DISCLOSURE BROCHURE. NACo RMA LLC. 25 Massachusetts Avenue, NW Suite 500 Washington DC 20001

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1 DISCLOSURE BROCHURE 25 Massachusetts Avenue, NW Suite 500 Washington DC This provides customers with information about the qualifications and business practices of. Please contact Peter Torvik, Compliance Responsible Person (CRP) of (202) or if you have questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Additional information on the disciplinary history of is available on the Internet at and can search these sites by s identifying. The SEC number for is and the MSRB number is K0647. Registration does not imply a certain level of skill or training. January

2 ABOUT () is a Registered Municipal Adviser registered with the Securities and Exchange Commission (SEC) and Municipal Securities Rulemaking Board (MSRB) under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). endeavors at all times to operate in compliance with federal and state laws and to conduct its business in the highest ethical manner. MATERIAL CHANGES No material changes for since its annual update January 12, TABLE OF CONTENTS ABOUT,... 2 MATERIAL CHANGES... 2 TABLE OF CONTENTS... 2 Item 4. ADVISORY BUSINESS... 3 Item 5. FEES AND COMPENSATION... 3 Item 6. PERFORMANCE BASED-FEES and SIDE-BY-SIDE MANAGEMENT... 4 Item 7. TYPES OF CUSTOMERS... 4 Item 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES and RISK of LOSS... 4 Item 9. DISCIPLINARY INFORMATION... 4 Item 10. OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS... 4 Item 11. CODE OF ETHICS, PATICIPATION or INTEREST in CUSTOMER TRANSACTIONS and PERSONAL TRADING... 5 Item 12. BROKERAGE PRACTICES A.1. Research and Other Soft Dollar Benefits A.2. Brokerage for Customer Referrals A.3. Directed Brokerage B. Aggregation and Allocation of Trades... 5 Item 13. REVIEW OF ACCOUNTS... 5 Item 14. CUSTOMER REFERRALS AND OTHER COMPENSATION... 6 Item 16. INVESTMENT DISCRETION... 6 Item 17. VOTING CUSTOMER SECURITIES... 6 Item 18. FINANCIAL INFORMATION... 6 Item 19. REQUIREMENTS for STATE-REGISTERD ADVISORS... 6 CUSTOMER COMPLAINTS

3 Item 4. ADVISORY BUSINESS () was founded in acts as a Solicitor for Nationwide Retirement Solutions (NRS), an affiliate of Nationwide Investment Services Corporation, member FINRA. and its Associated Persons do not solicit NRS products directly to individual participants/investors. The soliciting activities are limited to introducing the services of NRS to managers of the employee benefit plans of county governments and county agencies. While the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) imposes a fiduciary obligation on municipal advisors acting on behalf of their municipal entity customers, is not required to exercise a fiduciary duty when soliciting municipal entities on behalf of unrelated third parties (in such capacity, a Solicitor ). does not manage customer portfolios and has no discretionary accounts. Item 5. FEES AND COMPENSATION Adviser Compensation acts as a Solicitor. does not charge customers fees. NACo RMA LLC currently has an arrangement with Nationwide Retirement Solutions (NRS). NRS pays fees that are negotiated with NRS for s solicitation of NRS s services. Associated Person Compensation Any special compensation arrangement between an Associated Person and that could present a conflict of interest with the customer such as bonuses will be disclosed to the customer. Any economic benefit received from a non-customer in connection with providing any advisory services will be disclosed to the customer. Solicitor Disclosures may enter into arrangements that provide for the payment or receipt of Solicitor fees. Payment of Solicitor Fees may, from time to time, pay referral fees to finders or solicitors for obtaining new advisory customers. Such arrangements will be in the form of a written agreement and the Solicitor must not be subject to a statutory disqualification. The required disclosure depends on the type of solicitation, as follows: 3

4 Impersonal Services Only - Includes investment advice not intended to meet the investment objectives or needs of specific individuals or accounts. No specific disclosure will be required. Affiliated Solicitor - If uses an affiliated Solicitor who is offering personalized advisory services, the nature of the relationship will be disclosed but no disclosure of the specific terms of the agreement will be required; Unaffiliated Solicitor - If uses an unaffiliated Solicitor, full disclosure of the relationship will be made including the amount of compensation the Solicitor will be paid. is not reimbursed for out-of-pocket expenses, i.e., travel, lodging, meals, postage, or costs for printing either by NRS or any customer. Item 6. PERFORMANCE BASED-FEES and SIDE-BY-SIDE MANAGEMENT does not charge Performance-Based Fees or conduct Side-By-Side Management. Item 7. TYPES OF CUSTOMERS and its Associated Persons do not solicit NRS products directly to individual participants/investors. The soliciting activities are limited to introducing the services of NRS to managers of the employee benefit plans of county governments and county agencies. Item 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES and RISK of LOSS s advisory role is solely as a Solicitor. Therefore, does not perform an analysis of investment strategy and risk of loss. Item 9. DISCIPLINARY INFORMATION No Associated Person of has any past or current disciplinary disclosures. Item 10. OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS Mr. Torvik is associated as the CRP for NACo RMA which is also an RMA. 4

5 Item 11. CODE OF ETHICS, PATICIPATION or INTEREST in CUSTOMER TRANSACTIONS and PERSONAL TRADING A. has adopted a Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended, to prevent violations of federal securities laws. The Code of Ethics is predicated on the principle that does not owe a fiduciary duty to its customers. However, expects all Associated Persons to act with honesty, integrity and professionalism and to adhere to federal securities laws. All officers, directors, members and employees of and any other person who provides advice on behalf of and is subject to s control and supervision are required to adhere to the Code of Ethics. s Code of Ethics allows the purchase of IPOs or private placements only with prior permission from s Chief Compliance Officer. Customers may request to receive, at no cost, a copy of s Code of Ethics, which contains its policies on employee trading, gifts, and outside business activities. Gifts of nominal value are acceptable, and all Associated Persons must disclose any outside business activities generating revenue, which must be approved by s CRP B. Buys or Sells for that Associated Persons Also Recommend To Customers does not recommend purchases and sales of securities to its customers. C. Participation or Interest in Customer Transactions does not participate or have interest in customer transactions. Item 12. BROKERAGE PRACTICES does not engage in any brokerage transactions or other brokerage practices. 12.A.1. Research and Other Soft Dollar Benefits does not receive any research or other soft dollar benefits. 12.A.2. Brokerage for Customer Referrals does not have the incentive to select or recommend a broker/dealer based on its interest in receiving customer referrals. 12.A.3. Directed Brokerage does not engage in direct brokerage activities B. Aggregation and Allocation of Trades does not transact trades. Item 13. REVIEW of ACCOUNTS does not perform ongoing advisory services. All records related to any solicitations are maintained by. 5

6 All customer records related to services provided are reviewed by the Chief Compliance Officer of. Item 14. CUSTOMER REFERRALS and OTHER COMPENSATION and/or its Associated Persons do not recommend or introduce investment products and as such do not receive incentive rewards. Item 15. CUSTODY does not have custody of any customer funds or securities. Item 16. INVESTMENT DISCRETION does not exercise discretion for any accounts. Item 17. VOTING CUSTOMER SECURITIES does not engage in the purchases or sales of securities; therefore, NACo RMA LLC does not vote proxies on behalf of its customers. Item 18. FINANCIAL INFORMATION 18.A. Prepayments does not receive fees from customers; therefore, it does not require or solicit prepayments of more than $500 in fees per customer, six months or more in advance. 18.B. Financial Condition There are no financial conditions that are likely to impair s ability to meet its commitments to customers. 18.C. Bankruptcy has never been subject to a bankruptcy. Item 19. REQUIREMENTS for STATE-REGISTERD ADVISORS Associated Persons of must possess, minimally, a college degree and/or appropriate business experience and all licenses, if required. 19.A. All Designated Supervisors are required to have a minimum of 3 years experience in the securities and/or advisory industry. Mr. Peter Torvik Date of Birth 07/10/1954 Attended University of Minnesota, Bachelor of Science Business Dartmouth College, Amos Tuck School of Business, MBA Mr. Torvik is currently not required to hold any securities licenses. Ms. Lisa Cole Date of Birth 06/03/1951 Attended University of North Carolina Greensboro, majoring in history 6

7 Ms. Cole is currently not required to hold any securities licenses. Mr. David Keen Date of Birth 08/06/1965 Attended Virginia Tech, Business w/ major in accounting Mr. Keen is currently not required to hold any securities licenses. 19.B. Other Business Activities Mr. Torvik s other business activities are as follows: Managing Director, NACo Financial Services Center Ms. Cole s other business activities are as follows: Director, NACo Financial Services Corporation Mr. Keen s other business activities are as follows: NACo Chief Financial Officer 19.C. Calculation of Fees See Item 5 19.D. Disclosures and its Associated Persons do not have any current or past disclosures or customer complaints. 19.E. Relationships with Issuers of Securities s customers may issue securities; however, and its Associated Persons do not participate in or advise customers regarding such issuance. Item 20. CUSTOMER COMPLAINTS Customers may contact Peter Torvik, CRP of, at to submit a compliant. Written complaints should be sent to Mr. Peter Torvik,, 25 Massachusetts Ave NW, Suite 500, Washington DC or to ptorvik@naco.org. 7

Part 2A of Form ADV: Firm Brochure. Buckingham Financial Group, Inc Loop Road Dayton, OH 45459

Part 2A of Form ADV: Firm Brochure Buckingham Financial Group, Inc. 6856 Loop Road Dayton, OH 45459 Telephone: 937-435-2742 Email: service@buckinghamfinancial.com Web Address: www.buckinghamfinancial.com