Row Asset Management, LLC

ROW Asset Management, LLC, established in July 2010, is a financial advisor firm based in Newport Beach, CA. The firm specializes in providing discretionary investment advice to pooled investment vehicles and separately managed accounts. ROW offers three investment programs: the ROW Diversified Program, ROW Diversified 2X Program, and ROW RV Program. The firm manages over $2.5 billion in client assets on a discretionary basis as of December 31, 2024. Clients must meet a minimum investment of $1,000,000, subject to waiver by ROW. ROW charges management fees based on a percentage of the opening balance and receives performance allocations annually. The firm does not participate in wrap fee programs and does not manage non-discretionary client assets. ROW has full discretionary authority over client accounts and has established procedures to ensure fair and impartial trade allocations. The firm follows a systematic approach to trade execution and reviews client accounts daily. ROW has a Code of Ethics in place to address potential conflicts of interest and requires Access Persons to comply with federal securities laws. The firm does not have active agreements for client referrals and does not maintain custody of managed account funds or securities. Clients are provided with audited financial statements and monthly investment letters. ROW has the authority to vote client securities and follows proxy voting procedures in the best interests of clients. The firm does not require prepayment of fees longer than six months in advance and has no known financial conditions that could impair meeting contractual commitments.