OUR COMPANY SP Asset Management LLC, a California Limited Liability Company, offers discretionary management of investment portfolios and ongoing financial planning for individuals, pension and retirement plans, trusts, and business entities, in accordance with the investment objective(s) of the client. SP Asset Management LLC was formed in January 2022. SP Asset Management LLC succeeded to the business of Sandeep Pandya dba SP Asset Management, which had operated as a registered investment adviser since 1995. The principal owner of SP Asset Management LLC is Sandeep Pandya. Throughout this disclosure brochure, we refer to SP Asset Management LLC as “SP Asset Management” or “the Firm.” OUR INVESTMENT TEAM Sandeep Pandya, President and CEO Mr. Pandya is an experienced investment advisor who has been providing investment advice to individuals and organizations since 1995. Mr. Pandya has both Bachelors and Masters degrees in mechanical engineering and has over twenty-seven years of professional experience providing investment advisory services. Additional details about Mr. Pandya can be found in his Form ADV Part 2B brochure supplement. Page 5 of 19 SP Asset Management LLC OUR SERVICES Investment Advisory Services At SP Asset Management we provide investment supervisory and portfolio management services on a fully discretionary basis. On more than an occasional basis, we furnish advice to clients on matters not involving securities. Financial Planning Services SP Asset Management’s financial planning services are available on a “one-time” or “ongoing” basis, and range from comprehensive financial planning to more focused consultations, depending on the needs of each client. Such planning will at times, typically when requested by a client, involve discussions concerning alternative investments such as private placements. Generally, SP Asset Management performs financial planning for sophisticated clients and evaluates the Client’s financial, business, and investment information and makes recommendations designed with the intention of achieving the client’s overall goals and objectives. Clients have the option of utilizing the Firm to implement certain investment recommendations but are under no obligation to do so. Advice and recommendations may also be given on non-securities matters and any implementation of financial planning recommendations is entirely at the client’s discretion. Clients are always free to accept or reject any or all recommendations made by SP Asset Management, and clients retain the authority and discretion on whether or not to implement any recommendations. Clients should understand that a potential conflict of interest exists if the Firm recommends its own investment management services. Financial planning recommendations are based on the client’s financial situation at the time the recommendations are provided and are based on the information provided by the client. Past performance is in no way an indication of future performance and SP Asset Management cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As a client’s financial situation, goals, objectives, or needs change, the Client is strongly urged to promptly notify SP Asset Management. Private Fund Management Services SP Asset Management offers advisory services to private funds focused on fund of funds investments in venture capital and private equity OUR ASSETS UNDER MANAGEMENT As of December 31, 2023, the total amount of client assets managed by SP Asset Management LLC is $1,389,577,962. Of this total amount, $972,818,805 of client assets are managed on a discretionary basis and $416,759,157 of client assets are managed on a non-discretionary basis. FEES & COMPENSATION INVESTMENT MANAGEMENT FEES In the event the client desires, the client can engage the Firm to provide discretionary investment management services on a fee-only basis. The Firm charges an annual investment management fee based upon a percentage of the market value of the assets managed by the Firm (including cash and Page 6 of 19 SP Asset Management LLC cash equivalents). Although SP Asset Management’s fees are negotiable, they generally follow the below listed schedule. Assets Under Management Annual Fee (%) Applicable Quarterly Fee $0 to $999,999 1.00% 0.250% $1,000,000 to $1,999,999 0.90% 0.225% $2,000,000 to $2,999,999 0.80% 0.200% $3,000,000 to $3,999,999 0.70% 0.175% $4,000,000 to $4,999,999 0.60% 0.150% $5,000,000 to $9,999,999 0.50% 0.125% $10,000,000 and above 0.25% 0.0625% The Firm's annual investment management fee shall be pro-rated and paid quarterly, in arrears, based upon the market value of the assets (including cash and cash equivalents) on the last day of the previous quarter. FINANCIAL PLANNING FEES The Firm’s fees for financial planning services vary and are dependent upon the scope and complexity of the requested services, and are specified as part of the client’s written agreement. The Firm generally charges a fixed fee for its financial planning services that range from $10,000 or higher, depending on the complexity of the services being provided. These rates can be negotiable based on the sole discretion of the Firm. An invoice for services is issued on completion of the services, which is payable upon receipt. Clients can terminate the written agreement, without penalty, at any time upon written notice. At the time of termination, the Firm will invoice for the work completed based on the amount of work completed by the Firm as of the date the notice of termination is received. PRIVATE FUND FEES Compensation received by the Firm from the private fund it advises generally comprise management fees, based on a percentage of assets managed, and carried interest. Management Fee Management fees charged to the fund can vary and are established pursuant to negotiations with investors in

the fund and set forth in each fund investor’s respective documents. The Firm, in its sole discretion, has in the past and expects in the future to reduce or waive its standard fees for fund investors. Any management fees charged will be payable quarterly in arrears and deducted from the assets of the fund as described in the fund’s governing documents. Additionally, consistent with the governing documents of the fund, the fund typically bears certain out-of-pocket expenses incurred by the Firm in connection with the services provided to the fund. Further details about certain common fees and expenses are set forth below, and investors and prospective investors should review the fund’s governing documents for additional information about fund fees and expenses. Page 7 of 19 SP Asset Management LLC Carried Interest Investments made by the Firm on behalf of the fund are subject to a sharing of realized profits known as carried interest, which is a percentage of the investment income and net realized capital gains and losses. The Firm, in its sole discretion, has in the past and expects in the future reduce or waive its entitlement to receive carried interest with respect to investments by fund investors. Generally, for the fund, the Firm receives carried interest, after achievement of various performance hurdles. The terms of any carried interest arrangement, including a description of the carried interest calculation methodology, are set forth in the fund’s governing documents. IMPORTANT ADDITIONAL INFORMATION Fees Negotiable The Firm, in its sole discretion, has the ability to charge a lesser investment management fee based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, client negotiation, length of client relationship, etc.). In addition, for family and friends of the Firm, the Firm may, in its sole discretion, reduce or waive fees in their entirety. Although the Firm believes its advisory fees are competitive, clients should be aware that lower fees for comparable services may be available from other sources. Direct Debiting of Client Accounts We generally directly debit our advisory fees from our clients’ accounts on a quarterly basis. We will only do this under the following three conditions. First, the client must provide written authorization permitting SP Asset Management’s fees to be paid directly from the client’s account. Second, the client must have their account held by an independent custodian. Third, the custodian agrees to send to the client a statement, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to SP Asset Management. Clients are informed that it is their responsibility to verify the accuracy of the fee calculation and that the custodian will not determine whether the fee is properly calculated. Termination of Client Relationship Either party has the ability to cancel an agreement for any reason upon written notice. Upon termination of any account, any unpaid, earned fees will be due and payable to the firm, and the Firm will refund any unearned, prepaid fees. Mutual Fund and ETF Fees All fees paid to SP Asset Management for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (“ETFs”) to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee (including 12b-1 fees). If the fund also imposes sales charges, a client will pay an initial or deferred sales charge. A client could invest in a mutual fund or ETFs directly, without the services of SP Asset Management. In that case, the client would not receive the services provided by SP Asset Page 8 of 19 SP Asset Management LLC Management which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. To the extent that client assets are invested in money market funds or cash positions, the fees for monitoring those assets are in addition to the fees included in the internal expenses of those funds paid to their own investment managers, which are fully disclosed in each fund’s prospectus. Accordingly, the client should review both the fees charged by the funds and the fees charged by SP Asset Management to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Trading and Other Costs All fees paid to SP Asset Management for investment advisory services are separate and distinct from transaction fees charged by broker dealers associated with the purchase and sale of equity securities, fixed income and options. Such additional fees include, among others, custodial fees, private fund management and incentive/performance fees, other transaction related fees, IRA and Qualified Retirement Plan fees, interest charged on margin borrowing, interest charged on debit balanced, “spreads” imposed by brokers and dealers representing implicit transaction costs, commissions and transfer taxes. In addition, fees do not include the services of any co-fiduciaries, accountants, broker dealers or attorneys. Please see the section entitled “Brokerage Practices” of this disclosure brochure for additional information on brokerage and other transaction costs. PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT SP Asset Management does not accept performance-based fees (e.g., fees based on a share of capital gains on or capital appreciated of the assets in a client’s account). Please note that the SPV Fund does not charge separate fees. See additional information in the section titled Fees & Compensation.