ASCENT CAPITAL PARTNERS, LLC

Form ADV Part 2A: Disclosure Brochure Ascent Capital Partners, LLC 16427 North Scottsdale Road Suite 410 Scottsdale, AZ 85254 Effective: March 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Ascent Capital Partners, LLC (“Ascent” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (480) 841- 6956. Ascent is a SEC registered investment advisor located in the State of Arizona and Texas. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Ascent to assist you in determining whether to retain the Advisor. Additional information about Ascent and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching for our Firm name or by our CRD# 291218.  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about advisory personnel of Ascent. Ascent believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. Ascent encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Material Changes • Item 4 – Advisory Business – This section was revised to reflect assets under management as of December 31, 2025. 2 | P a g e  Item 3 – Table of Contents Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Services ............................................................................................................................ 4 Item 5 – Fees and Compensation .................................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 15 Item 7 – Types of Clients ............................................................................................................................. 16 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 16 Item 9 – Disciplinary Information .............................................................................................................. 21 Item 10 – Other Financial Industry Activities and Affiliations ................................................................. 21 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 23 Item 12 – Brokerage Practices .................................................................................................................... 24 Item 13 – Review of Accounts ..................................................................................................................... 25 Item 14 – Client Referrals and Other Compensation ................................................................................. 26 Item 15 – Custody........................................................................................................................................ 26 Item 16 – Investment Discretion ................................................................................................................. 27 Item 17 – Voting Client Securities .............................................................................................................. 28 Item 18 – Financial Information ................................................................................................................. 28 Privacy Policy .............................................................................................................................................. 29 3 | P a g e  Item 4 – Advisory Services A. Firm Information Ascent Capital Partners, LLC (“Ascent” the “Firm” or the “Advisor”) is a SEC registered investment advisor located in the States of Arizona and Texas, organized as a limited liability company under the laws of the State of Arizona. Ascent was founded in October 2017 and is owned by Ascent Consolidated, Inc. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Ascent. B. Advisory Services Offered Ascent offers investment advisory services to separately managed accounts (“SMAs”), which are typically individuals and entities and high net worth individuals and entities, and private fund Clients, Ascent Ventures LP, Ascent X Innventure TC, a Series of Ascent X Innventure, Spirit of the Game, a Series of Ascent Productions LP, and Ascent Mountain Partners - Phase 1, a series of Ascent Realty Partners I, LLC, Ascent X Envest, LP, and Ascent Ascenta LP (“Ascent Ventures”, “Ascent X Innventure”, “Spirit of the Game”, “Ascent Mountain”, “Ascent X Envest”, “Ascent Ascenta” or collectively the “Funds”), each Delaware limited partnerships. Ascent also offers additional services, such as Comprehensive Financial Planning Services, and Family Office Services. As of December 31, 2025, Ascent managed approximately $169,979,905 in Client assets on a discretionary basis and approximately $2,022,469 in Client assets on a nondiscretionary basis. Separately Managed Account Services Ascent provides customized investment advisory solutions for its Clients. This is achieved through continuous personal contact and interaction while providing discretionary investment management and related advisory services. Ascent works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Ascent will then construct the Client’s portfolio. (both public and private), income A Client’s portfolio may consist of a variety of investments including, but not limited to: equity securities, options contracts, fixed securities cryptocurrency/digital assets, crypto currency UITs, crypto currency ETFs/mutual funds, ETFs, leveraged ETFs/mutual funds, exchange-traded notes (ETNs), closed-end funds, real estate investment trusts (REITs), mutual funds, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, U.S. Government securities, non-publicly traded REITs, fee-based structured variable annuities, life insurance, annuities, options contracts on securities, special purpose vehicles, and alternative investments. 4 | P a g e  The Advisor may retain certain types of investments in a Client’s account based on such Client’s legacy portfolio construction. Ascent may recommend Clients invest a portion of their account in Ascent managed Fund(s). If such an investment is made from a Client account, the amount invested in the Fund will reduce the Client’s assets under management and corresponding IA Fee. The Fund(s) is subject to a separate Management Fee and Performance Fee structure, as discussed further in Item 5, below. A Client bears all its own costs and expenses directly related to investments in alternative investments, including accounting services, compliance costs, tax preparation, audit, and other fees and costs. Expenses are described in more detail in the alternative investments offering documents and related documents. Clients should carefully review these documents before investing. Investing in alternative investments involves a high degree of risk, including liquidity risk, business risk, dilution risk, and other risks. Such investments may involve significant fees and expenses and be subject to partnership tax reporting. The receipt of these fees, including performance-based fees, could represent an incentive for Ascent to recommend alternative investments over investments with lower fees, therefore creating a conflict of interest. These potential conflicts of interest are discussed in further detail in Item 6 below. Alternative investments are typically for long-term investors willing and able to bear the increased risk and tax reporting burden commonly associated with these types of investments. Clients should carefully review the private placement memorandum provided by the issuer to further understand the risks of investing prior to making any investment. Ascent’s SMA strategy is primarily long-term focused, but the Advisor may buy, sell, or re- allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Ascent will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Ascent evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Ascent may recommend, on occasion, redistributing investment allocations to diversify or rebalance the portfolios of its Clients. Ascent may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Ascent may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of a Client, generating cash to meet a Client’s needs, or any risk deemed unacceptable due to the Client’s risk tolerance. 5 | P a g e  Ascent will not act as the custodian of any SMA Client’s funds or securities. All Client assets will be managed within their designated account, pursuant to the Client Investment Management Agreement (“IMA”). Please see “Item 12 – Brokerage Practices”. For certain Clients who qualify, Ascent may recommend alternative investments. These investments include private placements, private equity funds, closed-end interval funds, private business development companies (BDCs), Private Real Estate Investment Trusts (REITs), Qualified Opportunity Zone investments, direct private equity investments via secondary market purchases, real assets through private partnerships or private placements, debt instruments or investments, debt funds, debt instruments, hedge funds, or similar investment structures (collectively “alternative investments”). None of these alternative investments are registered with the SEC or state regulatory bodies, nor are any of these investments publicly traded. These investments are only available to Accredited Investors, as defined under the relevant SEC rules and regulations. This means the investor must meet certain income or net worth thresholds, or otherwise be determined to be an institutional or professional investor or to hold certain professional certifications. These investments may be managed by independent (unaffiliated managers) or by Ascent as described below. Third-Party Advisors Ascent may select, with a Clients’ consent, other third-party investment managers that Ascent will monitor on the Clients’ behalf. If a third-party manager is engaged, Clients will likely incur additional fees associated with such third-party manager’s services. Use of Amplify Platform Ascent’s investment adviser representatives may utilize the various services, such as access to model portfolios, available through the Amplify Platform. Use of the Amplify Platform will result in fees payable by the Client in addition to Ascent’s management fee. Pontera Accounts (formerly FeeX) We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset allocation and opportunistic rebalancing strategies. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools, as necessary. Pontera accounts will incur fees in addition to Ascent’s management fees, and such additional fees will be assessed and billed quarterly. Specifically, the exact amount charged is determined by the 6 | P a g e  account value at the end of the quarter. If the Adviser only manages your assets for part of a quarter, the charge will be prorated. Private Fund Services The Funds are offered in accordance with Rule 506 of SEC Regulation D (which governs private placements) and various state securities laws governing private placements. The Funds are pooled investment vehicles. Investments in the Funds are only available to individuals or entities that are both Qualified Clients and Accredited Investors. Ascent Capital Partners is the investment advisor. Ascent is paid management fees and performance-based fees as further detailed in Item 6 below. Ascent Ventures was formed in 2021 as a vehicle to invest in early- and late-stage venture capital technology companies, with a focus on software, data and device technologies disrupting and modernizing traditional industries, services, and infrastructure, managed by the Advisor. This Fund is open to new investors. Investment in the Fund involves a high degree of risk. Ascent X Innventure TC, a Series of Ascent X Innventure, LP (“Ascent X Innventure”) was formed in 2022 as a vehicle to invest in Innventure LLC, who will use the proceeds to fund operating expenses of Innventure LLC, and other pre-seed and seed expenses related to the creation of new portfolio companies. Spirit of the Game, a Series of Ascent Productions, LP was formed in 2022 for the sole purpose of pursuing sports, media, and entertainment related investments. Ascent Mountain was formed in 2023 for the sole purpose of acquiring exposure to securities issued by MHMF LLC. Ascent X Envest was formed in 2024 for the purpose of investing in Envest, a Canadian independent energy producer delivering clean energy infrastructure and decarbonization solutions to industrial and government off-takers. Ascent Ascenta was formed in 2024 and invests in early- stage and growth-stage companies, primarily in the technology and healthcare sectors. All relevant information, terms and conditions related to the Fund, including the remuneration and expense reimbursement to be received by Ascent, suitability, risk factors, and potential conflicts of interest, are set forth in the fund’s private placement memorandum, the operating agreement, and other related documents or disclosures. Each investor in the Fund is required to receive, carefully review, and sign these documents prior to an investment being accepted. 7 | P a g e  Other Services Offered Comprehensive Financial Planning Services Ascent will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A comprehensive financial plan could cover retirement planning, 401k and pension decisions, stock options, investment management and consolidation, buying a home, and other major items such as education funding, insurance and risk management, and cash-flow management. A financial plan developed for, or financial consultation rendered to, a Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Ascent may also refer Clients to accountants, attorneys, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor could pose a conflict, as it could increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effectuate the transaction through the Advisor. 8 | P a g e  Family Office Management Services Ascent provides family office management and administrative services (“Family Office Management”) to its Clients (“Family Office Clients”). Depending on the Family Office Client’s needs, Family Office Management may include, but is not limited to, income, gift and estate tax planning, multi-generational planning, philanthropic planning, family business and continuity planning, family member education and family governance services, in addition to education tax and estate planning. Ascent will also provide its investment management services as described above as part of the Family Office Management services along with a complementary analysis of other assets to provide a holistic solution for an investment portfolio. Family Office Clients may instruct Ascent to provide investment management or Family Office Management only. Ascent may recommend the services of itself, or other professionals to devise or implement its recommendations. Family Office Clients are advised that a conflict of interest may exist if Ascent recommends its own services. The Family Office Client is under no obligation to act upon any of the recommendations made by Ascent under a Family Office Management engagement or to engage the services of any such recommended professional, including Ascent itself. Family Office Clients retain absolute discretion over all such implementation decisions and is free to accept or reject any of Ascent’s recommendations. Family Office Clients are advised it remains their responsibility to promptly notify Ascent if there is ever any change in their financial situation, as well as facts and circumstances that may impact their investment objectives to provide for proper comprehensive and timely reviewing, evaluating, or revising Ascent’s previous recommendations or services. Estate Planning Services We offer estate planning services to our Clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans. C. Wrap Fee Programs Ascent does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Ascent. Item 5 – Fees and Compensation The following paragraphs detail the standard fee structure and compensation methodology for services provided by the Advisor and is not inclusive of any potential additional fees as outlined 9 | P a g e  in certain services in Item 4 above. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services SMA Investment Management Services Ascent’s fee for SMA advisory and portfolio management services (“IA Fee”) is based on a percentage of the Client’s assets under management, as indicated in the fee schedules below. Except as discussed below in Item 6, Ascent does not charge Client’s performance-based fees or other fees based on share of capital gains or capital appreciation. IA Fees are paid quarterly in advance pursuant to the terms of the IMA. IA Fees are based on the market value of assets under management at the end of the prior calendar quarter. IA Fees are based on the following standard fee schedule: Assets Under Management ($) Annual Rate (%) $0 to $500,000 1.50% $500,001 to $1,000,000 1.25% $1,000,001 to $3,000,000 1.15% $3,000,001 to $5,000,000 1.00% $5,000,001 to $10,000,000 0.80% $10,000,001 to $20,000,000 0.60% $20,000,001 to $50,000,000 0.50% $50,000,001 and Up Negotiable The IA Fee in the first quarter of service is prorated from the inception date of the account(s) to the end of the first quarter. Fees may be negotiable at the discretion of the Advisor. The Client’s IA Fees will take into consideration the aggregate assets under management with Advisor as of the last day of a calendar quarter. All securities held in accounts managed by Ascent will be independently valued by the designated Custodian. Ascent will not have the authority or responsibility to value portfolio securities. 10 | P a g e  For fee-based structured variable annuities and life insurance, Ascent charges a maximum investment management fee of 1.25%. This fee is negotiable based on the amount of assets under management with Ascent. The Client may direct the fee to be withdrawn from the fee-based variable annuity or a different account managed by Ascent. Certain fee-based variable annuities carriers only allow fee billing in arrears. Therefore, the fee collection schedule will differ from carrier to carrier. Ascent will disclose the fee collection schedule to each Client when the Client agreement is signed. Third Party-Fees Ascent’s IA Fee is exclusive of, and in addition to, any Third-Party advisor’s fees, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. The fees charged by the Third-Party Advisor, including fees for use of the Amplify Platform and Pontera Accounts, as discussed in more detail below, will be in the third-party advisor’s Client agreement. Amplify Platform Prior to the use of the Amplify Platform, Ascent Client will execute documents acknowledging both Ascent’s intent to use of the Amplify Platform and disclosure relating to any and all additional fees such Client may bear in addition to the fees associated with Ascent’s the advisory services provided to the Client, as described in the IA Fee schedule above. Pontera Accounts (Formerly FeeX) Pontera Account Clients are charged a flat fee of 0.75% of assets under management, paid quarterly in advance, and includes any and all fees charged directly by Pontera. Such fees will be assessed and billed quarterly, and the exact amount charged is determined by the Pontera account’s AUM as of the last day of the quarter. In either case, if the Adviser only manages your assets for part of a quarter, the charge will be prorated. IA Fees are generally directly debited from a Client’s Pontera account, except for 401(k)’s as it is impossible to directly debit the fees from these accounts. As such, a Client may choose to have such fees withdrawn from other Ascent Managed SMA taxable account or have the fees billed directly to the Client. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time the account was open during the billing period. An IMA granting the advisor discretion over a Client’s Pontera account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in advance, a Client may be entitled to receive a rebate upon termination of the account. 11 | P a g e  Alternative Investments The Advisor may recommend a Client to invest in alternative investments. Alternative investments have their own unique fee structure, which may be in addition to Ascent’s IA Fees, and fees may be different for each such investment, or for different share classes of the same investment. In addition, such investments generally bear many additional fees, including, but not limited to, accounting services, compliance costs, startup costs, tax preparation, audit, and other fees and costs. Clients are therefore required to carefully review the private placement memorandum for each recommended private placement investment before making an investment decision. Although Ascent does not generally provide discounts for its fees on alternative investments, it may negotiate a unique fee structure for very large individual investments. Fee variances, if any, that differ from the standard fee schedule will be disclosed and agreed upon in a written agreement signed between Ascent and the Client. Private Fund Management and Performance-Based Fees The Funds pay performance-based fees on the Fund’s underlying investments. These performance-based fees will be calculated and charged as described below and in the Fund’s private placement memorandum and/or operating agreement. Generally, the Advisor will be paid a management fee (the “Management Fee”) equal to 2% per annum on all Fund capital commitments for each of the first five-years of the Fund’s life, resulting in an upfront Management Fee paid to the Advisor of 10%. If the term of the Fund life is extended, a Management Fee equal to 2% per annum of all capital commitments shall be paid to the Advisor at the beginning of each extension period from the Fund’s assets, including from cash reserves. The Management Fee may be lower than 2% in certain instances and for future private funds. Additionally, for the Ascent X Innventure, the management fee is received up front for the ten-year term of the Fund resulting in an upfront Management Fee paid to the Advisor of 20%. Although Ascent does not generally provide Management Fee discounts, it may negotiate a unique fee structure for very large individual Fund investments. Fee variances, if any, that differ from the standard Management Fee will be disclosed and agreed upon in a written agreement signed between Ascent and the Client. In addition to the Management Fee, the Funds participate in a performance fee (“Performance Fee”) structure. After 100% of capital commitments have been returned to its limited partners, 80% of all subsequent distributions will be made to the limited partners and 20% to the General Partner. The Funds bear all of its own costs and expenses directly related to its investment strategy, 12 | P a g e  including accounting services, compliance costs, startup costs (some of which are provided by and paid to Ascent), tax preparation, audit, and other fees and costs. Expenses are described in more detail in the Fund’s private placement memorandum and related documents. Clients should carefully review these documents before investing. Ascent does not represent that its Performance Fees or the manner of calculating them is consistent with performance-based fees charged by other investment advisers under the same or similar circumstances. The performance-based fees charged by Ascent may be higher than those charged by other investment advisers for the same or similar services. Ascent has established policies and procedures to address the various conflicts of interest associated with charging a performance fee: In addition, as required by Adviser’s Act Section 205(e) and Rule 205-3 thereunder, only Clients who are Qualified Clients may enter into agreements providing for performance-based fees. This means that natural person or company must meet at least one of the following conditions: • Have at least $1,100,000 under management with Ascent immediately after entering into the contract; • Provide documentation that reasonably demonstrates that the Client has a net worth of at least $2,200,000; • Be a qualified purchaser under Section 2(a)(51)(A) of the Investment Company Act of 1940; • Be an executive officer, director, trustee, general partner, or person serving in a similar capacity, of Ascent; or • Be an employee of Ascent (other than an employee performing solely clerical, secretarial or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of Ascent, provided that such employee has been performing such functions and duties for or on behalf of Ascent, or substantially similar functions or duties for or on behalf of another company for at least 12 months. Financial Planning Services Ascent offers financial planning services on either an hourly basis or a fixed engagement fee basis. Hourly engagements are billed at $1,200 per hour. Fixed fee engagement fees range from $2,500 to $50,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be 13 | P a g e  provided to the Client prior to engaging for these services. Fixed fees for annual engagements are charged on a quarterly basis in advance. A Financial Planning Services Agreement can be terminated by either party within five (5) business days of signing the agreement at no cost. After the five-day period, charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable. Ascent will refund any unearned, prepaid fees from the effective date of termination to the end of the billing period. Family Office Management Services Ascent charges a fixed annual fee or an hourly fee for Family Office Management. These fees are negotiable, but generally range from $25,000 to $750,000 on an annual fee basis, and up to $1,250 on an hourly rate basis, depending upon the level and scope of the services and the professional rendering the financial planning and/or the consulting services. Family Office Management Services can be terminated by either party within five (5) business days of signing the agreement at no cost. After the five-day period, charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable. Ascent will refund any unearned, prepaid fees from the effective date of termination to the end of the billing period. Estate Planning Services The Firm does not charge a fee for Estate Planning Services. B. Fee Billing Investment Management Services IA Fees are calculated by the Advisor or its delegate and deducted from the Client’s account(s) held at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account(s) at the beginning of the respective quarter. Limited partners and Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Limited partner and Client provide written authorization permitting Ascent to be paid directly from their account(s) held by the Custodian as part of the IMA and separate account forms provided by the Custodian. 14 | P a g e  Mid-quarter deposits in excess of 10% of a Client’s assets under management are subject to a prorated fee for that billing period. Mid-quarter withdrawals in excess of 10% of a Client’s asset under management are subject to a prorated refund of fees based on the amount of time in the billing period. The refund or charge may be assessed and billed at the time of the deposit, withdrawal or during the next billing period. Financial Planning Services Financial planning fees will be invoiced up to fifty percent (100%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable(s). Family Office Management Services The fixed annual fee is agreed to in the Client agreement and it is collected quarterly in advance. The hourly fee is calculated monthly and billed in arrears or at the end of the month. These fees can be paid by check or by deducting it from an account managed by Ascent. C. Other Fees and Expenses Any and all fees charged by Ascent are separate and distinct from these custodial and execution fees. These fees and expenses are generally for services such as account administration, custody, brokerage, and account reporting. Accordingly, the Client should review both the fees charged by the Advisor and the fees charged by third-parties to fully understand the total fees being paid. Please refer to Item 12 for additional information. D. Compensation for Sales of Securities Ascent does not receive any compensation for securities transactions in any Client account, other than the IA Fee noted above. Item 6 – Performance-Based Fees and Side-By-Side Management As discussed in response to Item 5, above, Ascent may render investment management services to qualified Clients for a performance fee. This fee arrangement raises potential conflicts of interest. The performance fee may be an incentive for Ascent to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. In addition, where Ascent charges performance-based fees and also provides services to accounts not being charged performance-based fees, there is an incentive to favor accounts paying a performance-based fee. 15 | P a g e  Ascent has policies and procedures in place to ensure that any recommendations are objectively made based on underlying fundamentals and in the best interest of every Client regardless of whether the Client is paying a performance-based fee or different type of fee arrangement. Item 7 – Types of Clients Ascent offers investment advisory services to Clients as described in more detail in Item 4, above. Minimum account sizes will vary per Fund. Ascent generally imposes a $2.5 million SMA minimum that can be reduced or waived on Advisor’s discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis & Investment Strategies Ascent employs fundamental, technical, and cyclical analysis methods in developing investment strategies for its Clients. Research and analysis from Ascent is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to Clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than 16 | P a g e  the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Ascent will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that Ascent is recommending. The risks with cyclical analysis are similar to those of technical analysis. As noted above, Ascent generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Ascent will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Ascent may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Ascent will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as 17 | P a g e  part of the portfolio construction process. Following are some of the risks associated with the potential speculative components of the Advisor’s strategy: Recommended Securities Several types of securities are used in Client portfolios including, but not limited to, exchange traded funds, mutual funds, stocks, bonds, options contracts, crypto currency ETFs/mutual funds, leveraged ETFs/mutual funds, non-publicly traded REITs, special purpose vehicles, private debt, or private equity funds to meet the needs of its Clients. Some of the risk associated with these securities include: • Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation. • Inflation Risk: This is the risk that inflation will undermine the performance of an investment and/or the future purchasing power of a Client's assets. • Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. • International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social, or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, which differ from those of the U.S. • Liquidity Risk: Liquidity risk exists when particular investments of a fund would be difficult to purchase or sell, possibly preventing the fund from selling such illiquid securities at an advantageous time or price, or possibly requiring the fund to dispose of other investments at unfavorable times or prices in order to satisfy its obligations. • Manager Risk: The chance that the proportions allocated to the various securities will cause the Client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective. • Portfolio Concentration: Accounts that are not diversified among a wide range of types of securities, countries or industry sectors may have more volatility and are considered to have more risk than accounts that are invested in a greater number of securities because changes in the value of a single security may have more of a significant effect, either negative or positive. Accordingly, less diversified portfolios are subject to more rapid 18 | P a g e  changes in value than would be the case if the Client maintained a more diversified portfolio. • Market Risk: The chance that security or cryptocurrency prices overall will decline. The value of the investments held in Clients’ accounts is subject to changes in economic conditions, growth rates, profits, and the market’s perception of these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. The Advisor will discuss these risks with the Client. Leveraged ETFs A leveraged ETF seeks to generate a return that is a multiple (usually 2X or 3X or -2X or -3X) of its benchmark index's performance over a specific, pre-set time period indicated in the fund’s prospectus. That time period is also referred to as the "rebalancing period", and it is generally only one day, although it could be for a longer time period such as a month. As a result, the returns for these types of ETFs can differ significantly from that of their benchmark index, over periods lasting longer than the rebalancing period because of the compounding of returns. Generally, the longer the security is held, the more likely the returns of the leveraged product will differ from the long- term return of the index. Although potential returns are increased by leveraging, so are the potential losses, so these securities carry significant risk. As a result, leveraged and inverse ETFs are intended only for sophisticated investors with an aggressive tolerance for risk. Inverse ETFs An inverse ETF attempts to mimic the inverse, or opposite, of its stated benchmark. For example, an inverse S&P 500 ETF would attempt to deliver the opposite of the S&P 500's daily performance, net of fees. These funds, also called "short ETFs” or “bear ETFs" are often in an attempt to profit from a downturn in a given market, sector, or index, or to hedge against a potential loss in their portfolio. Although an inverse ETF does not explicitly use leverage to magnify the intended return, they can suffer from the same compounding effects as the leveraged long and leveraged short ETFs. Real Estate Investment Trusts (REITs) Ascent may invest a portion of a Client’s asset in REITs. A REIT is a company that owns, operates, or finances income-generating real estate. REITs may or may not be listed on public exchanges. • REIT Market Risk: REITs have no control over market and business conditions and are vulnerable to market risk and slowdowns. External conditions beyond its control may 19 | P a g e  reduce the value of properties that it acquires, the ability of tenants to pay rent on a timely basis, the amount of rent that can be charged and the ability of borrowers to make loan payments on a timely basis or at all. Cash available for distribution to stockholders can be affected by the tenant’s inability to make rents or pay loans. • REIT Tenant Strength Risk: REIT’s revenues are highly dependent on lease payments from its properties and interest payments on the loans it makes. Defaults by tenants or borrowers reduce the cash available for repayment of outstanding debt and distribution to investors. If tenants have multiple properties or borrowers have multiple loans it increases the risk of more than one property or loan going bad if that tenant or borrower defaults. More than one property could become vacant, or loans are in default because of the financial failure of one tenant or borrower. Multiple vacancies or defaults can reduce a REITs cash receipts and funds available for distribution and could decrease the value of the affected properties. • REIT Qualifying Risk: REITs must be organized and operated and intend to continue to be organized and to operate, in a manner that will enable them to qualify as a REIT for federal income tax purposes. No assurance can be given that a REIT qualifies or will continue to qualify as a REIT. If a REIT fails to qualify as a REIT, it will be subject to federal income tax at regular corporate rates. If a REIT fails to qualify the funds available for distribution to investors would be greatly reduced for each of the years involved. Cryptocurrency ETFs/Mutual Funds: Investments in cryptocurrency and digital assets are speculative investments that involve high degrees of risk, including a partial or total loss of invested funds. Cryptocurrency and digital assets are not suitable for any investor that cannot afford loss of the entire investment. Product may be unable to meet its investment objective. Private Funds: These are investment vehicles that pool capital from several investors and invest in securities and other instruments. Private funds may include hedge funds, private real estate funds, private credit funds, venture capital funds and private equity funds. In almost all cases, private funds are structured as a private investment vehicle that is typically not registered under federal or state securities laws. To qualify to avoid registration, issuers make the funds available only to certain sophisticated or accredited investors and do not make the funds available to the general public. The fees for private funds typically include a management fee plus a performance fee. In many cases, the mangers of the private funds can 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. Investors should review this document carefully, including the risk 20 | P a g e  factors, and should consider conducting additional due diligence before investing. The primary risks of private funds include illiquidity and the risks associated with the underlying investments. Item 9 – Disciplinary Information Ascent is required to disclose the facts of any legal or disciplinary event that are material to a Client’s evaluation of its advisory business or the integrity of management. There are no legal, regulatory, or disciplinary events involving Ascent or any of its management persons. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Ascent and Mr. Pomeroy is to provide investment advisory services to its Clients. Mr. Loeffler serves on the advisory board of Platform Technology Group Inc. (the "Platform") an international technology company based out of Barbados specializing in disruptive technology in various verticals. Jonathan Loeffler and other prominent business executives on the board advise Platform on strategy, vision, and direction. Jonathan Loeffler receives stock options/grants for his service on Platform's Advisory Board. A conflict of interest exists to the extent Ascent or Mr. Loeffler recommend a Client invest in the Platform due to its affiliation with Mr. Loeffler and his receipt of stock options/grants for his service on such advisory board. Such stock options / grants are completely unrelated to and non- reliant on potential investments into Platform during formal raises by the company’s private equity backers and is directly correlated to Mr. Loeffler's service on the Advisory Board of Platform The Firm seeks to ensure that any recommendation that a Client to invest in Platform are provided on a fully disclosed basis and made only when aligned with its Client’s best interests. In addition, Mr. Pomeroy and Mr. Loeffler attempt to mitigate any and all potential conflicts of interest to the best of their ability by placing the Client’s interests ahead of their own and through their fiduciary duty. Additionally, it is the Firm’s policy that any recommendation of another investment advisor services does not have to be purchased through the Firm or any Firm affiliate. The Firm may recommend its Fund(s) to Clients. Because Mr. Pomeroy and Mr. Loeffler are Managing Partners of the general partner of the Fund entities, it creates a financial incentive to 21 | P a g e  recommend Clients invest in the Fund. Ascent and its owners and management attempt to mitigate any conflict of interest by disclosing that they are owners of the fund and placing the Clients’ interests ahead of their own. Additionally, Clients are not required to pursue an investment in the Fund after a recommendation is made. Insurance Agency Affiliations Mr. Pomeroy is a licensed insurance agent (life). Mr. Pomeroy may receive commission related to life insurance sales. Insurance products may be offered to Ascent Capital Clients and would be offered through Ascent Life and any fees or commissions paid by a Client would be in addition to fees paid to Ascent Capital Partners. With the ability to work as a client’s insurance agent and investment adviser representative, this could be viewed as a conflict of interest because each service pays a separate fee or commission. However, Mr. Pomeroy attempts to mitigate any conflicts of interest to the best of his ability by placing the client’s interests ahead of his own, through his fiduciary duty and through the implementation of policies and procedures that address the conflict. Clients are never obligated to purchase recommended insurance through him. Mr. John Boyle is a Managing Principal with Ascent Tax Advisers, LLC. He is a licensed Enrolled Agent who provides tax advisory, tax preparation, tax resolution, and accounting services. Clients are advised that the fees paid to Ascent Tax Advisers for these services are separate from the advisory fees paid to Ascent Capital Partners. Mr. Boyle expects to spend 75% of his professional time in these capacities. The managing directors of Ascent Capital Partners have direct and indirect ownership of Ascent Tax Advisers, LLC. These business activities may create a conflict of interest since individuals associated with Ascent Tax Advisers have a financial incentive to recommend other services based on the compensation received, rather than based solely on the needs of Ascent Capital Partner’s clients. Clients are advised that they always have the right to decide whether to use Ascent Tax Advisers or any affiliated entity or individual for tax or accounting services and that they may use any service provider they choose. Clients to whom Ascent Capital Partners offers investment services are also advised that they always have the right to decide whether to act on insurance, investment, or other service recommendations made by the Ascent Capital Partners; and, if they decide to act on such recommendations, they always have the right to obtain products or services from any insurance or other service provider they choose. 22 | P a g e  Selection and Monitoring of Third-Party Investment Advisers Ascent’s services include recommending and monitoring third party investment advisors. A detailed description of this service can be found under Item 4 and Item 5. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Ascent has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all persons associated with Ascent (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. Ascent and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of Ascent’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (602) 206-2814. B. Personal Trading with Material Interest Ascent allows its Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of its Clients. Ascent does not act as principal in any transactions. However, Ascent and its owners own the Fund, and they may recommend this fund to Clients. Because they own the Fund, it creates a financial incentive to recommend Clients invest in it. Ascent and its owners attempt to mitigate any conflict of interest by disclosing that they are owners of the fund and placing the Clients’ interests ahead of their own. Additionally, Clients are not required to pursue an investment in the Fund after a recommendation is made. C. Personal Trading in Same Securities as Clients Ascent allows its Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that we recommend to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address insider trading (material non-public information controls), gifts and entertainment, outside business activities and personal securities reporting. When trading for personal accounts, 23 | P a g e  Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Ascent requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer. We have also adopted written policies and procedures to detect the misuse of material non-public information. D. Personal Trading at Same Time as Client While Ascent allows its Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Ascent, or any Supervised Person of Ascent, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian(s) Ascent does not have discretionary authority to select the custodian for custodial and execution services. The Client will select the custodian (herein the "Custodian") to safeguard Client assets and authorize Ascent to direct trades to this Custodian as agreed in the IMA. Further, Ascent does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade- by-trade basis. While Ascent does not exercise discretion over the selection of the Custodian, it may recommend the Custodian(s) to Clients for execution and/or custodial services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a broker not recommended by Ascent. The Firm may recommend Equity Trust for self-directed IRAs to allow clients to participate in investments such as private placements. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers whereby an advisor enters into an agreement to place security trades with the broker in exchange for research and other services. Ascent does not participate in soft dollar programs sponsored or offered by any broker-dealer. However, the Advisor receives certain economic benefits from the Custodian. Please see “Item 14 – Client Referrals and Other Compensation”. 24 | P a g e  2. Brokerage Referrals - Ascent does not receive any compensation from any third party in connection with recommending 2. Brokerage Referrals – Ascent does not receive any compensation from any third party in connection with recommendation of establishing a brokerage account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Ascent will place trades within the established account(s) at the custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage account(s). The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account(s). In selecting the Custodian, Ascent will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, and 3) difficulty of execution, Ascent will execute its transactions through an unaffiliated broker-dealer selected by the Client. Ascent may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Firm’s CCO. In addition, each Client account shall be holistically reviewed at least annually. B. Cause for Reviews Accounts may be reviewed more frequently than described above, as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. Clients are encouraged to notify Ascent if changes occur in your personal financial situation that might adversely affect the Client’s investment plan. Additional Client account reviews may be triggered by material market, economic or political events. 25 | P a g e  C. Review Reports The Client will receive brokerage statements no less than quarterly from the trustee or Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account(s). The Advisor may also provide Client with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Ascent Ascent is primarily compensated by its Client. Ascent does not receive commissions (with the exception of insurance) or other compensation from product sponsors, broker-dealers or any un- related third party. Ascent may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial or other services necessary to meet the goals of its Clients. Ascent is not compensated for these referrals. The exception to this is Ascent Tax Advisers, LLC. Please see Item 11 for more information on Ascent Tax Advisers, LLC. Likewise, Ascent may receive non-compensated referrals of new Clients from various third parties. At no point will Ascent accept compensation for referring its own Clients to other investment managers nor will Ascent refer its own Clients to other investment managers for the purpose of investing in their pooled investment vehicles. B. Client Referrals from Solicitors Ascent currently has no contractual agreements with unaffiliated solicitors and/or placement agents who assist with marketing our fund(s) in order to refer potential clients to Ascent. Item 15 – Custody Ascent does not accept or maintain custody of any SMA Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian.” Clients are required to engage the Custodian to retain their funds and securities and direct Ascent to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Ascent to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices”. 26 | P a g e  At times, we assist some Clients with the ability to move money from one account to another. In these situations, you will sign standing letter of instruction (“SLOAs”) with your custodian that grants us the ability to facilitate the transfer. When your money is transferred between accounts with different titles, this is considered a limited form of custody. In 2017, the SEC issued a no‐ action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). We and your custodian follow the safeguards outlined in the letter. These safeguards include: • The Client provides an instruction to the qualified custodian, in writing, which 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 Ascent generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Ascent. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by 27 | P a g e  the Client's execution of, for Clients, an IMA, and for the Fund, an investment management agreement, containing all applicable limitations to such authority. All discretionary trades or investments made by Ascent will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Ascent does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. The Firm will accept proxy-voting responsibility for its Fund Client and keep a log/tracker of all such votes. Item 18 – Financial Information Neither Ascent, nor its management, is aware of any adverse financial situations that would reasonably impair the ability of Ascent to meet all obligations to its Clients. Neither Ascent, nor any of its advisory persons, has been subject to a bankruptcy or financial compromise. The Advisor collects Management Fees from its Fund Clients in an amount greater than $1,200 for services to be performed 6 months or more in advance. Accordingly, the Firm provides a copy of its audited balance sheet to Fund Clients with this brochure. The Advisor does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance from other advisory Clients. 28 | P a g e  Privacy Policy Last Updated: March 2025 Our Commitment to You Ascent Capital Partners, LLC (“Ascent” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Ascent (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Ascent does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Assets and liabilities Social security or taxpayer identification number Name, address, and phone number(s) Income and expenses E-mail address(es) Investment activity Investment experience and goals Account information (including other institutions) 29 | P a g e  What Information do we collect from other sources? Account applications and forms Custody, brokerage, and advisory agreements Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Do we share? Basis For Sharing Can you limit? Servicing our Clients Yes No We may share non-public personal information with non- affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. 30 | P a g e  No Not Shared Yes Yes No Not Shared Marketing Purposes Ascent does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Ascent or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). Information About Former Clients Ascent does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually, to the extent there are any changes from the previous version you received, for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (480) 841-6956. 31 | P a g e