Our Owners and Principals We have been providing portfolio management to our clients since 1993. In September 2011, we changed the firm’s name to Aspen Investment Management, Inc. We are required to disclose the persons owning twenty-five percent (25%) or more of our firm’s ownership interests. As of July 1, 2022, William J. Alphenaar, Jr. and Richard G. Knoor each own more than twenty-five percent (25%) of our firm’s common stock. Our Advisory Services We primarily provide discretionary portfolio management services. However, we do manage some accounts on a non-discretionary basis. Prior to engaging us to provide our services you will be required to enter into a written agreement with us setting forth the terms and conditions under which we will provide our services. Our specific services, terms of our compensation, method of payment, and other important information are explained in more detail below. If engaged by you, we will provide continuous advice to you regarding the investment of your funds based on your individual needs. Through our personal discussions with you, we analyze your investment goals and objectives and develop your investment policy. We invest your portfolio based on your investment policy. Account management is guided by your stated objectives in the policy (i.e., current income, conservative, balanced, growth or equity), as well as tax considerations. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. The initial investment and asset allocation recommendations are based on the financial information gathered from you including your net worth, risk tolerance, financial goals and objectives, your investment experience, and the investment restrictions you request. We also take into consideration the overall market and financial conditions. Based on this information, the investment recommendations are designed to provide an appropriate asset mix consistent with your objectives. We monitor your portfolio and performance in light of your stated goals and objectives. When you engage us to provide discretionary portfolio management services, we determine the frequency of our reviews and transactions placed for your account. You are free to contact and meet with us at any time if there are any questions about their accounts. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We

use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the Form ADV Part 2A Page 5 Aspen Investment Management, Inc. account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Participant Account Management We use a third-party platform to facilitate the management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of client funds since it does not have direct access to client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing him or her to connect an account(s) to the platform. Once the client account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Assets Under Management We manage your assets on either a discretionary or non-discretionary basis. As of December 31, 2023, we had $257,081,775 in client assets managed on a discretionary basis and $0 on a non-discretionary basis.