Description of Firm
Ascend Interplay, LLC is a registered investment adviser based in New York, NY. We are organized
as a limited liability company ("LLC") under the laws of the State of Delaware. We are owned by Mark
Peter Davis and Kevin Tung.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Ascend Interplay, LLC and the
words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Services are broken into two categories: 1) clients that onboard all of their assets ("Members") and 2)
clients that onboard only a portion of their assets ("Partial Members").
Portfolio Management Services
We offer non-discretionary portfolio management services. Our investment advice is tailored to meet
our clients' needs and investment objectives. If you enter into non-discretionary arrangements with our
firm, we must obtain your approval prior to executing any transactions on behalf of your account. You
have an unrestricted right to decline to implement any advice provided by our firm on a non-
discretionary basis.
Types of Investments
We offer advice on equity securities, warrants, corporate debt securities (other than commercial
paper), commercial paper, certificates of deposit, municipal securities, variable life insurance, variable
annuities, mutual fund shares, United States government securities, options contracts on securities,
options contracts on commodities, futures contracts on tangibles, futures contracts on intangibles,
private placements, money market funds, real estate, REITs, PIPEs, derivatives, structured products,
ETFs, leveraged ETFs, digital assets, interests in partnerships investing in real estate and interests in
partnerships investing in oil and gas interests.
We may advise you on various types of investments based on your stated goals and objectives. We
may also provide advice on any type of investment held in your portfolio at the inception of our
advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
Ascend Interplay may also refer Clients to an accountant, estate attorney or another specialist, as
appropriate for their unique situation. The accountant, attorney and other specialists
referred to clients
may be affiliated through common control with Ascend Interplay, which may present certain conflicts of
interests.
Provisional Members
Clients that only allocate between $250,000 and $2,000,000 of their assets to us are considered
Provisional Members. While an advisory client, the Provisional Member will pay a one-time fee based
upon total committed capital. No other advisory fee is charged. Please refer to Item 5 for further details
on fees. Please note that the Provisional Member's total committed capital may not fall below $250,000
or exceed $2,000,000. If the Provisional Member wishes to exceed the $2,000,000 threshold, a Partial
Membership Agreement must be executed with Ascend Interplay.
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 you.
When we provide investment advice to you regarding your 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 your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. 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 your 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
your best interest.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $172,721,124 in client
assets on a non-discretionary basis.