A. Description of the Advisory Firm ASB Consultores, LLC (hereinafter “ACL”) is a Corporation organized in the State of Florida. The firm was formed in June 2014, and the principal owner is Alex Silberwasser. B. Types of Advisory Services Portfolio Management Services ACL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ACL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring ACL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. ACL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. ACL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of ACL’s economic, investment or other financial interests. To meet its fiduciary obligations, ACL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, ACL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is ACL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Financial Planning and Consulting Services Financial planning may include, but is not limited to: ‐ Investment planning; life insurance; tax concerns; retirement planning; college planning; and debit/credit planning. ‐ Work with current insurance, tax advice and legal advice providers as appropriate in order to generate coordinated plans Consulting Services may include,

but are not limited to: - Supervise current advisor/bank relationships, focusing on: o Cost control o Product due diligence o New advisor/bank due diligence o Periodic evaluations and feedback: level of service, investment performance ‐ Setup and ongoing management of investment committee, as needed ‐ Design of internal investment process ‐ Investment policy creation and maintenance ‐ Industry research (asset managers, endowments, SWF, Portfolio theory, other topics) ‐ Read advisor/bank research and provide written opinion ‐ Analyze various investment projects and provide written opinion, as requested Services Limited to Specific Types of Investments ACL generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although ACL primarily recommends mutual funds and etfs to a majority of its clients. ACL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ACL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 ACL from properly servicing the client account, or if the restrictions would require ACL to deviate from its standard suite of services, ACL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. ACL does not participate in any wrap fee programs. E. Assets Under Management ACL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 745,740,194.00 $ 0.00 December 2023