AHARA ADVISORS LLC

Item 1 Cover Page Ahara Advisors LLC 201 Montgomery St, Ste 263 Jersey City, NJ 07302 201-298-3144 www.aharaadvisors.com May 2025 This Brochure provides information about the qualifications and business practices of Ahara Advisors LLC (“Ahara Advisors”, “us”, “we”, “our”). If you have any questions about the contents of this Brochure, please contact us at 201-308-3283 or via email at kamel.Tarazi@aharaadvisors.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. information about Ahara Advisors is also available via the SEC’s website Additional www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Ahara Advisors is 312385. The SEC’s web site also provides information about any persons affiliated with Ahara Advisors who are registered, or are required to be registered, as Investment Adviser Representatives (IARs) of Ahara Advisors. Ahara Advisors LLC is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them. Ahara Advisors ADV Part 2A & 2B July 2024 Page 1 of 29  Item 2 Material Changes This section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last annual amendment filing of this Brochure. This section will also identify the date of our last annual Brochure update. We will ensure that you receive a summary of any material changes to this, and subsequent Brochures, within 90 days of the close of our business’ fiscal year end, which is December 31. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you information to obtain the complete brochure. Currently, our brochure may be requested at any time, without charge, by contacting Kamel Tarazi at 201-308-3283. Since our last annual amendment filed on February 4th, 2025, our firm has the following material changes to disclose: • Our firm has a new financial industry affiliation/financial conflict of interest to disclose. Please see Item 10 for more information. Ahara Advisors ADV Part 2A & 2B July 2024 Page 2 of 29  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................ 1 Item 2 – Material Changes .................................................................................................................. 2 Item 3 – Table of Contents .................................................................................................................. 3 Item 4 – Advisory Business Introduction ............................................................................................. 4 Item 5 – Fees and Compensation ........................................................................................................ 7 Item 6 – Performance Based Fee and Side by Side Management ....................................................... 11 Item 7 – Types of Client(s) ................................................................................................................. 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 11 Item 9 – Disciplinary Information ...................................................................................................... 18 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 18 Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ............... 19 Item 12 – Brokerage Practices ........................................................................................................... 21 Item 13 – Review of Accounts ........................................................................................................... 23 Item 14 – Client Referrals and Other Compensation .......................................................................... 24 Item 15 – Custody ............................................................................................................................. 24 Item 16 – Investment Discretion ....................................................................................................... 25 Item 17 – Voting Client Securities ...................................................................................................... 25 Item 18 – Financial Information ........................................................................................................ 26 ADV Part 2B Brochure Supplement – Aseem Garg ............................................................................. 27 Ahara Advisors ADV Part 2A & 2B July 2024 Page 3 of 29  Item 4 – Advisory Business Introduction Our Advisory Business Ahara Advisors is a limited liability company formed under the laws of the state of Delaware in 2020 and has been operating as an investment adviser since 2021. Ahara Advisors was founded in November 2020 by Aseem Garg. Ahara Advisors is wholly owned by Aseem Garg. Ahara Advisors aims to bring an institutional approach to financial consulting for families and institutions. Services Trade Execution As part of our Trade Execution service, we will execute the trade recommendations resulting from the Financial Consulting service. Trades could be executed in individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all previously mentioned securities. Portfolios will be designed to meet a particular investment goal that the Firm believes is suitable for the specific client and their circumstances. Once the appropriate portfolio has been determined, portfolios are continuously, and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals, and objectives. Portfolio Management As part of our Portfolio Management service, a portfolio is constructed, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously, and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals, and objectives. Financial Consulting Ahara Advisors offers two stages of financial consulting services to family clients. 1. The State of the Family report, including recommendations, delivered electronically and presented in-person. 2. Ongoing Financial Consulting and Support for a client. Additionally, Ahara Advisors may consult with institutions on an ad-hoc basis to provide investment due diligence, analysis, and modeling services. Ahara Advisors ADV Part 2A & 2B July 2024 Page 4 of 29  State of the Family Report The State of the Family Report (“Report”) process consists of meetings, data collection, and the generation of a summary report. The report is generated and addresses the following: Values & Ambitions Ahara Advisors looks to understand the values and ambitions of the client, and to articulate those back to the family to get agreement. These include a client’s desires on education, retirement, economic security, risk, inheritance, and philanthropy. Net Worth Analysis Ahara Advisors will try to get a full picture of all assets and liabilities for a client, which helps establish a financial profile, which provides many of the building blocks for other analyses including tax liabilities from unrealized capital gains. Cash Flow Analysis (Income & Expense) Ahara Advisors helps the client to understand the full sources of income and expenses, including dividends, interest, salaries, bonuses, as well as taxes, mortgage payments, fees paid to investment products, and advisors. Economic Accrual Analysis Cash flow analysis is not complete because it misses items such as principal paid on a mortgage, and vesting schedules for stock or option awards etc. Economic accrual analysis provides a client the evolution of their net worth over time. Tax & Liability Analysis Ahara Advisors will analyze a client's liabilities (mortgages, unrealized capital gains, etc.) and suggests ways of improving the risk profile while reducing the cost of liabilities. This could include recommendations such as extending the duration of a mortgage or refinancing it to a lower rate. Risk Analysis Ahara Advisors provides clients with stress scenarios customized to their situations, by highlighting the greatest sources of financial vulnerability. Ahara Advisors uses those stress scenarios to recommend risk mitigation opportunities. These scenarios may include major market events (2008 financial crisis, 1970’s stagflation, etc.) in addition to stress scenarios specific to a client’s situation (such as a natural disaster in a geographic area where a client has concentrated their assets, or the untimely passing of a family’s primary bread winner). Long Term Planning Ahara Advisors will analyze whether the clients’ current posture is in tune with their values and ambitions. This could relate to paying for secondary education for children, to retirement, estate planning, or to other plans more specific to the client. Ahara Advisors ADV Part 2A & 2B July 2024 Page 5 of 29  Timeline Initial recommendations are completed and delivered within ninety (90) days, contingent upon the timely delivery of all required documentation by the client. Financial Consulting and Support The State of the Family process is a prerequisite for entering into a financial consulting and supporting relationship.. Client Communication Ahara Advisors will schedule quarterly meetings to discuss goals, recommend changes to the client’s portfolio, monitor progress and update any changes. There will also be ongoing check-ins via phone or email for accountability, encouragement, and to address required changes along the way. Portfolio Reporting & Analytics Services All clients receive access to a portfolio analytics module that provides transparency into all of State of the Family report supporting documents, on an ongoing manner. Clients subscribed to the ongoing financial consulting and support will have access to this quarterly data for the whole portfolio, updated daily public securities data, as well as ongoing attribution and performance reporting. The portfolio transparency spans the entire client asset base, from public securities held in brokerage accounts, to private investments, and cash held in bank accounts. Ahara Advisors utilizes a third-party software platform (Addepar) which aggregates daily feeds of public positions from client brokerage accounts. "Offline" assets (i.e., those assets which do not have a direct feed into the software platform) will be manually updated on a quarterly basis in consultation with the client. In this way, we will have an up-to-date picture of a client’s portfolio, on a daily basis, for liquid securities, and on a quarterly basis for offline assets. Clients will be able to access this information via a web portal. Investment Due Diligence As part of the investment services offered, we will conduct due diligence on behalf of the client and present written reports on the following areas: Individual securities – stocks, bonds, etc. • • Private investments in alternatives, including, but not limited to: o Hedge Funds: Equity Long/Short, Global Macro, Event Driven, Credit, Distressed, MultiPM; o Private Equity Funds: Buyout, Growth & Venture; o Real Estate Opportunities: Funds and investments in other private opportunities. When a client is made aware of investments opportunities, including alternative investments, through their own network of connections, our Chief Investment Officer, Aseem Garg (“CIO”), will utilize his industry experience to assist the client in conducting their own due diligence on those opportunities. Ahara Advisors will only present alternative investment opportunities to other clients if there exists Ahara Advisors ADV Part 2A & 2B July 2024 Page 6 of 29  capacity for those clients, and, it is suitable to those clients, based on their objectives, risk tolerance, and needs. When Ahara Advisors provides a client an alternative opportunity, it will always do so in a way that describes the suitability for the client's financial situation and goals. Additionally, when a recommended alternative investment is purchased by a client, Ahara Advisors will conduct ongoing due diligence of the product, at least annually, and notify the client if any issues or concerns are raised. At other times, the CIO may be considering an alternative investment on behalf of his own family. When appropriate, Ahara Advisors will inform its clients, for whom the investment is appropriate, of the CIO's interest and make a recommendation for the client to invest. This is in keeping with Ahara Advisors' commitment to transparency and alignment with its clients’ objectives and needs. CIO Portfolio Transparency Ahara Advisors, in an effort to create maximum alignment between the client and the firm, provides transparency to the Chief Investment Officer (CIO) Portfolio. The CIO Portfolio consists primarily of the public equity positions the Chief Investment Officer holds for his/her family. Before the Chief Investment Officer makes a change/trade to his/her portfolio, clients will be notified in advance. Tailoring of Advisory Services Our firm offers individualized investment advice to our Trade Execution, Portfolio Management, and Financial Consulting clients. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities, or types of securities, may not be possible due to the level of difficulty this would entail in managing the account. Third Party Money Managers When appropriate, Ahara Advisors will help clients evaluate third party money managers to the extent it’s appropriate for their situation. Wrap Fee Ahara Advisors does not sponsor or participate in a third-party sponsored wrap fee program. Assets Under Management As of December 31st, 2024, our firm manages $122,361,770 on a discretionary basis. Item 5 – Fees and Compensation Ahara Advisors generally provides access to its services to institutions and families at a rate of $1000 per hour. All fees disclosed below are negotiable at Ahara Advisors’ discretion. All fees will be invoiced directly to the client. Ahara Advisors ADV Part 2A & 2B July 2024 Page 7 of 29  Private Clients Trade Execution Service We do not charge fees for our Trade Execution service. Portfolio Management The maximum annual fee charged for this service will not exceed 1% per annum. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Ahara Advisors bills on cash unless indicated otherwise in writing. Annualized fees are billed on a pro-rata basis, quarterly in arrears, based on the market value of the account(s) on the last day of the quarter. Fees will be deducted from the client’s account(s). In certain instances, the Firm may use margin to purchase securities for a client’s portfolio. Such use will typically increase the market value of the assets in a client’s account, and thus increase the fee billed on the account. If the client portfolio is invested in illiquid or alternative investment(s). the Firm will use the total commitment value, or cost basis, whichever is applicable to determine the fee to be billed for the first 12 months the asset is held in the clients portfolio. After such time, the Firm will no longer assess a fee on such assets. In rare cases, our firm may agree to directly invoice for this service. As part of this process, clients understand the following: • The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; • Clients will provide authorization permitting our firm to be directly paid by these terms. Our • firm will send an invoice directly to the custodian; and If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. State of the Family Report We charge a fixed fee for the Report. The fee will be based upon the expected amount of hours of work required to provide the service. The total fee, which will not exceed 1% per annum on Net Assets1 to be paid is negotiable and based on the estimated time to meet with the client, collect the necessary data, and complete and present the recommendations outlined in the report. For example, Client X owns $2MM of stocks, $1MM of cash, and owns a $4MM home, which is financed by a $1MM mortgage, then X has $6MM of net assets ($2MM+$1MM+$4MM-$1MM). The State of the Family report for X is estimated to take 3 months to complete. Therefore, the fee for the report would be no more than $15,000 ($6MM*1%*(3/12 of a year)). An initial deposit of $495, which covers the initial 1 Net Assets include the client’s disclosed net worth and should include the client's estimate of their holdings in liquid securities (e.g., cash, stocks, bonds, and funds), private investments, and real estate reduced by liabilities (e.g., mortgages or other forms of debt) Ahara Advisors ADV Part 2A & 2B July 2024 Page 8 of 29  meeting and data collection, is due and payable to Ahara Advisors on the effective date of a contractual agreement and the remainder of the fee will be due upon delivery, and presentation, of the Report. Please note that we will not collect $500 or more, six (6) or more months, in advance. The fee will be based on the hourly rate disclosed above. Payments will be accepted in the form of wire transfer or credit card. The Financial Consulting Agreement will disclose the fee for services. If for any reason the client terminates this agreement prior to the completion and presentation of the Report, the client will be responsible for all fees over and above the initial deposit, if applicable, for all time spent in reviewing data and documentation, and work on the report. The fee is due and payable at the time the agreement is terminated. Financial Consulting and Support The ongoing consulting and support fee is based upon an estimate of the hours involved and the potential benefit to the client. The ongoing consulting and support fee, which will not exceed 1% per annum on Net Assets and will not increase except annually at the rate of inflation, to be paid is negotiable and based on the estimated time to; review client financial data, meet with the client, collect any necessary data, execute trades on the client's behalf, respond to client requests for financial guidance, and to develop client-specific investment or positioning recommendations to be presented during the or between scheduled meetings. For example, Client X, as shown under the State of the Family Report section, would incur a support fee of no more than $60,000 per year ($6MM*1%). Irrespective of any growth in assets, the fee will remain $60,000 with inflationary adjustments in future years (e.g., if inflation increases 5% in the following year the fee would increase by $3000, e.g., $60,000*105% = $63,000). Ahara Advisors will only charge clients the negotiated rate on the estimated time to perform the services described above. Payments will be accepted in the form of wire transfer or credit card. The maximum fee charged for this service which includes the fee from sub-advisor/third-party money manager (if utilized) will not exceed 2%. Annualized fees are billed on a pro-rata basis quarterly in arrears. The Financial Consulting Agreement will show the fee. Institutional Clients Project Based Fixed Fee Consulting For project-based consulting, the client agrees to pay Ahara Advisors a fee that incorporates the number of hours expected for Ahara Advisors to commit at a rate of $1,000 per hour and will reimburse Ahara Advisors for out of pocket expenses (travel, specialized software, etc) incurred. Ahara Advisors will provide the client with a written notice for estimated out of pocket expenses before incurring those expenses. Payments will be accepted in the form of wire transfer or credit card. Fees will be calculated, billed, and charged when the services are rendered and completed. Ad-hoc hourly consulting For ad-hoc consulting services the client agrees to pay Ahara Advisors $1,000 per hour and will reimburse Ahara Advisors for out of pocket expenses (travel, specialized software, etc) incurred. Ahara Advisors will provide the client with a written notice for estimated out of pocket expenses before Ahara Advisors ADV Part 2A & 2B July 2024 Page 9 of 29  incurring those expenses. Payments will be accepted in the form of wire transfer or credit card. Fees will be calculated, billed, and charged when the services are rendered and completed. Recommendations All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Other Fees Clients will incur transaction fees for trades executed by their chosen custodian, either based on a percentage of the dollar amount of assets in the account(s) or via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Fidelity Brokerage Services (“Fidelity”) has eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not share or receive any portion of these “Other Fees”. Termination Either party may terminate the advisory agreement signed with our firm for Trade Execution, Portfolio Management, and Financial Consulting services in writing at any time. Upon notice of termination prorata advisory fees for services rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory fees to the client. For purposes of calculating refunds for our Financial Consulting services, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Commissionable Securities Sales Our firm and representatives do not sell securities nor other investment products, including asset-based sales charges or service fees from the sale of mutual funds for a commission in advisory accounts. Ahara Advisors ADV Part 2A & 2B July 2024 Page 10 of 29  Item 6 – Performance Based Fee and Side by Side Management We do not charge any performance-based fees, which are fees based on a share of capital gains on, or capital appreciation of, the assets of a client. Item 7 – Types of Client(s) We provide financial consulting services to individuals, high net worth individuals, and businesses and have no minimum net worth requirement for an individual to become a client. However, clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis We use Fundamental, Economic Analysis and Stress Testing as part of our overall investment management discipline when evaluating a client’s financial condition and providing our recommendations. Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis uses real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of determining what strategy to take with that security (underpriced = buy, overpriced = sell, reduce or hold). Stress Tested Economic Analysis Stress testing is a risk management tool and analysis used to simulate an economic crisis and determine if this event could impact a client’s assets. By implementing a stress test, we can identify potential worst- case scenarios in order to manage a client’s exposure to risk. Based on the results of stress testing, we can take strategic actions such as adjusting economic capital levels or adjusting portfolio mix, which might result in enhanced economic returns. Third-party Money Managers Ahara Advisors may recommend allocations to third party money managers if appropriate and suitable for the client. This will be the case when the client is seeking exposure to a strategy or asset class that is not Ahara Advisors ADV Part 2A & 2B July 2024 Page 11 of 29  readily available in the public markets. Examples of these types of third-party money managers would include: • Hedge Fund managers investing long and short in securities, including derivatives and credit instruments; • Private Equity managers investing in private securities; • Long only managers, investing in securities/sectors where the client seeks to increase exposures (such as healthcare, technology, or disruptive innovation). Investment Strategies Asset Allocation The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals, and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are: • stocks (value, dividend, growth, sector-specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets) • bonds (fixed income securities more generally: investment-grade junk [high-yield]; government, corporate; short-term, intermediate-term, long-term; domestic, foreign, emerging markets) cash or cash equivalents. • Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be considered include: • Commodities: precious metals, nonferrous metals, agriculture, energy, among others; • Commercial or residential real estate (also REITs); • Collectibles such as art, coins, or stamps; • Insurance products (annuity, life settlements, catastrophe bonds, personal insurance products, etc.); Ahara Advisors ADV Part 2A & 2B July 2024 Page 12 of 29  • Derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures; foreign currency; venture capital; private equity; and/or distressed securities. There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are strategic, dynamic, tactical, and core-satellite. • Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions. • • Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their allocation postures over time relative to changes in the economic environment. Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes. • Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. (“ETFs”) Exchange Traded Funds An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) whose primary objective is to achieve the same return as a particular market index. The vast majority of ETFs are designed to track an index, so their performance is close to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference between the returns of a fund and the returns of the index, can arise due to differences in composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-until-canceled orders, stop loss orders, etc. They can also be sold short. Traditional mutual funds are bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought and sold at the market prices on the exchanges, which resemble the underlying NAV but are independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in Ahara Advisors ADV Part 2A & 2B July 2024 Page 13 of 29  board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which generally can only be bought in the country in which they are registered. One of the main features of ETFs are their low annual fees, especially when compared to traditional mutual funds. The passive nature of index investing, reduced marketing, and distribution as well as accounting expenses all contribute to the lower fees. However, individual investors must pay a brokerage commission to purchase and sell ETF shares; for those investors who trade frequently, this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient. Private Funds A private fund is an investment vehicle that pools capital from a number of investors and invests in securities and other instruments. In almost all cases, a private fund is a private investment vehicle that is typically not registered under federal or state securities laws. So that private funds do not have to register under these laws, issuers make the funds available only to certain sophisticated or accredited investors and cannot be offered or sold to the general public. Private funds are generally smaller than mutual funds because they are often limited to a small number of investors and have a more limited number of eligible investors. Many but not all private funds use leverage as part of their investment strategies. Private funds management fees typically include a base management fee along with a performance component. In many cases, the fund’s managers may become “partners” with their clients by making personal investments of their own assets in the fund. Most private funds offer their securities by providing an offering memorandum or private placement memorandum, known as “PPM” for short. The PPM covers important information for investors and investors should review this document carefully and should consider conducting additional due diligence before investing in the private fund. The primary risks of private funds include the following: (a) Private funds do not sell publicly and are therefore illiquid. An investor may not be able to exit a private fund or sell its interests in the fund before the fund closes.; and (b) Private funds are subject to various other risks, including risks associated with the types of securities that the private fund invests in or the type of business issuing the private placement. Fixed Income Fixed income is a type of investing or budgeting style for which real return rates or periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income investors are typically retired individuals who rely on their investments to provide a regular, stable income stream. This demographic tends to invest heavily in fixed-income investments because of the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding their spending power. Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds, asset-backed securities, municipal bonds, and international bonds. The primary risk associated with fixed-income investments is the borrower defaulting on his payment. Other considerations include exchange rate risk for international bonds and interest rate risk for longer-dated securities. The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local Ahara Advisors ADV Part 2A & 2B July 2024 Page 14 of 29  municipalities, and major corporations. Fixed-income securities are recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products, such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio in order to reduce the overall risk. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Long-Term Purchases Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm decides to sell. Risk of Loss We cannot guarantee our analysis methods will yield a positive return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to bear. Investment decisions made for your account by us are subject to various market, currency, economic, political, and business risks. The investment recommendations we make for you will not always be profitable nor can we guarantee any level of performance. A list of risks associated with the strategies, products, and methodology we offer are listed below: Alternative Investment Risk Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices • Lack of liquidity in that there may be no secondary market for the fund and none may be expected to develop • Volatility of returns • Absence of information regarding valuations and pricing • Delays in tax reporting Less regulation and higher fees than mutual funds • Ahara Advisors ADV Part 2A & 2B July 2024 Page 15 of 29  Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields. Risks associated with bond funds include: • Call Risk — The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date. • Credit Risk — the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. • Interest Rate Risk — the risk that the market value of the bonds will go down when interest rates rise. As a result, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. • Prepayment Risk — the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks: • There are a numerous number of factors that can affect the earnings of a company, and its stock price, over time. These can include economic, political, and social factors, in addition to the various company statistics. The data used may be out of date. • It is difficult to give appropriate weightings to the factors. • It assumes that the analyst is competent. • • It ignores the influence of random events such as oil spills, product defects being exposed, acts of God and so on. Exchange Traded Fund (“ETF”) Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds: • The market price of the ETF’s shares may trade at a premium or a discount to their net asset value; Ahara Advisors ADV Part 2A & 2B July 2024 Page 16 of 29  • An active trading market for an ETF’s shares may not develop or be maintained; and • There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged Liquidity and Early Withdrawal Risk There may be a surrender charge for withdrawals within a specified period, which can be as long as six to eight years. • Retirement Plan Distributions: Any withdrawals from an IRA or retirement plan before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real i.e., inflation-adjusted, returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk -The possibility that an investment will decline in value, or "lose money," from the original or invested amount. Ahara Advisors ADV Part 2A & 2B July 2024 Page 17 of 29  Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services. Overall Risks Clients need to remember that past performance is no guarantee of future results. All investments carry some level of risk. You may lose some or all the money you invest, including your principal, because the securities’ value either increases or decreases. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. Item 9 – Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning Ahara Advisors or any of our IARs. We adhere to high ethical standards for all IARs and associates. Item 10 – Other Financial Industry Activities and Af�iliations Neither Ahara Advisors nor any of its management persons are registered as a broker-dealer or registered as a representative of a broker-dealer, nor does it have any pending application to register. In addition, neither Ahara Advisors nor its management persons are affiliated with any broker-dealer. Ahara Advisors and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor. Mr. Garg has no outside business activities to report. Please see Item 4 for more information regarding our firm’s selection of third-party managers. Prior to recommending third-party managers, our firm will ensure that the third-party manager is properly Ahara Advisors ADV Part 2A & 2B July 2024 Page 18 of 29  licensed or registered with the respective authorities. A potential conflict of interest for our firm in utilizing a third-party manager is receipt of services not available to us from other similar advisers. To minimize this conflict, our firm will make recommendations and selections in the best interest of our Clients. Please note that as of April 2025, Ahara Advisors is the advisor to NASH FEB 2025 A SERIES OF CGF2021 LLC, SPV under the Sydecar LLC/CGF2021 LLC umbrella, please note that Ahara does not have authorization on the account(s) of the SPV and therefore Ahara doesn't have custodial access or responsibilities. Clients of our firm may be solicited to invest in the Fund. Clients, however, are under no obligation to do so. Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading General Information We have adopted a Code of Ethics for all IAR’s of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our IAR’s must acknowledge the terms of the Code of Ethics annually, and/or as amended. Participation or Interest in Client Accounts Our compliance policies and procedures prohibit anyone associated with Ahara Advisors from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO (Chief Compliance Officer). The following acts are prohibited: Employing any device, scheme, or artifice to defraud • • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading Engaging in any fraudulent or deceitful act, practice, or course of business • Engaging in any manipulative practices • Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO. Personal Trading We may recommend securities to you that we will purchase or sell for our own accounts. We may trade securities in our account that we have recommended to you as long as we place our orders either in Ahara Advisors ADV Part 2A & 2B July 2024 Page 19 of 29  conjunction or subsequent to your orders. This policy is meant to prevent us from benefiting as a result of transactions placed on behalf of advisory accounts. Neither Ahara Advisors nor any of its related persons recommend securities (or other investment products) to advisory clients in which we or any related person has some other proprietary (ownership) interest, other than those mentioned above. Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Ahara Advisors has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of “Access Persons.” The policy requires that an Access Person of the firm provide the CCO or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the CCO or his/her designee with a written report of the Access Person’s current securities holdings at least quarterly thereafter on a date Ahara Advisors selects; provided, however that at any time that Ahara Advisors has only one Access Person, he or she shall not be required to submit any securities report described above. We have established the following restrictions in order to ensure our fiduciary responsibilities, regarding insider trading, are met: • No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of IARs of Ahara Advisors, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours. Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request. Con�licts of Interest Ahara Advisors’ IARs may employ the same strategy for their personal investment accounts as they do for Ahara Advisors’ clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of Ahara Advisors ADV Part 2A & 2B July 2024 Page 20 of 29  investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Item 12 – Brokerage Practices Selecting a Brokerage Firm • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation •Timeliness and accuracy of trade confirmations While our firm does not maintain physical custody of client assets, we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts (see Item 15 Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, include: • Timeliness of execution • Quality of services • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity"), and Charles Schwab & Co. (“Schwab”) collectively, “the Custodians” through which the Custodians provide our firm with "institutional platform services." Our firm is independently operated and owned and is not affiliated with the Custodians. The institutional platform services include, among others, brokerage, custody, and other related services. The Custodians’ institutional platform services that assist us in managing and administering clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. The Custodians may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by the Custodians may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and Ahara Advisors ADV Part 2A & 2B July 2024 Page 21 of 29  services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by the Custodians to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. The aforementioned research and brokerage services are used by our firm to manage accounts for which our firm has investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to our clients, our firm will always endeavor to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of the Custodians as custodial recommendations. Our firm examined this potential conflict of interest when our firm chose to recommend the Custodians and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Our clients may pay a transaction fee or commission to the Custodians that is higher than another qualified broker dealer might charge to effect the same transaction where our firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Our firm does not receive soft dollars more than what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all our clients but not necessarily all at any one particular time. Client Brokerage Commissions The Custodians do not make client brokerage commissions generated by client transactions available for our firm’s use. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Ahara Advisors ADV Part 2A & 2B July 2024 Page 22 of 29  Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. However, our firm routinely recommends that clients direct us to execute through Fidelity. Client-Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration, and consistently nonarbitrary methods of allocation. Item 13 – Review of Accounts Reviews For ongoing consulting clients, we review their financial situation on a regular basis. Formal reviews are conducted at least quarterly. Reviews will be conducted by our CIO, Aseem Garg. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. For our Trade Execution and Portfolio Management clients, our CIO, Aseem Garg, reviews accounts on at least an annual basis. The nature of these reviews is to help verify whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when our Trade Execution, Portfolio Management, and Third-Party Money Management clients are contacted. Ahara Advisors ADV Part 2A & 2B July 2024 Page 23 of 29  Reports As part of the ongoing consulting process written reports will be provided quarterly. Item 14 – Client Referrals and Other Compensation Fidelity Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional arrangements regarding the relationship with Fidelity to disclose. Schwab Our firm may receive economic benefit from Schwab in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Client Referrals In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Item 15 – Custody Deduction of Advisory Fees While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Third Party Money Movement.” All of our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Ahara Advisors ADV Part 2A & 2B July 2024 Page 24 of 29  Third Party Money Movement On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian: • • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • • • • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s qualified custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16 – Investment Discretion Our firm manages accounts on a discretionary basis. After you sign a Trade Execution, or Portfolio Management agreement with our firm, we’re allowed to buy and sell investments in your account without asking you in advance. Any limitations will be described in the signed advisory agreement. We will have discretion until the Trade Execution or Portfolio Management agreement is terminated by you or our firm. Item 17 – Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies. The Ahara Advisors ADV Part 2A & 2B July 2024 Page 25 of 29  custodian will forward you copies of all proxies and shareholder communications relating to your account assets. Item 18 – Financial Information Disclosure of Financial Condition Our firm is not required to provide financial information in this Brochure because: • Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm has never been the subject of a bankruptcy proceeding. Ahara Advisors ADV Part 2A & 2B July 2024 Page 26 of 29  ADV Part 2B Brochure Supplement – Aseem Garg Item 1 – Cover Page Aseem Garg CRD # 7333129 February 2025 Ahara Advisors LLC 201 Montgomery St, Ste 263 Jersey City, NJ 07302 201-298-3144 This Brochure supplement provides information about Aseem Garg and supplements the Ahara Advisors (“Ahara Advisors”) Brochure. You should have received a copy of that Brochure. Please contact Mr. Garg if you did not receive the Brochure or if you have any questions about the contents of this supplement. Additional information about Aseem Garg CRD# 7333129 is available on the SEC’s website at www.adviserinfo.sec.gov. Ahara Advisors ADV Part 2A & 2B July 2024 Page 27 of 29  Item 2 – Educational Background and Business Experience Full Legal Name: Aseem Garg Year of Birth: 1981 Education 2003 2003 BS in Computer Science BS in Policy & Management Carnegie Melon University, Pittsburgh, PA Business History • Ahara Advisors LLC.; Investment Advisor Representative; 01/2021 – Present Tetragon Financial Group; Head of Risk; 10/2015 – 7/2021 • • Willet Advisors; Associate Director; 11/2012 – 08/2015 2007 Designations Chartered Financial Analyst (CFA®) Charterholder CFA Institute Minimum Designation Requirements Chartered Financial Analyst (CFA®) The Chartered Financial Analyst (CFA®) certification is a globally recognized, graduate-level investment credential, recognized for its foundation in investment analysis and portfolio management skills, and emphasizes the highest ethical and professional standards. To attain the right to use the CFA® marks, an individual must satisfactorily fulfill the following requirements: Prerequisites/Experience: Complete either an undergraduate degree and four years of professional experience involving investment decision-making, or four years of qualified work experience (full time, but not necessarily investment related). Educational Requirements: Complete a self-study program (250 hours of study for each of the three levels). Examination Type: Pass the comprehensive CFA® Certification Examination. The examination consists of three comprehensive exams which are six hours in length each. Ethics: Agree to be bound by CFA Institute's Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFA® professionals. CFA® professionals who fail to comply with the above standards and requirements may be subject to CFA Institute’s enforcement process, which could result in suspension or permanent revocation of their CFA® certification. Item 3 – Disciplinary History Ahara Advisors ADV Part 2A & 2B July 2024 Page 28 of 29  Neither Ahara Advisors nor Aseem Garg has any disciplinary history to disclose. Item 4 – Other Business Activities Aseem Garg has no outside business activities to report. Item 5 – Additional Compensation Aseem Garg does not receive any compensation for providing advisory services to a non-client. Item 6 – Supervision Aseem Garg is the owner & CIO and performs all investment advisory duties for his firm. Ahara Advisors ADV Part 2A & 2B July 2024 Page 29 of 29