Aspire is an investment adviser registered with the U.S. Securities and Exchange Commission. We began operations on November 22, 2010. Our owners are John Bryan Philpott and Thomas Keith Kelly. The following individuals are the principal owners of Aspire: John Bryan Philpott Born: 1971 Education: Central Piedmont Community College, Business, Charlotte, NC 1990-1992 Business Background: Mr. Philpott has been a Founding Managing Member of Aspire since its inception in 2010. He is also a president of Aspire Insurance Solutions. Mr. Philpott also is a North Carolina licensed real estate broker with, and president of, Pier 28 Realty, Inc. Finally, Mr. Philpott also holds the Life and Health insurance licenses. Thomas Keith Kelly Born: 1969 Education: Central Piedmont Community College, Business, Charlotte, NC 1988-1992 Business Background: Mr. Kelly has been a Member of Aspire since January of 2014. He is managing member of Covenant Private Capital, an affiliated firm that provides insurance services. Mr. Kelly holds Life, Health, and LTC insurance licenses. Advisory Services Aspire offers the following services to advisory clients: Investment Management and Third-Party Managed Programs The client may engage Aspire to provide discretionary and/or non-discretionary investment advisory services. Aspire typically recommends third-party managers, portfolio specialists, model providers or sub-advisers (“Sub-advisers”) to its clients for asset management and other investment advisory services. Some Sub-advisers are made available through an investment platform offered by GeoWealth Management, LLC (“GeoWealth”). Typically, when Aspire, in consultation with the Client, agrees to use the GeoWealth Platform, Aspire assists the client in selecting the risk/return objective and sub-advisers that best suit the client’s objectives. The client then specifically directs the account to be invested in accordance with the chosen investment solution. When the client selects the investment solutions, the client further directs that the account be automatically adjusted to reflect any adjustment in the asset allocation by the selected Sub-adviser. This client authorization results in the purchase and sale of securities without further authorization by the client or any other party at such time as the Sub- adviser changes the composition of the selected model asset allocation. Furthermore, if the client has granted Aspire discretion to manage assets, Aspire will then manage the assets with discretion within the GeoWealth platform. Specifically, Aspire may, without any further input from or permission of the client, move client assets from one Sub-adviser to another, terminate the services of a Sub-adviser with respect to a client, or reallocate client assets between Sub-advisers. Aspire may have the ability to negotiate lower account minimums, and has negotiated lower account minimums for many of the programs offered by GeoWealth. Aspire makes investment recommendations to clients based upon a review of each client’s specific needs, experience, assets and goals. Clients may impose reasonable restrictions on the investment of their assets including investing in certain securities or type of securities. Clients’ portfolios may consist of stocks, bonds, no-load and/or load mutual funds and cash or cash equivalents, or other securities deemed appropriate and suitable to the client by Aspire. Aspire cannot offer any guarantees or promises that clients’ financial goals and objectives will be met. Further, clients should inform Aspire of any changes in the client’s financial situation, goals, or restrictions. Aspire is available to answer questions that you may have regarding your account and act as the communication conduit between you and the Sub-adviser. The Sub-adviser will take discretionary authority to determine the securities to be purchased and sold for your account. Although Aspire reviews the performance of numerous third-party investment adviser firms, Aspire enters into only a select number of relationships with third-party investment adviser firms. Therefore, Aspire has a conflict of interest in that it will only recommend third-party investment advisers that have a Sub-advisory relationship with Aspire. We address this conflict of interest by selecting third-party investment advisers that will allow us to serve our clients’ best interests, and by advising clients in this brochure that there may be other third-party managed programs not recommended by the Firm that are suitable for the client and that may be more or less costly than arrangements recommended by the Firm. Aspire also has a conflict of interest in that it will only use or recommend platform providers, Sub-advisers or other third-party investment advisers that have a relationship with Aspire and have met the conditions of our due diligence review. There may be other third-party money managers that may be suitable that we do not have a relationship with or that may be more or less costly. To address this conflict, we consider the best interests of clients in selecting Sub-advisers. You are under no obligation to utilize the services of the Sub- advisers or platform providers we recommend. No guarantees can be made that your financial goals or objectives will be achieved. Further, no guarantees of performance can be offered. Aspire will not maintain custody of clients’ funds or securities. However, Aspire does have limited rights to direct payments of clients’ funds, in the form of the right of deduction of Aspire’s fees from clients’ accounts that are authorized in the Advisory Agreement between clients and Aspire, and the right to initiate transfers of funds pursuant to third-party standing letters of authorization. (Please refer to Item 15 – Custody for more details.) Clients are advised that transactions in the account, account reallocations and rebalancing may trigger a taxable event for the client, with the exception of transactions in IRA accounts, 403(b) accounts and other qualified retirement accounts. For clients not enrolled in tax consulting services (explained below), Aspire may offer some tax advice incidental to the management of client assets. Clients are always urged to consult with their tax advisers before making any tax decisions. No guarantees can be made that a client’s financial goals or objectives will be achieved by us or by a Sub-adviser or third-party investment adviser recommended by the Firm. Further, no guarantees of performance can ever be offered by the Firm. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.) Tax Consulting Upon Adviser and client’s agreement, we may provide tax consulting to our asset management clients with investment portfolios in excess of $3,000,000, as part of the investment advisory services. In performing these services, Aspire will recommend an unaffiliated accountant for clients to use for accounting services. Aspire will help interface with the accountant and provide tax planning services in conjunction with the accountant. Eligible clients may enroll in tax consulting services by executing the Tax Consulting Addendum to the Investment Advisory Agreement. It is essential that a client provide the information and documentation we request regarding income, investments, taxes, insurance, estate plan, etc. We will discuss investment objectives, needs and goals, but the client is obligated to inform us of any changes. If Aspire is granted discretionary authority under an Investment Management arrangement, Aspire will implement investment decisions based on the tax planning strategy. If discretionary authority is not granted to Aspire, clients are responsible for implementing the investment decisions based on the tax planning strategy. Non-discretionary clients are under no obligation to implement recommendations through us. A non-discretionary client may implement their tax plan through any financial organization of their choice. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Educational Workshops Aspire regularly provides educational workshops that cover general financial and investment topics. Workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. However, strategies discussed during the workshops are generally best suited for attendees with investable assets of $250,000 or more. Aspire reserves the right to prevent individuals from attending workshops. Workshops are conducted free of charge. Tailor Advisory Services to Individual Needs of Clients Aspire’s advisory services are always provided based on your individual needs. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Clients may impose reasonable restrictions on investing in certain asset classes or any specific types of securities by advising their investment adviser representative of such restrictions. Financial Planning Services We provide financial planning to our asset management clients as part of the investment advisory services. Financial planning is a comprehensive relationship which incorporates many different aspects of a client’s financial status into an overall plan that intends to meet their goals and objectives. The financial planning relationship consists of face‐to‐face meetings and ad hoc meetings with clients and/or the client’s other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning services, we typically examine and analyze a client’s overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing the current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement. It is essential

that a client provide the information and documentation we request regarding income, investments, taxes, insurance, estate plan, etc. We will discuss investment objectives, needs and goals, but the client is obligated to inform us of any changes. We do not verify any information obtained from a client, their attorney, accountant or other professionals. Clients are under no obligation to implement recommendations through us. A client may implement their financial plan through any financial organization of their choice. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Retirement Plan Consulting Services We provide prudent advice and guidance to both ERISA and non-ERISA retirement plan sponsors through our retirement plan consulting services. Our retirement plan consulting services include, but are not limited to, the following services: Fiduciary Consulting Services
• Non-Discretionary Investment Advice. The Firm provides clients with general, non- discretionary investment advice regarding specific investments to be held by the plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the plan, consistent with the plan’s IPS. Clients have final decision-making authority regarding the selection, retention, removal or addition of investments or investment options.
• Investment Selection Services. The Firm provides clients with recommendations of investment options consistent with ERISA Section 404(c). Client retains the ultimate responsibility to comply with the requirements of Section 404(c), to monitor Section 404(c) compliance, and to follow the terms of the Plan document.
• Investment Due Diligence Review. The Firm provides clients with period due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. The Firm assists in monitoring of investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and conformance to the investment objectives. The Firm will make recommendations to maintain or remove and replace investment options. At least annually, the Firm will provide updated investment reports with investment recommendations to adhere to the investment objectives.
• Qualified Default Investment Alternative Advice. The Firm provides clients with non- discretionary investment advice to assist in developing qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. Clients retain the sole responsibility to provide all notices to participants required under Section 404(c)(5) of the Employee Retirement Income Security Act of 1974 (“ERISA”). Not all of the above services are provided to all clients. The particular services to be provided are described in a written agreement between the client and the Firm. The Firm acknowledges that in performing the services listed above it is acting as a “fiduciary” as such term is defined under ERISA Section 3(21)(A)(ii) for purposes of providing non- discretionary investment advice only. Aspire acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause the Firm to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, the Firm (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of the client’s retirement plan documents; (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets; (c) is not a “fiduciary” under ERISA with respect to any particular participant’s plan assets; (d) is not the “administrator” of the client’s retirement plan as defined in ERISA. Retirement plan consulting services are not investment management services, and the Firm does not serve as administrator or trustee of the plan. The Firm does not act as custodian for any client account or have access to client funds or securities (with the exception of having written authorization from the client to deduct advisory fees). In addition, the Firm does not implement any transactions in a retirement plan’s account. All recommendations of investment options and portfolios are submitted to the client for ultimate approval or rejection. The retirement plan which elects to implement any recommendations made by us is solely responsible for implementing all transactions. Non-Fiduciary Services
• Education Services to Plan Committee. The Firm provides education, training, and/or guidance for the members of the plan committee with regard to plan features, retirement readiness matters, or duties and responsibilities of the committee, including education with respect to fiduciary responsibilities.
• Participant Enrollment. The Firm assists clients with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. These meetings do not include recommendations with respect to any specific investment alternatives or options available to participants.
• Participant Education. The Firm arranges education sessions for plan participants about general investment principles and the investment alternatives available under the plan. Such education services may include preparation, edit or review of education materials and/or conducting investment education seminars and meetings for plan participants. Meetings may be on a group or individual basis. Education presentations do not take into account the individual circumstances of each participant and do not refer to the appropriateness of any specific investment alternatives or options for the participants.
• Benchmarking. Provide Client with comparisons of plan data (e.g. regarding fees, services, participant enrollment and contributions) to data from the plan’s prior years and/or a benchmark group of similar plans. Assist clients in identifying fees and other costs borne by the plan for, as specified by Client, investment management, recordkeeping, participant education, participant communication and/or services provided with respect to the plan.
• Service Provider/Vendor. Assist clients by acting as a liaison between the plan and service providers, product sponsors and/or vendors. In such cases, Adviser acts only in accordance with instructions from the client on investment or plan administration matters, and shall not exercise any judgment or discretion. Adviser can also assist with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 (the “Advisers Act”) and is required to meet the fiduciary duties required of an investment adviser, the services listed above as “Non-Fiduciary” are not considered fiduciary services for the purposes of ERISA since Aspire is not acting as a fiduciary to the plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to clients are listed and detailed in the Retirement Plan Consulting Agreement. We have the flexibility to tailor our services to the specific needs of our clients. This is open for discussion with each client but may include inclusion or exclusion of particular types of investments based on asset class, geographical, political or socio-economic factors. Retirement Plan Rollovers When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income 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 our client’s interests, so we operate under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our clients. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we are asked by a client or prospective client to make a recommendation from among these choices, we have a conflict of interest in that we have an incentive to recommend that a client roll over their retirement plan assets into an account to be managed by Aspire in order to earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Wrap Fee Program A “wrap fee program” is an investment management structure whereby the client pays a single fee for investment management and the execution of transactions in the client’s account. Aspire does not currently participate in any wrap fee programs. Assets Under Management As of December 31, 2023, Aspire’s assets under management totaled $388,282,637, with $377,128,535 managed on a discretionary basis and $11,154,102 managed on a non-discretionary basis.