Firm Description ASPEN CAPITAL MANAGEMENT, LLC, (“FIRM NAME”) was founded in 2002. ASPEN CAPITAL MANAGEMENT, LLC provides personalized confidential financial planning and investment management to individuals, trusts, estates, and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, limited investment tax planning, investment management, education funding, retirement planning, and limited estate planning. ASPEN CAPITAL MANAGEMENT, LLC is strictly a fee-only financial planning and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. However, we will often thank our clients for referrals with “thank you” gifts or gift certificates of $100 in value or less. Investment advice is provided, with the client making the final decision on investment selection. The client always maintains asset control. ASPEN CAPITAL MANAGEMENT, LLC places trades for clients under a limited power of attorney and does not maintain full discretion on any assets under management. Periodic reviews take place with clients to review their portfolio, discuss portfolio rebalancing that may be necessary and to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting (and in many cases multiple meetings), which may be by phone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Principal Owners Mike Mers is an 85% stockholder. Katie Dow is a 10% stockholder. Rachel Rant is a 5% stockholder. Types of Advisory Services ASPEN CAPITAL MANAGEMENT, LLC provides investment supervisory services, also known as asset management services; furnishes investment advice through consultations and provides financial planning services. On more than an occasional basis, ASPEN CAPITAL MANAGEMENT, LLC furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and estate planning. 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 interests 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. As of March 15, 2024 ASPEN CAPITAL MANAGEMENT, LLC manages approximately $1,010,000,000 in assets. All assets under management are managed on a non-discretionary basis. Tailored Relationships The goals and objectives for clients are documented in their financial plans. Investment policy statements, which define the client’s asset allocation targets, are created and reflect the client’s goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client

relationships. Financial Planning Agreement A financial plan is designed to help the client with all aspects of financial planning. The financial plan may include, but is not limited to: a net worth statement; a review of investment accounts; one or more retirement scenarios; and education planning with funding recommendations. Implementation of the recommendations is at the discretion of the client. The fee for a financial plan is predicated upon the facts known at the start of the engagement. The fee range is $2,000 to $10,000 and is negotiable. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. In the event that the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. Advisory Service Agreement Most clients choose to have ASPEN CAPITAL MANAGEMENT, LLC manage their assets in order to obtain ongoing advice and financial planning. Different aspects of the client’s financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Agreement may include, but is not limited to: asset allocation recommendations, investment management (including performance reporting), and recommended portfolio rebalancing when required. A quarterly fee is based on the total value of assets under management for development and implementation of the investment policy, account reviews, and investment policy updating. Our fees start at 1.00% per year and decline to 0.35% per year based on aggregate assets under management. Fees are negotiable. Fees for assets managed that are not custodied by Charles Schwab are billed per the rates above or they may be negotiated. Fees for each quarter are paid at the end of the quarter based on the total value of assets under management at the close of trading on the last business day of the quarter. Fees will be electronically deducted from your account(s). Fees for the initial quarter will be pro-rated and begin on the date the advisory agreement is signed. If either party chooses to terminate this agreement, fees will be pro-rated to the end of the 30 day notice period. Although the Advisory Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or ASPEN CAPITAL MANAGEMENT, LLC may terminate an Agreement by written notice to the other party. If either party chooses to terminate this agreement fees will be pro-rated to the end of the 30 day notice period. The portfolio value on the date of written notice is used as the basis for the fee computation. Asset Management Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually through our custodian, Charles Schwab. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Charles Schwab does not charge a transaction fee for the purchase or sale of individual stocks and exchange- traded funds, but does charge a transaction fee for the purchase or sale of some mutual funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. ASPEN CAPITAL MANAGEMENT, LLC does not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), corporate debt securities, commercial paper, certificates of deposit, municipal securities, and U. S. government securities. Initial public offerings (IPOs) are not available through ASPEN CAPITAL MANAGEMENT, LLC. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying ASPEN CAPITAL MANAGEMENT, LLC in writing and paying the rate detailed in the Advisory Services Agreement. ASPEN CAPITAL MANAGEMENT, LLC may terminate any of the aforementioned agreements at any time by notifying the client in writing.