefit Trust Program clients invested in mutual funds have
annual operating expenses paid by investors. These mutual fund expenses can range from 7 basis points (.07 of 1 percent)
for passive or indexed funds to 150 basis points (1.5 percent) for specialized active funds. In general, the smaller, more
niche, and global the fund’s investments are, the higher the operating expenses, because of the extra research involved.

D. If your clients either may or must pay your fees in advance, disclose this fact. Explain how a client may
obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period.
Explain how you will determine the amount of the refund.
Not applicable.
E. If you or any of your supervised persons accepts compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact
and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4.
    1. Explain that this practice presents a conflict of interest and gives you or your supervised persons an
    incentive to recommend investment products based on the compensation received, rather than on a client’s
    needs. Describe generally how you address conflicts that arise, including your procedures for disclosing the
    conflicts to clients. If you primarily recommend mutual funds, disclose whether you will recommend “no-
    load” funds.
   While RCM does not have a related person that is a broker/dealer, the associated persons of RCM are registered
   representatives of Osaic, Inc. (formerly Securities America, Inc.), a full-service broker/dealer, member FINRA/SIPC.
   When placing institutional fixed income securities transactions for RCM clients through Osaic, Inc. in their capacity as
   registered representatives, they do not earn sales commissions. Clients may be charged a transaction fee of $13 per
   trade by Osaic, Inc., which is paid as a mark-up or mark-down in price or shown separately in the trade conformation.
   No transaction fees or commissions are charged in the Health Benefit Trust Program. Osaic, Inc. can issue payments

in the form of loans to registered representatives that can be forgivable based on years of service or extent of
production with Osaic. This practice can create a conflict of interest because the representative can have a financial
incentive to continue to affiliate with Osaic or maintain certain levels of production with Osaic in order for the loan to
be forgiven.
However, to the extent that the associated persons of RCM recommends Osaic be used for certain products or
brokerage services, it is because RCM believes that it is in the clients’ best interest to do so based on the quality and
pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services
provided by Osaic.

2. Explain that clients have the option to purchase investment products that you recommend through other
brokers or agents that are not affiliated with you.
...

Types of Clients

                                                                                        Form ADV Part 2A, Item 7

Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts,
investment companies, or pension plans. If you have any requirements for opening or maintaining an account,
such as a minimum account size, disclose the requirements.

RCM serves primarily local government agencies in the State of California. While there is no minimum account
size for advisory clients in the Health Benefits Program, the suggested minimum account for fixed income
clients is $10 million.

            Methods of Analysis, Investment Strategies and Risk of Loss

                                                                                          Form ADV Part 2A, Item 8

A. Describe the methods of analysis and investment strategies you use in formulating investment advice
   or managing assets. Explain that investing in securities involves risk of loss that clients should be
   prepared to bear.

    RCM uses portfolio management models based on the Graham value theory and/or modern portfolio
    theory, including the use of demographics to determine consumer trends and consumption patterns.
    Principals of the RCM maintain both formal and informal relationships with various mutual fund
    management companies and other investment advisors. RCM uses a variety of sources to formulate
    opinion for economic direction and asset selection that will influence recommendations in clients’
    portfolios. RCM subscribes to various databases and trade journals to obtain statistical information,
    consensus and contrarian opinion, fundamental and technical data on stocks, bonds, funds, separate
    account managers and markets. Model mutual fund and asset allocation portfolio programs, provided
    by a number of institutional investment managers and strategists, may be used when managing client
    assets. Each investor's portfolio must be constructed based on the individual's financial resources,
    investment goals, risk tolerance, investing time horizon, tax situation and other relevant factors.
    Portfolios may contain foreign securities which carry special risks, including currency exchange
    fluctuations, foreign taxes and possible delays in settlement.

B. For each significant investment strategy or method of analysis you use, explain the material risks
involved. If the method of analysis or strategy involves significant or unusual risks, discuss these risks in
detail. If your primary strategy involves frequent trading of securities, explain how frequent trading can
affect investment performance, particularly through increased brokerage and other transaction costs and
taxes.
Fixed income clients, such as public agencies RCM serves, have very specific restrictions to the type and
maturity of securities allowed. These portfolios inherently carry less risk over-all due to the nature of the
securities held. Clients participating in investments seeking growth require riskier assets such as equities,
and other more aggressive fixed income investments should be aware that losses may occur.

C. If you recommend primarily a particular type of security, explain the material risks involved. If the type of
security involves significant or unusual risks, discuss these risks in detail.
Foreign investing has special risks, including currency exchange fluctuations, foreign taxes and possible
delays in settlement