A. Description of the Advisory Firm Asset Strategy Retirement Plan Consultants, LLC is a limited liability company organized in the State of Pennsylvania. The firm has been in business since August 27, 2008. Stacy S. Heistand, Keaton T. Macut, and Neil J. Moody became owners in July 2020. Founder, Clark Frese, serves as an internal stakeholder and firm advisor. B. Types of Advisory Services Asset Strategy Retirement Plan Consultants, LLC (hereinafter “ASRPC”) is a registered investment adviser. ERISA Investment Management Services ASRPC provides pension consulting services to clients covered by the Employee Retirement Income Security Act of 1975 (ERISA), such as, defined benefit plans, 401(k), or profit sharing. Services include, but are not limited to the following:
• Review plan documents;
• Meet with the trustee(s) to understand the specific needs to help define investment objectives and risk tolerances;
• Based upon this information, ASRPC will draft an investment policy statement and present to the trustee(s);
• Review and make suggestions as to the client's current and future investment needs;
• Review the asset allocation;
• Assist the trustee(s) in selection of appropriate money managers or mutual funds;
• Monitor the performance of the selected money manager(s) or mutual funds and report to the trustee(s);
• Advise in regard to the retention or dismissal of a money manager or mutual fund being used;
• Review the account's investment expenses;
• Limited education and enrollment assistance. Specific and individualized advice is not provided to plan participants'
• Preparation of Form 5500 Although ASRPC considers itself a fiduciary, ASRPC does not typically have discretionary authority or control over the plan assets, nor discretionary authority or control over the administration of the plan. Advice is provided to the plan in the form of recommendations to the trustees. ASRPC develops portfolios based upon a Client's goals, objectives, investment time horizon and risk tolerance as well as their core financial-related values. Investment strategies used to implement investment advice are generally long-term in nature and primarily utilize a buy and hold philosophy. Investment strategies may include long-term and short-term purchases depending upon the individual needs of the Client. ASRPC uses asset allocation, or spreading investments among a number of asset classes (domestic stocks vs. foreign stocks; large cap stocks vs. small cap stocks; corporate bonds vs. government securities) for most Client accounts. Asset allocation seeks to achieve the most efficient diversification of assets, to help lessen risk while not sacrificing the effectiveness of the portfolio to yield the Client's objectives. Individual Investment Management Services ASRPC offers investment management services, which include selection, monitoring and review of portfolio assets, on a non-discretionary basis. An initial interview and data-gathering process is completed in an effort to determine the Client's individual needs, goals, time horizons, risk tolerance and investment experience. Based upon information provided by the Client, ASRPC may prepare recommendations for investments, which may include planning for long-range goals (i.e. retirement planning or college funding) or other segments of an investment plan that may be needed. ASRPC provides investment management services primarily through the use of no-load mutual funds, U.S. Government securities and tax-exempt bonds, although individual common and/or preferred stocks

may also be used. ASRPC will analyze performance of existing money managers against appropriate Capital Market Indices (passive) and Peer Group Indices (active). A mutual fund manager is the person(s) responsible for implementing a fund's investing strategy and managing its portfolio trading activities. A fund can be managed by one person, by two people as co-managers or by a team of three or more people. Fund managers are paid a fee for their work, which is a percentage of the fund's average assets under management. ASRPC will use Quarterly Capital Markets Commentary, which is a publication designed to help investors make informed investment decisions. The investment newsletter provides an investor with insights into the markets or into a specific market sector, leaving specific investment decisions to the investor's own discretion. While the investment newsletter provides solid information it is always recommended that investors do their own due diligence before making any investment. ASRPC will annually review Fund offerings as well as possible inclusion of new asset classes. Mutual funds are operated by money managers, who invest the fund's capital and attempt to produce capital gains and income for the fund's investors. A mutual fund's portfolio is structured and maintained to match the investment objectives stated in its prospectus. Clients are obligated to promptly notify ASRPC of any changes in financial status to ensure the designed investment strategies continue to meet the Client's changing needs or to determine if there needs to be a change in investment objectives and strategies. Clients may place reasonable investment restrictions on their accounts, including bans on investing in particular industries, invest in limited amounts of securities, request third-party checks, and to re-balance portfolios. At the client’s request, clients can initiate a third party check, EFT or wire request where the name(s) on both account are different. The request may require additional signatures. Client approval is needed for each and every transaction prior to rebalance of a portfolio. Services Limited to Specific Types of Investments ASRPC limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, commercial paper, warrants, debt securities, ETFs, hedge funds, REITs, insurance products including annuities, private placements, government securities. ASRPC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ASRPC offers the same suite of services to all of its clients. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ASRPC from properly servicing the client account, or if the restrictions would require ASRPC to deviate from its standard suite of services, ASRPC reserves the right to end the relationship. D. Wrap Fee Programs ASRPC does not participate in any wrap fee programs. E. Amounts Under Management ASRPC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $3,603,023 $72,202,716 December 2023 In addition, ASRPC advises on assets totaling $377,462,444. Assets under advisement include private securities ($3,936,308), participant-directed retirement plans under ASRPC’s advisement ($368,856,537), and ASRPC client assets that have been allocated to independent advisers for ongoing management ($4,669,599).