A. Firm Information
Aspire Growth Partners, LLC (“Aspire” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of the
State of Florida. Aspire was founded in January 2021. Aspire is owned and operated by Steven S. Zangmeister
(Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Aspire.
For information regarding this Disclosure Brochure, please contact Richard H. Harris (Chief Compliance Officer) at (330)
239-1776.
B. Advisory Services Offered
Aspire offers investment advisory services to individuals, high net worth individuals, trusts, estates, retirement plans,
charitable organizations, and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of
interest. Aspire's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading.
Investment Management Services
Aspire provides customized investment advisory solutions for its Clients. This is achieved through continuous personal
Client contact and interaction while providing discretionary investment management and related advisory services. Aspire
works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial
situation in order to create a portfolio strategy. Aspire will then construct an investment portfolio, consisting of diversified
mutual funds, exchange-traded funds (“ETFs”), individual stocks and individual bonds to achieve the Client’s investment
goals. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of the Client. The
Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax
considerations.
Aspire’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that
have been held for less than one year to meet the objectives of the Client or due to market conditions. Aspire will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance
agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments
to be held in their respective portfolio, subject to acceptance by the Advisor.
Aspire evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. Aspire may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Aspire may
recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash
positions as a possible hedge against market movement. Aspire may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or
class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Aspire accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a
Client regarding a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement
Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another,
one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based
account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee
Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are
laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new
(or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning
Services
Aspire will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial
planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings,
education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or
financial consultation rendered to the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their
investment programs, commence or alter retirement savings, establish education savings and/or charitable giving
programs.
Where appropriate, depending on client needs and the complexity of a client’s unique situation, Aspire will also refer
Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial
planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and
recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or
consultations are typically completed within six (6) months of contract date, assuming all information and documents
requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests
of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the amount of
advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or
maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the
Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
Aspire provides retirement plan advisory services on behalf of company retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting
its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and
Plan Sponsor. Services generally include:
● Vendor Analysis
● Plan Participant Enrollment and Education
● Investment Policy Statement (“IPS”) Design and Monitoring
● Investment Oversight and/or Management Services (ERISA 3(21) and 3(38))
● Performance Reporting
● Ongoing Investment Recommendation and Assistance
● ERISA 404(c) Assistance
● Benchmarking Services
These services are provided by Aspire serving in the capacity as a fiduciary under the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided
with a written description of Aspire’s fiduciary status, the specific services to be rendered and all direct and indirect
compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Aspire to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client.
These services may include:
● Establishing an Investment Strategy – Aspire, in connection with the Client, will develop a strategy that seeks to
achieve the Client’s goals and objectives.
● Asset Allocation – Aspire will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Aspire will develop a portfolio for the Client that is intended to meet the stated goals and
objectives of the Client.
● Investment Management and Supervision – Aspire will provide investment management and ongoing oversight of
the Client’s investment portfolio.
D. Wrap Fee Programs
Aspire does not manage or place Client assets into a wrap fee program. Investment management services are provided
directly by Aspire.
E. Assets Under Management
As of December 31, 2023, Aspire manages $873,506,733 in Client assets, $825,384,454 of which is managed on a
discretionary basis and $48,122,279 on a non-discretionary basis. Clients may request more current information at any
time by contacting the Advisor.