Our Firm Aspire Strategist Portfolios LLC (“Aspire”, “we” or “our”) is a Delaware limited liability company located in New York, New York. Aspire was founded in 2023 and is a wholly owned subsidiary of Vela Azure Holdings LLC. Aspire provides non-discretionary advisory services to financial institutions through our provision of model portfolios we design and develop. Our institutional clients use our model portfolios to assist with and support the management of their underlying client accounts. Our Business Aspire’s primary advisory business consists of providing financial institutions, such as banks, broker-dealers and other investment advisers (collectively, “our Clients” or “Aspire’s Clients”) with non-discretionary advisory services in the form of model portfolios. Aspire’s Clients, in turn, use the model portfolios to help manage the assets of their underlying client accounts (the “Underlying Clients”). In most cases Aspire and Aspire’s Clients will both enter into an agreement with a third-party “Model Platform” provider (such as a “Turn-Key Asset Management Platform” i.e. TAMP or a “Model Marketplace”) where Aspire will maintain and deliver changes to its model portfolios. Aspire’s Clients will then subscribe to Aspire’s model portfolio(s) on the Model Platform and then make them available to their Underlying Clients. In some cases, Aspire may provide model portfolios and changes to our model portfolios directly to our Clients via an agreed- upon delivery method rather than through the Model Platform’s. With these types of arrangements, Aspire and our Clients will be the sole parties to an advisory agreement. Aspire’s Clients make the decision to use our model portfolio(s) to implement all or part of their Underlying Clients’ investment plans and in the event of Aspire’s issuance of recommended changes to our model portfolios, to accept or reject such changes to our model portfolios. Underlying Clients are typically retail investor accounts. Aspire does not provide investment advice directly to Underlying Clients and does not have advisory or advisory fiduciary relationships with or serve as an ERISA fiduciary to the Underlying Clients. Rather, it is Aspire’s Clients who are responsible for determining if Aspire’s model portfolios are suitable vehicles for achieving each of their Underlying Client’s investment objectives and for all other aspects of the advisory client relationship, such as decisions concerning suitability, risk tolerance, and best execution. It is therefore Aspire’s Clients (and not Aspire) who maintain the advisory relationship with each of the Underlying Clients. In all instances, it is Aspire’s Clients (and not Aspire) who are responsible for evaluating the appropriateness of utilizing our model portfolios to implement the investment strategies for Underlying Clients. To the extent this Brochure is ever delivered to Underlying Clients, this Brochure will be delivered for informational purposes only and not because Aspire has an advisory relationship with any Underlying Clients. Our Services Aspire Model Portfolios Aspire’s team of portfolio managers construct and develop model portfolios which utilize investment strategies designed to target specific risk and return objectives, investment goals (such as income or capital appreciation), and/or investment time horizons (referred to as “Aspire Model Portfolios” or “Model Portfolios”). Aspire Model Portfolios employ multi-asset investment strategies which invest in a diversified set of asset classes, including, but not limited to, U.S. equities, international developed equities, emerging market equities, investment-grade bonds, high-yield bonds, inflation-protected bonds, mortgage-backed securities, and cash or cash equivalents. Aspire Model Portfolios are implemented using exchange-traded funds (“ETFs”), mutual funds, or a combination thereof. Aspire’s portfolio managers monitor and review the performance of our Model Portfolios on a periodic basis and, as necessary, recommend to our Clients changes to the asset allocations and/or securities used in the Model Portfolios. Aspire’s flagship core offering consists of a suite of eight multi-asset model portfolios implemented with ETFs (referred to as “Aspire Model Allocation Portfolios”,

“Aspire MAPs”, or “MAPs”). MAPs are long-term investment strategies tailored to various risk profiles to cover a broad spectrum of investment goals. The target allocations for MAPs range from 20% equity / 80% fixed income to 90% equity / 10% fixed income. MAPs are not customizable. However, Aspire may work with our Clients or prospective clients to develop customized multi- asset model portfolios that take into consideration Client-directed investment restrictions, investment objectives, and other factors. As Aspire MAPs are non-customized, we will offer these non-customized MAPs and other non-customized Model Portfolios to multiple Clients and Model Platforms. As a result, Aspire has adopted a model delivery policy to deliver non-customized Model Portfolios, and model change recommendations concurrently to our Clients during non-trading market hours, to minimize the risk of preferential treatment such as selective disclosure. In connection with the provision of the Aspire Model Allocation Portfolios, Aspire will directly manage proprietary accounts (i.e., “Performance Measurement Accounts” or “PMAs”) that include nominal investments in securities recommended in Model Portfolios for the sole purpose of tracking investment performance. Refer to Item 11 of this Brochure entitled Code of Ethics, Participation or Interest in Client Transactions and Personal Trading for a further discussion about Aspire’s Performance Measurement Accounts. Aspire is compensated for our provision of our Model Portfolios via a portion of the annual asset-based advisory fee Aspire’s Clients charge their Underlying Clients whose accounts are managed utilizing one or more of our Model Portfolios. Refer to Section 5 of this Brochure entitled Fees and Compensation for further information about our fee arrangements. Aspire Asset Allocation Strategies Aspire’s portfolio managers construct and develop asset allocation investment strategies (referred to as “Aspire Asset Allocation Strategies” or “Asset Allocation Strategies”) based on a Client’s risk tolerance, investment time horizon, return objectives, investment objectives and restrictions and other investment guidelines (collectively “Investor Profile”). Unlike Aspire’s Model Portfolios, Asset Allocation Strategies are constructed using the Client’s existing portfolio(s). Aspire does not recommend individual securities for Asset Allocation Strategies. This service provides ongoing analysis of Client portfolios which may include total investment performance (i.e., individual, or aggregated portfolio analysis), underlying factors affecting investment performance, diversification strategies and periodic recommendations in the form of asset class weightings. Our portfolio managers may use proprietary tools, third-party research or applications, quantitative and qualitative factors when constructing the Client’s Asset Allocation Strategy. Aspire provides these advisory services on a non-discretionary basis and the Client has the sole authority to accept, reject, or execute in part or in full, any of the recommendations made by Aspire’s portfolio managers. Thought Leadership Aspire will also provide information, analysis, and perspective relating to investments and markets generally. Our (“Thought Leadership”) communications are intended to be informational, non-customized, and distributed directly to investment professionals, or through third-party media sources such as television and investment-themed publications, or at broad-venue events such as industry conferences. Any analysis we provide in these presentations is non-customized and precludes consideration of appropriateness or suitability to non-professional or retail investors and represents solely the opinion of Aspire. Aspire does not charge for our Thought Leadership communications. While Thought Leadership is generally independent of our Model Portfolios and Asset Allocation Strategies, our commentary may reference asset classes and underlying investment strategies used in our Model Portfolios and Asset Allocation Strategies. Assets Under Management As of the date of this Brochure, Aspire’s regulatory assets under management are approximately $29,829,764 which are managed on a non-discretionary basis.