Aspen Partners, Ltd.

Aspen Partners, Ltd. is a registered investment adviser established in 1996, providing investment advisory services to pooled investment vehicles. The firm is organized as an S-Corporation under Delaware law and became registered with the state of Georgia in March 2020. The principal owners are William Ware Bush and Bryan R. Fisher, with George Vick serving as the Chief Compliance Officer. Aspen offers tailored advisory services to Funds on a discretionary basis, managing $4,416,386 in Client assets as of December 31, 2020. The firm charges management fees based on a percentage of assets under management, with fees deducted monthly in arrears. Clients may also incur operating expenses allocated pro rata. Aspen's personnel are compensated based on revenue generated from client assets, potentially presenting a conflict of interest. The firm primarily serves private pooled investment vehicles and does not participate in wrap fee programs. Aspen exercises full discretion in managing client assets, with authority to select investments in line with client objectives. The firm votes proxies for client securities in the best economic interests of the clients, guided by fiduciary principles. Aspen maintains a Code of Ethics and has had no material disciplinary events. Clients receive monthly statements and annual audited financial statements. The firm's financial condition is sound, with no impairments affecting its ability to meet commitments.