ACM registered as a Delaware limited liability company in October 2016. ACM’s principal owners are Peter J. Johnson, Chief Operating Officer and Chief Compliance Officer, Dave Van Benschoten, Chief Investment Officer & Strategist, and Lorenzo Paloscia, Portfolio Manager and Research and Development. ACM currently provides investment management services and discretionary investment advice to clients through separately managed accounts and the ACM Risk Managed US Equity Strategy, LP (the “Fund”). ACM may also provide non-discretionary investment consulting services to certain institutions and high net worth individuals. Separately managed accounts, and investment consulting clients are collectively referred to hereinafter as “Clients”. While the Fund is also a client of ACM, we will refer to it as the Fund throughout this Brochure. Advisory Services Generally ACM’s investment management services include determining a Client’s investment objectives, determining appropriate asset allocation across a Client’s investment strategies, executing trades, and monitoring existing and prospective investments in light of each Client’s objectives and risk parameters. Advisory Services to Separately Managed Accounts Investments for a separately managed account Client are managed in accordance with the Client’s investment objectives, strategies, restrictions, and guidelines as set forth in the documents governing ACM’s relationship with such Client or as otherwise communicated to ACM by the Client. Depending on the nature of the relationship, these services may be offered on a discretionary or non-discretionary basis and may include the investment and reinvestment of securities, cash and cash equivalents, futures and options held in a Client’s account. If a Client wishes to impose certain restrictions on investing in certain securities or types of securities, or is prohibited by applicable law from investing in such securities or types of securities, ACM will address those requests on a case-by-case basis. ACM offers: 1) ACM Risk Managed US Equity: “Participate but Protect” The objective for this strategy seeks to deliver asymmetric risk/returns over the long-term where there is meaningful participation in upside equity performance while limiting the downside (see additional descriptions and disclosures throughout this Brochure). A benchmark was created by ACM for this strategy and launched in the spring of 2017, under the ticker of EALTS, with S&P Dow Jones serving as the calculation agent. 2) ACM Dynamic Rebalancing: “Adhere and Harvest” The objective for this strategy seeks adherence to target allocations of an overall asset allocation for equities and bonds and attempts to deliver realized gains on a notional amount from short-term deviations of those targets, and, assuming reinvestment of these gains, to increase the value of the overall investment program. 3) Opportunistic Income Strategy: ACM advises clients regarding investments for income producing assets such as Master Limited Partnerships (“MLPs”), bonds, and closed end funds which may trade at a discount. Asymmetric Capital Management, LLC Page 5 ACM deploys an active systematic rebalancing (“ASR”) methodology to harvest short-term volatility of its target allocations for stocks, bonds, and volatility when they deviate from their respective targets in a predetermined and rules-based manner. ACM Risk Managed US Equity, LP (the “Fund”) The Fund was created to provide asymmetric risk/returns over the long-term for investors. Our goal for the Fund is to “Participate but Protect” or to participate more in upside equity performance while limiting the downside. Overall, this may result in lower volatility with the potential for better cumulative returns. We invest in very liquid assets for equities, bonds, and volatility, that are quite efficient to trade, with specific target allocations for each of 70% equities, 15% bonds, and 15% for volatility. Also, these assets are negatively correlated which provides greater diversification benefits. We deploy a proprietary active systematic rebalancing (ASR) methodology for consistent adherence to the target allocations but importantly, attempt to harvest short-term volatility in a predetermined and disciplined manner when these allocations drift from their respective targets. Our volatility allocation, which is always net long, serves to hedge

equities with cost efficiency. We believe our strategy can be a fit for an alternatives allocation including being competitively priced with no incentive fee. It can also fit for a hedged core equity investment, a multi-asset strategy, and is quite flexible for customization as the equity components are modular (capitalization, style, non-US, EM, among others). A benchmark for this strategy was created and launched in the spring of 2017 with S&P Dow Jones serving as the calculation agent. Wrap Fee Programs Currently, ACM does not sponsor any wrap fee programs or utilize any wrap fee programs that incorporate the ACM strategy as SMA accounts into a wrap fee program. Investment management provided to sub- advised wrap fee clients is substantially the same as that provided to non-wrap fee clients. However, practical restraints to the management of wrap fee accounts may exist. Most notably, the smaller asset value of certain wrap fee accounts and IRA accounts may result in slightly different returns due to investment limitations imposed, administrative restrictions, and wrap fees imposed by wrap fee sponsors. For sub- advised clients and wrap fee clients whose accounts are managed by ACM pursuant to a wrap-fee, consulting, or other referral program, advisory and wrap fee services may be provided by the third-party broker-dealer, investment adviser, trust company or other financial services provider who sponsors the program and advises the client. Under these arrangements, the financial services provider typically interviews the client or has the client complete a written questionnaire, assesses the client's financial situation and objectives, and determines whether the strategies and services offered by ACM would be appropriate for the client before ACM is retained to manage the client's account. The financial services provider also normally is responsible for determining and notifying ACM of any changes in the client's investment objectives or personal or financial circumstances that should be considered in managing the account. Like ACM clients, sub-advised clients have ACM imposed account restrictions such as a minimum investment levels, among others. If clients cannot meet these restrictions or fall out of certain thresholds, then ACM reserves the right to terminate the management of the account. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to Clients and prospective clients. When we provide investment advice regarding a Client’s or prospect’s retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Asymmetric Capital Management, LLC Page 6 Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with a Client’s interests, so we operate under a special rule that requires us to act in a Client’s best interest and not put our interest ahead of our clients. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of a Client’s assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in a Client’s best interest. Regulatory Assets Under Management As of December 31, 2023, ACM manages $303,948,471on a discretionary basis and $0 on a non- discretionary basis. Asymmetric Capital Management, LLC Page 7