ASPEN CAPITAL MANAGEMENT

Firm Brochure (Part 2A of Form ADV) ASPEN CAPITAL MANAGEMENT, LLC 101 S Capitol Blvd, Suite 610 Boise, ID. 83702 Phone: 208-345-0174 www.aspencapitalmgmt.com rachel@aspencapitalmgmt.com This brochure provides information about the qualifications and business practices of ASPEN CAPITAL MANAGEMENT, LLC. If you have any questions about the contents of this brochure, please contact us at: 208- 345-0174, or by email at: RACHEL@ASPENCAPITALMGMT.COM. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about ASPEN CAPITAL MANAGEMENT, LLC is available on the SEC’s website at www.adviserinfo.sec.gov March 5, 2025 Aspen Capital Management  Item 2 - Material Changes Annual Update The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update ASPEN CAPITAL MANAGEMENT, LLC has discretionary authority. (Item 16) ASPEN CAPITAL MANAGEMENT, LLC updated its fee schedule. (Item 5) Rachel Lysne replaced Mike Mers as the Chief Compliance Officer. Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by phone at: 208-345-0174 or by email at: RACHEL@ASPENCAPITALMGMT.COM. i Aspen Capital Management  Table of Contents Item 2 - Material Changes .............................................................................................. i Annual Update ............................................................................................................ i Material Changes since the Last Update .................................................................... i Item 4 - Advisory Business .......................................................................................... 1 Firm Description ......................................................................................................... 1 Principal Owners ........................................................................................................ 1 Types of Advisory Services ........................................................................................ 1 Tailored Relationships ............................................................................................... 2 Types of Agreements ................................................................................................. 2 Financial Planning Agreement ................................................................................... 2 Advisory Service Agreement ...................................................................................... 3 Asset Management .................................................................................................... 4 Termination of Agreement ......................................................................................... 4 Item 5 - Fees and Compensation ................................................................................. 4 Description ................................................................................................................. 4 Fee Billing .................................................................................................................. 4 Other Fees ................................................................................................................. 5 Expense Ratios .......................................................................................................... 5 Past Due Accounts and Termination of Agreement ................................................... 5 Item 6 - Performance-Based Fees ................................................................................ 6 Sharing of Capital Gains ............................................................................................ 6 Item 7 - Types of Clients ............................................................................................... 6 Description ................................................................................................................. 6 Account Minimums ..................................................................................................... 6 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................... 6 Methods of Analysis ................................................................................................... 6 Investment Strategies ................................................................................................ 6 Risk of Loss ............................................................................................................... 7 Item 9 - Disciplinary Information .................................................................................. 8 Legal and Disciplinary ................................................................................................ 8 Item 10 - Other Financial Industry Activities and Affiliations .................................... 8 Financial Industry Activities ........................................................................................ 8 Aspen Capital Management  Affiliations .................................................................................................................. 8 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................... 8 Code of Ethics............................................................................................................ 8 Participation or Interest in Client Transactions ........................................................... 9 Personal Trading........................................................................................................ 9 Item 12 - Brokerage Practices ...................................................................................... 9 Selecting Brokerage Firms ......................................................................................... 9 Best Execution ......................................................................................................... 10 Soft Dollars .............................................................................................................. 10 Order Aggregation ................................................................................................... 10 Item 13 - Review of Accounts ..................................................................................... 10 Periodic Reviews ..................................................................................................... 10 Review Triggers ....................................................................................................... 10 Regular Reports ....................................................................................................... 10 Item 14 - Client Referrals and Other Compensation................................................. 11 Incoming Referrals ................................................................................................... 11 Referrals Out............................................................................................................ 11 Other Compensation ................................................................................................ 11 Item 15 – Custody........................................................................................................ 11 Account Statements ................................................................................................. 11 Performance Reports ............................................................................................... 12 Item 16 - Investment Discretion ................................................................................. 12 Discretionary Authority for Trading ........................................................................... 12 Limited Power of Attorney ........................................................................................ 13 Item 17 - Voting Client Securities............................................................................... 13 Proxy Votes ............................................................................................................. 13 Item 18 - Financial Information................................................................................... 13 Financial Condition .................................................................................................. 13 Business Continuity Plan ........................................................................................... 13 General .................................................................................................................... 13 Disasters .................................................................................................................. 13 Alternate Offices ...................................................................................................... 14 Loss of Key Personnel ............................................................................................. 14 Aspen Capital Management  Information Security Program .................................................................................... 14 Information Security ................................................................................................. 14 Privacy Notice .......................................................................................................... 14 Education and Business Standards ......................................................................... 16 Aspen Capital Management  Item 4 - Advisory Business Firm Description ASPEN CAPITAL MANAGEMENT, LLC, (“FIRM NAME”) was founded in 2002. ASPEN CAPITAL MANAGEMENT, LLC provides personalized confidential financial planning and investment management to individuals, trusts, estates, and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, limited investment tax planning, investment management, education funding, retirement planning, and limited estate planning. ASPEN CAPITAL MANAGEMENT, LLC is strictly a fee-only financial planning and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. However, we will often thank our clients for referrals with “thank you” gifts or gift certificates of $100 in value or less. Periodic reviews take place with clients to review their portfolio, discuss portfolio rebalancing that may be necessary and to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting (and in many cases multiple meetings), which may be by phone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Principal Owners Mike Mers is an 85% stockholder. Katie Dow is a 10% stockholder. Rachel Lysne is a 5% stockholder. Types of Advisory Services ASPEN CAPITAL MANAGEMENT, LLC provides investment supervisory services, also known as asset management services; furnishes investment advice through consultations and provides financial planning services. On more than an occasional basis, ASPEN CAPITAL MANAGEMENT, LLC furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and estate planning. - 1 - Aspen Capital Management  When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. As of December 2024 ASPEN CAPITAL MANAGEMENT, LLC manages approximately $1,108,473,506 in assets on a discretionary basis and $22,157,923 on a non-discretionary basis. Tailored Relationships The goals and objectives for clients are documented in their financial plans. Investment policy statements, which define the client’s asset allocation targets, are created and reflect the client’s goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client relationships. Financial Planning Agreement A financial plan is designed to help the client with all aspects of financial planning. The financial plan may include, but is not limited to: a net worth statement; a review of investment accounts; one or more retirement scenarios; and education planning with funding recommendations. Implementation of the recommendations is at the discretion of the client. - 2 - Aspen Capital Management  The fee for a financial plan is predicated upon the facts known at the start of the engagement. The fee range is $2,000 to $10,000 and is negotiable. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. In the event that the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. Advisory Service Agreement Most clients choose to have ASPEN CAPITAL MANAGEMENT, LLC manage their assets in order to obtain ongoing advice and financial planning. Different aspects of the client’s financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Agreement may include, but is not limited to: asset allocation recommendations, investment management (including performance reporting), and recommended portfolio rebalancing when required. A quarterly fee is based on the total value of assets under management for development and implementation of the investment policy, account reviews, and investment policy updating. Our fees start at 1.00% per year and decline to 0.35% per year based on aggregate assets under management. Fees are negotiable. Fees for assets managed that are not custodied by Charles Schwab are billed per the rates above or they may be negotiated. Fees for each quarter are paid at the end of the quarter based on the total value of assets under management at the close of trading on the last business day of the quarter. Fees will be electronically deducted from your account(s). Fees for the initial quarter will be pro-rated and begin on the date the advisory agreement is signed. If either party chooses to terminate this agreement, fees will be pro-rated to the end of the 30-day notice period. Although the Advisory Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or ASPEN CAPITAL MANAGEMENT, LLC may terminate an Agreement by written notice to the other party. If either party chooses to terminate this agreement fees will be pro-rated to the end of the 30-day notice period. The portfolio value on the date of written notice is used as the basis for the fee computation. - 3 - Aspen Capital Management  Asset Management Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually through our custodian, Charles Schwab. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Charles Schwab does not charge a transaction fee for the purchase or sale of individual stocks and exchange- traded funds, but does charge a transaction fee for the purchase or sale of some mutual funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. ASPEN CAPITAL MANAGEMENT, LLC does not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), corporate debt securities, commercial paper, certificates of deposit, municipal securities, and U. S. government securities. Initial public offerings (IPOs) are not available through ASPEN CAPITAL MANAGEMENT, LLC. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying ASPEN CAPITAL MANAGEMENT, LLC in writing and paying the rate detailed in the Advisory Services Agreement. ASPEN CAPITAL MANAGEMENT, LLC may terminate any of the aforementioned agreements at any time by notifying the client in writing. Item 5 - Fees and Compensation Description ASPEN CAPITAL MANAGEMENT, LLC bases its investment management fees on a percentage of assets under management. Financial plans are priced according to the degree of complexity associated with the client’s situation. Fees are negotiable. Fee Billing Investment management fees are billed quarterly, in arrears, meaning that we charge you after the three-month billing period has ended. Our fees are calculated based on the number of days in a quarter within a 365-day period. Fees are electronically deducted from a designated client account(s) to facilitate billing. The client must consent in advance to direct debiting of their investment account through their approval of our advisory agreement. - 4 - Aspen Capital Management  If the Client’s quarterly fee – calculated using the fee schedule above – is less than $1,250, a minimum quarterly fee of $1,250 will be assessed. Our minimum fee is negotiable. Fees for financial plans are billed upon delivery of the financial plan. Other Fees Custodians charge transaction fees on purchases or sales of certain mutual funds, stocks, bonds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Clients will sometimes incur brokerage and other transaction costs (see page 8 for Brokerage Practices). ASPEN CAPITAL MANAGEMENT, LLC does not receive any compensation from custodians. ASPEN CAPITAL MANAGEMENT, LLC, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Expense Ratios Mutual funds generally charge a fee for their services as investment managers. Mutual funds also charge other fees in addition to their management fees. The aggregate fees of the management company are called an expense ratio. For example, an expense ratio of 0.30 means that the mutual fund company charges 0.3% annually for their services. These fees are in addition to the fees paid by you to ASPEN CAPITAL MANAGEMENT, LLC. ASPEN CAPITAL MANAGEMENT, LLC does not receive any compensation from mutual fund companies. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Past Due Accounts and Termination of Agreement ASPEN CAPITAL MANAGEMENT, LLC reserves the right to stop work on any account that is more than 30 days overdue. In addition, ASPEN CAPITAL MANAGEMENT, LLC reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in ASPEN CAPITAL MANAGEMENT, LLC’s judgment, to providing proper financial advice. - 5 - Aspen Capital Management  Item 6 - Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. ASPEN CAPITAL MANAGEMENT, LLC does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7 - Types of Clients Description ASPEN CAPITAL MANAGEMENT, LLC generally provides investment advice to individuals, trusts, estates, or business entities. However, the vast majority of our clients are individuals, families, or non-profit organizations. Client relationships vary in scope and length of service. Account Minimums In most cases ASPEN CAPITAL MANAGEMENT, LLC does not have an account minimum. While we don’t have an account minimum, we do have a minimum quarterly fee. If the Client’s quarterly fee – calculated using the fee schedule above – is less than $1,250, a minimum quarterly fee of $1,250 will be assessed. Our minimum fee is negotiable. Other exceptions will apply to employees of ASPEN CAPITAL MANAGEMENT, LLC and their relatives, or relatives of existing clients. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Analysis is typically done with the historical returns of major global indexes of all asset classes. An example of these indexes would be the S&P 500 for US large cap equities, the MSCI Emerging Market index for emerging market equities and the Barclays Aggregate Bond Index for US bonds. This index information is usually obtained through Orion and Dimensional Fund Advisors Returns 2.0 program. Investment Strategies The primary investment strategy used on client accounts is strategic asset allocation utilizing a global equity and global REIT approach (using mutual funds and exchange traded funds from Dimensional Fund Advisors) with - 6 - Aspen Capital Management  multi-sector bond funds. Portfolios are globally diversified to control the risk associated with traditional markets. ASPEN CAPITAL MANAGEMENT, LLC may, at its sole discretion, deviate from this strategy if it believes it is in the client’s best interest. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. Each client executes an Investment Policy Statement that documents their objectives and their desired asset allocation. The client may change these objectives at any time. It is the client’s responsibility to immediately notify ASPEN CAPITAL MANAGEMENT, LLC in writing if there has been a change in their financial situation, risk tolerance or investment objectives, or if they desire to impose, add, or modify any reasonable restrictions to the management of my accounts. Risk of Loss All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from - 7 - Aspen Capital Management  a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Item 9 - Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events. Item 10 - Other Financial Industry Activities and Affiliations Financial Industry Activities ASPEN CAPITAL MANAGEMENT, LLC is a Registered Investment Advisor with the Securities and Exchange Commission. Affiliations ASPEN CAPITAL MANAGEMENT, LLC has no arrangements that are material to its advice or its clients. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of ASPEN CAPITAL MANAGEMENT, LLC have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The Code of Ethics sets forth our expectations of appropriate ethical conduct by our employees. The Code provides guidance and specific standards of conduct for situations where violations, inadvertent or otherwise, could occur in the conduct of business. The Code describes appropriate conduct regarding gifts and entertainment, outside employment, and personal investment and trading activities. In addition, the Code prohibits dishonest and fraudulent acts and reaffirms our commitment to client confidentiality. Every employee and associated person is required annually to attest to reading and being up to date on the standards set forth in the Code. The firm - 8 - Aspen Capital Management  will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions ASPEN CAPITAL MANAGEMENT, LLC and its employees buy or sell securities that are also held by clients. For securities that are not traded at net asset value (NAV), employees may not trade their own securities ahead of client trades. The Aspen Capital Management, LLC Compliance manual outlines the policy that employees may not place securities trades ahead of client trades, and employee trades of non-NAV securities must be aggregated with client trades when administratively possible to receive the same price. Employees comply with the provisions of the ASPEN CAPITAL MANAGEMENT, LLC Compliance Manual. Personal Trading The Chief Compliance Officer of ASPEN CAPITAL MANAGEMENT, LLC is Rachel Lysne. Rachel Lysne or Mike Mers review all employee covered trades (non mutual fund or ETF trades) before the trades are placed. The personal trading reviews ensure that the personal trading of employees does not affect the markets for all securities that are not traded at net asset value (NAV). Since most employee trades are small mutual fund trades or exchange-traded fund trades (non-covered trades), the trades do not affect the securities markets. The personal trading reviews also ensure personal securities transactions do not include insider trading, trading securities on the watch list, or IPOs. Item 12 - Brokerage Practices Selecting Brokerage Firms ASPEN CAPITAL MANAGEMENT, LLC does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their need for such services. ASPEN CAPITAL MANAGEMENT, LLC recommends custodians based on the proven integrity and financial responsibility of the firm and the best execution of orders at reasonable commission rates. ASPEN CAPITAL MANAGEMENT, LLC recommends discount brokerage firm Charles Schwab. Not all advisers require their clients to direct brokerage. By the client directing brokerage, ASPEN CAPITAL MANAGEMENT, LLC may be unable to achieve most favorable execution of client transactions, and this practice may cost the client more money. ASPEN CAPITAL MANAGEMENT, LLC does not receive fees or commissions from any of these arrangements. - 9 - Aspen Capital Management  Best Execution ASPEN CAPITAL MANAGEMENT, LLC reviews Charles Schwab’s best execution report annually. In addition to best execution trading information we evaluate the value of services provided by Charles Schwab in comparison with other custodians. Since the firm's clients predominately own mutual funds traded at NAV, the firm will compare brokerage commission rates for trading mutual funds as part of its annual review. The firm also follows an internal set of guidelines for trading ETFs in pursuit of best execution. The annual review is documented in the ASPEN CAPITAL MANAGEMENT, LLC Compliance Manual. ASPEN CAPITAL MANAGEMENT, LLC does not receive any portion of the trading fees. Soft Dollars ASPEN CAPITAL MANAGEMENT, LLC receives no soft dollars from Charles Schwab or any other firm. Order Aggregation Most trades are mutual funds, where trade aggregation does not garner any client benefit, or exchange-traded funds. We have the ability to block trade securities in our clients’ portfolios. If we opt to block trade security positions, then all participants receive the same price executed on that day. Item 13 - Review of Accounts Periodic Reviews Account reviews are performed either annually or semi-annually by the financial advisory team. Account reviews may be performed more or less frequently if market conditions dictate or by client request. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation. Regular Reports Clients have the ability to generate portfolio reports in their client vault from ASPEN CAPITAL MANAGEMENT, LLC on an ongoing basis. These reports include a list of investments, asset allocation vs target allocation, year to date aggregate portfolio performance, year to date performance by asset class (vs benchmark indexes), historical performance since inception and current portfolio value vs. cumulative net investment. In addition, clients receive monthly or quarterly statements from Charles Schwab. In the case of certain mutual funds, sometimes dividends are accrued and due on the last day of the month but not posted until the first day of the following month. In these cases, the mutual fund company will post the - 10 - Aspen Capital Management  dividend after our custodian cutoff time when they receive daily pricing from all fund companies. The dividend may show on the custodian statement on the last day of the month due to backdating in the custodian software, but the transaction shows in our reporting software on the first day of the following month. In those cases, the custodian report may contain different account values than the account values reported in our portfolio management software. This situation could impact our quarterly billing. Item 14 - Client Referrals and Other Compensation Incoming Referrals ASPEN CAPITAL MANAGEMENT, LLC has been fortunate to receive many client referrals over the years. The referrals came from current clients, accountants, attorneys, personal friends and other similar sources. From time to time we do thank those who’ve provided a referral with a “thank you” gift, $100 or less in value. Referrals Out ASPEN CAPITAL MANAGEMENT, LLC does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation Not applicable. Item 15 – Custody Account Statements Assets are held at Charles Schwab, which provides account statements and annual 1099 tax statements directly to clients at their address of record on a monthly basis or quarterly basis. In some cases the clients will ask ASPEN CAPITAL MANAGEMENT, LLC. To advise, manage and report on a 401K/403b retirement account or deferred compensation account that can’t be transferred to Charles Schwab. In those cases we’ll use a third-party service to capture data from this account and import the data into our portfolio system. The custodian of these accounts is responsible for providing account statements and annual 1099 tax statements directly to clients at their address of record. Clients should carefully review statements provided by custodians, and clients should compare the account statements they receive from the client custodian with any reports they receive from Aspen Capital Management. - 11 - Aspen Capital Management  We use a data aggregator to gather daily pricing and transaction information from the custodians of our clients’ accounts not custodied at Charles Schwab. On occasion, custodians update their daily pricing and transaction details after our software cutoff time. In these cases, the price information in our system may reflect the previous day’s pricing, leading to potentially inaccurate account values and billing in our portfolio management software. In the case of securities custodied at Fidelity, security prices provided on the Fidelity website are shown having two decimal places (i.e $14.62). However, Fidelity’s actual price goes out to 6 decimal places ($14.628391). As a result, on the Fidelity website, if you multiply the price by the quantity of shares the total value does not match the value shown on their website. This discrepancy between the displayed and actual prices lead data aggregators to incompletely capture security prices and resulting security values on a daily basis. This harvesting discrepancy may lead to clients’ held-away assets custodied at Fidelity to be undervalued in our portfolio management software and underbilled on a quarterly basis. Aspen Capital Management does have custody of some client assets due to having authority to make third-party money movements based on standing letters of authorizations signed by the clients. Additionally, Aspen Capital Management has custody of some client assets not custodied at Charles Schwab due to Aspen Capital Management’s ability to access clients’ accounts through client IDs and passwords kept on file. Performance Reports Clients are urged to compare the account statements received directly from Charles Schwab or other custodians to the performance report statements provided by ASPEN CAPITAL MANAGEMENT, LLC. Item 16 - Investment Discretion Discretionary Authority for Trading ASPEN CAPITAL MANAGEMENT, LLC provides discretionary and non- discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, ASPEN CAPITAL MANAGEMENT, LLC generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the - 12 - Aspen Capital Management  account, the total amount of the securities to be bought/sold, or the price per share. Limited Power of Attorney A limited power of attorney is a trading authorization provided by the client. You sign a limited power of attorney when completing your account applications so that we may execute the trades that you have approved. The client approves the use of Charles Schwab as the custodian of their accounts. ASPEN CAPITAL MANAGEMENT, LLC does not receive any portion of the transaction fees or commissions paid by the client to Charles Schwab on any trades. Item 17 - Voting Client Securities Proxy Votes ASPEN CAPITAL MANAGEMENT, LLC does not vote proxies on securities. Clients are expected to vote their own proxies. When assistance on voting proxies is requested, ASPEN CAPITAL MANAGEMENT, LLC will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18 - Financial Information Financial Condition ASPEN CAPITAL MANAGEMENT, LLC does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because ASPEN CAPITAL MANAGEMENT, LLC does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. Business Continuity Plan General ASPEN CAPITAL MANAGEMENT, LLC has a Business Continuity Plan in place that provides steps to mitigate and recover from the loss of office space, communications, or services. Disasters The Business Continuity Plan covers natural disasters such as snow storms, hurricanes, tornados, and flooding. The Plan covers man-made disasters - 13 - Aspen Capital Management  such as fire, bomb threat, and internet outage. Electronic files are securely backed up daily and archived offsite in multiple data center facilities. Alternate Offices An alternate office location is identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within ten days of a disaster that dictates moving our office to an alternate location. Loss of Key Personnel As a fiduciary, ASPEN CAPITAL MANAGEMENT, LLC has certain legal obligations, including the obligation to act in clients’ best interest. ASPEN CAPITAL MANAGEMENT, LLC maintains a Business Continuity and Succession Plan and seeks to avoid a disruption of services to clients in the event of an unforeseen loss of key personnel, due to disability or death. ASPEN CAPITAL MANAGEMENT, LLC can provide additional information to any current or prospective client upon request to Mike Mers, Principal at mike@aspencapitalmgmt.com. Information Security Program Information Security ASPEN CAPITAL MANAGEMENT, LLC maintains an information security program to reduce the risk that your personal and confidential information may be breached. Privacy Notice ASPEN CAPITAL MANAGEMENT, LLC is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, and information about transactions between you and third parties. We use this information to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by phone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. - 14 - Aspen Capital Management  We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed. We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing. - 15 - Aspen Capital Management  Brochure Supplement (Part 2B of Form ADV) Education and Business Standards ASPEN CAPITAL MANAGEMENT, LLC requires that advisors in its employ have a bachelor's degree and further work demonstrating knowledge of financial planning and investment management. Additionally, advisors must have work experience that demonstrates their aptitude for financial planning and investment management. - 16 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Mike Mers – Founder and Principal Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Michael Mers that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Mike Mers is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Mike Mers Date of Birth: May 4, 1970 Educational Institutions (Year): • Bristol University (England), Master in Business Administration (1994) o International Rotary Scholar • Boise State University, Bachelors in Business (1992) Business Experience: Founder, Aspen Capital Management LLC (2002-Current) Partner, BRM Capital (1999-2001) Senior Investment Manager, Intel Capital (1998-1999) Product Marketing Manager, Hewlett Packard (1994-1998) • • • • • Marketing Intern, Hewlett Packard (1990-1993) Certifications and Professional Designations: Series 65. Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities – None. Item 5 - Additional Compensation – Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Mike Mers is supervised by Rachel Lysne, Chief Compliance Officer. Rachel reviews Mike’s work through frequent office interactions. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. Supervisor contact info: 208-345- 0174 ext. 4; rachel@aspencapitalmgmt.com - 17 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Katie Dow – Financial Advisor Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Katherine Dow that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Katie Dow is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Katie Dow Date of Birth: February 23, 1984 Educational Institutions (Year): • Rocky Mountain College, Bachelors in Business Administration (2013) • • Kansas State University, Masters in Financial Planning (2022) Kansas State University, Graduate Certificate in Financial Therapy (2022) Certifications and Professional Designations: Series 65. Business Experience: Financial Advisor, Aspen Capital Management LLC (January 2019-Current) • • Global Experience and Community Engagement, Carnival Corporation (Jan 2016-Dec 2018) • AVP Loan Officer, Rocky Mountain Bank (Oct 2008-Jan 2016) • Loan Officer, Real Estate, Bank of America (June 2006-Oct 2008) Item 3 - Disciplinary Information – None. Item 4 - Other Business Activities - TamFam LLC is a limited liability company made up of one single family home, that is located in Donnelly Idaho and used as a short-term rental. Katie Dow owns 1/3 of the LLC, along with her husband who owns 1/3 and Dustin Dlouhy, who is a client, and owns 1/3. There are no material conflicts of interest. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Katie Dow is supervised by Mike Mers, founder. He reviews Katie’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174; mike@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 18 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Lavea G. Thomas – Financial Advisor Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Lavea Thomas that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Lavea Thomas is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Lavea G. Thomas Date of Birth: January 15, 1980 Educational Institutions (Year): • Boise State University, Bachelors in Accountancy (2003) Certifications and Professional Designations: Certified Financial Planner™, Series 65. See last page for certification requirements. Business Experience: • • • • • • Financial Advisor, Aspen Capital Management LLC (May 2021-Current) Financial Advisor, Legacy Wealth Management (2020-2021) Executive Vice President, Waypoint Securities (2017-2019) Executive Vice President, MCI Securities (2016-2017) Senior Vice President, RC Securities (2011-2015) Senior Vice President, Grubb & Ellis Securities (2007-2011) Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities - None. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Lavea Thomas is supervised by Mike Mers, founder. He reviews Lavea’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174; mike@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 19 - Aspen Capital Management  - 20 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Jake Taylor – Financial Advisor Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Jake Taylor that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Jake Taylor is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Jake Taylor Date of Birth: December 16, 1996 Educational Institutions (Year): • Boise State University, Bachelor of Science in Finance (2019) Certifications and Professional Designations: Certified Financial Planner™, Series 65. See last page for certification requirements. Business Experience: Financial Advisor, Aspen Capital Management LLC (2021-Current) • • Business Development Representative, Clearwater Analytics (2019-2021) • Business Development Intern, Clearwater Analytics (2017-2019) Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities - None. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Jake Taylor is supervised by Mike Mers, founder. He reviews Jake’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174; mike@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 21 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Trevor Hotmer – Financial Analyst Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Trevor Hotmer that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Trevor Hotmer is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Trevor Hotmer Date of Birth: May 9, 2001 Educational Institutions (Year): • Boise State University, Bachelor of Science in Business Administration (2022) o Concentration: Finance Certifications and Professional Designations: Series 65. Business Experience: • • Financial Analyst, Aspen Capital Management LLC (2021-Current) Intern, Aspen Capital Management LLC, (2021-2022) Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities - None. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Trevor Hotmer is supervised by Lavea Thomas, financial advisor. She reviews Trevor’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174 ext. 3; lavea@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 22 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Rachel Lysne – Director of Operations Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Rachel Lysne that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Rachel Lysne is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Rachel Lysne Date of Birth: March 27, 1994 Educational Institutions (Year): • Pepperdine University, Bachelor of Science in Business Administration (2016) o Minor in Professional and Academic Writing o Magna Cum Laude Certifications and Professional Designations: Series 65. Business Experience: Founder and Executive Editor, Bluebird Writing and Editing Solutions (2016-Current) • Director of Operations, Aspen Capital Management LLC (2018-Current) • • Book Editor, Elevate Publishing (2016-2017) Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities - None. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Rachel Lysne is supervised by Mike Mers, founder. He reviews Rachel’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174; mike@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 23 - Aspen Capital Management  Part 2B Form ADV: Brochure Supplement, February 2025 Item 1 – Cover Page Nathan Burman – Operations Associate Aspen Capital Management, LLC 101 S Capitol Blvd. Suite 610 Boise, ID 83702 (208) 345-0174 This brochure supplement provides information about Nathan Burman that supplements the Aspen Capital Management, LLC Part 2A Brochure. You should have received a copy of that brochure. Please contact Rachel Lysne at 208-391-4547 if you did not receive Aspen Capital Management, LLC’s brochure or if you have any questions about the content of this supplement. Additional information about Nathan Burman is available on the SEC’s website at http://www.advisorinfo.sec.gov. Item 2 - Educational Background and Business Experience Nathan Burman Date of Birth: September 3, 1999 Educational Institutions (Year): • The College of Idaho, Bachelor of Science in Business Administration (2022) o Concentration: Finance o Minors: Mathematics, Political Economy, Spanish Certifications and Professional Designations: Series 65. Business Experience: • Operations Associate, Aspen Capital Management LLC (2022-Current) Item 3 - Disciplinary Information - None. Item 4 - Other Business Activities - None. Item 5 - Additional Compensation - Advisors have the opportunity to receive additional compensation when opening new accounts and increasing assets. This compensation comes only from Aspen Capital Management, LLC and does not include any compensation from third parties, including asset managers or custodians. Item 6 – Supervision Nathan Burman is supervised by Rachel Lysne, director of operations. She reviews Nate’s work through frequent office interactions. Supervisor’s contact information: 208-345-0174 ext. 4 rachel@aspencapitalmgmt.com. Client accounts are reviewed at least annually. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. - 24 - Aspen Capital Management  Certification Requirements Certified Financial Planner: The program is administered by the Certified Financial Planner Board of Standards, Inc. Those with the CFP® designation have demonstrated competency in all areas of finance related to financial planning. Candidates complete studies on over 100 topics, including stocks, bonds, taxes, insurance, retirement planning, and estate planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience and agree to adhere to the CFP Board’s code of ethics and professional responsibility and financial planning standards. - 25 - Aspen Capital Management