Form ADV Part 2A, Item 4 Altfest’s registration was granted by the SEC on February 2, 1983. The principal owners of the Firm, i.e., the individuals who control 25% or more of Altfest, are Lewis Jay Altfest (CRD Number 4029), beneficial majority owner of the Firm, and Andrew Altfest (CRD Number 6316746), President of the Firm. The Firm is not publicly owned or traded. As of December 31, 2022, the Firm managed, on a discretionary basis $1,373,290,923, which represented 3,188 accounts, and managed on a nondiscretionary basis $16,794,668, which represented 95 accounts. Client assets are managed on an individualized basis. Clients may impose restrictions on their accounts. The Firm does not sponsor any wrap programs. Types of Advisory Services Altfest offers the following advisory services to its clients: Investment Management, Management of Pooled Investment Vehicles, Financial Planning, and ERISA Fiduciary Services. Please see the disclosure below in this Item 4 for additional information regarding each of these services. Investment Management We are in the business of managing individually tailored investment portfolios. Our Firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. With one exception, Altfest manages all client accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives (e.g., balanced, diversified, fixed income, growth, moderate, income/balanced, income/diversified, income/growth, and income/moderate), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Management of Pooled Investment Vehicles Altfest offers two pooled investment vehicles to its clients: Altfest Alternative Value Fund, LLC (the “AAVF Funds”) and Arden Woods Real Estate, LLC (the “Arden Woods Real Estate Fund”) (collectively, the “Funds”). The Funds are Delaware limited liability companies that were formed, in part, to facilitate investment in private offerings. Interests in the Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Funds are exempt from registration with the SEC under the Investment Company Act of 1940, as amended. Altfest Management, LLC, an affiliate of Altfest, is the managing member of the AAVF Funds, and ArdRE Management, LLC, also an affiliate of Altfest, is the Managing Member of Arden Woods Real Estate Fund (collectively, the “Altfest Affiliates”). The Altfest Affiliates have discretionary authority over the respective fund for which each affiliate serves as the managing member. Altfest charges an advisory fee to a client who invests in either of the Funds. Clients may invest in either or both Funds, and investors who are not clients of the Firm may invest in either or both Funds. All relevant information, terms and conditions relative to the Funds, including suitability, risk factors and potential conflicts of interest, are set forth in the Confidential Private Offering Memorandum, Investor Agreement, and Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Funds. Given the above discussion relative to the objectives, suitability, risk factors and qualifications for participation in the Funds, Altfest may give advice or take action with respect to the Funds that differs from the advice that Altfest gives its clients that have a wealth management or portfolio management account that is not invested in either of the Funds. Financial Planning We provide financial planning services on topics such as retirement planning, cash flow and debt management, work benefits, and estate planning. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. In general, the financial plan will address any or all of the areas identified immediately below. A client may select only the areas they wish to cover, and do not have to choose all of the below services. Should the client choose to implement the recommendations contained in the financial plan, we suggest the client work closely with his/her attorney and/or accountant. A client is under no obligation to implement our financial plan recommendations or to utilize our Firm for investment management. College Savings: Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren, if appropriate. Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. Estate Planning: This usually provides for ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts.

We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. Financial Goals: Helps clients identifying their financial goals and planning on how to reach them. Identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how you budget for your goal. Investment Analysis: This may involve providing information on the types of investment vehicles available, employee stock options, investment analysis and strategies, asset selection and portfolio design. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ERISA Fiduciary Services 3(21) ERISA Fiduciary Services - (1) identifying investment objectives and restrictions; (2) allocating plan assets to various objectives; (3) selecting money managers to manage plan assets in ways designed to achieve objectives; (4) selecting mutual funds that plan participants can choose as their funding vehicles; (5) monitoring performance of money managers and mutual funds and making recommendations for changes; and (6) selecting other service providers, such as custodians, administrators and broker-dealers. 3(38) ERISA Fiduciary Services - Manage your plan assets with full discretionary authority, making and implementing investment decisions, all without prior consultation, subject only to such limitations as you may specify in writing. Altfest acts as a Discretionary Investment manager as defined in Section 3(38) of ERISA that is ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the plan in accordance with the plan’s the plan’s Investment Policy Statement. Under this authority, Altfest may remove or replace the investment alternatives available under the plan at its discretion. Altfest provides retirement plan consulting services to employee benefit plans and their fiduciaries based upon an analysis of the needs of the plan. Altfest uses various internet-based 401(k) daily valuation retirement plan platforms to deliver its 401(k) services to businesses across the United States. The platforms allow a company to offer its employees the widest possible array of investment options using daily valuation connectivity and multi-fund/multi-family investments. A) In connection with providing these platforms, Altfest will enter into its agreement with the Responsible Plan Fiduciary and such plan’s trustee(s) to provide discretionary and non- discretionary investment advice for the 401(k) plan. The decision whether to implement or at upon Altfest’s recommendations or advice rests solely with the Responsible Plan Fiduciary. The services provided by Altfest to such plan typically include the following:Assist in the development of an Investment Policy Statement, which establishes the investment policies and objectives for the plan; B) Assist in the search for and selection of mutual funds; C) Evaluate plan costs, mutual fund performance and risk; D) Monitor the suitability of all selected investment options and recommend changes when appropriate; E) Provide assistance to plan fiduciary(ies) regarding ongoing supervision and due diligence of mutual funds performance and risk metrics; F) Assist the plan fiduciary(ies) in evaluating how to avoid or manage conflicts of interest; and G) When engaged to do so, Altfest may assist in the education of the plan participants about general investing principles and the investment alternatives available under the plan. The education component will customarily be delivered through group meeting, one-on-one counseling, or a proprietary interactive video workshop designed to provide investment education for participants of company-sponsored 401(k) plans. A participant may access the website by registering as a user and accepting terms of use. The participant will then be guided through a series of videos that describe the advantages of joining the company plan, saving for retirement, and general principals of investing. Each participant is offered a risk questionnaire to asset their risk tolerance. Participants are then guided to potential investment allocation solutions provided by the company plan (the mutual fund lineup). Your plan shall consist of all securities, cash and cash equivalents and other assets in your plans except those assets which, by mutual agreement, shall be specifically excluded. Altfest does not hold or receive any of the client’s funds or securities, other than payment for Altfest’s services. The Plan’s assets will be held by a custodian selected by the client, and the client will be solely responsible for paying all of the Custodian’s fees. Client understands that Altfest is not authorized to establish or maintain custodial arrangements for the Plan. All transactions will be consummated by payment to, or delivery by, Client or such other party as Client may designate in writing (the "Custodian"), of all cash and/or securities due to or from the Plan. Client shall direct the Custodian to segregate the assets of the Plan and to invest and reinvest them in accordance with the directions transmitted by Altfest. Client understands that the Firm shall not be responsible for any loss incurred by reason of any independent act or omission of the Custodian or any other party, to the extent permitted by law. The Custodian should provide statements for the Plan. Altfest encourages the client to notify Altfest promptly if the client does not receive statements from the custodian on at least a quarterly basis. Altfest will hold educational seminars for the plan employees and provide information on the plan specifics and allocation choices. All client accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). Altfest will provide consulting services to the plan fiduciaries as described above. Only if a participant engages Altfest as an Investment Advisor will we provide individualized advice regarding their investments in the company plan. We act as the registered investment adviser to other clients and may take action with respect to other clients that may differ from the timing and nature of action taken with respect to your Plan. We shall have no obligation to purchase or sell for your Plan any security which we, or our principals or employees, may purchase or sell for themselves or for any other clients.