ASPEN WEALTH STRATEGIES, LLC

Aspen Wealth Strategies, LLC Form ADV Part 2A – Disclosure Brochure Effective: December 22, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Aspen Wealth Strategies, LLC (“Aspen” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (303) 421-1113 or by email at info@aspenwealthstrategies.com. Aspen is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the 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 Aspen to assist you in determining whether to retain the Advisor. Additional information about Aspen and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the firm name or CRD# 307424. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2 Arvada, CO 80002 Phone: (303) 421-1113 * Fax: 303-421-2301 www.aspenwealthstrategies.com  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. Aspen 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. Aspen encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes No material changes have been made to this Disclosure Brochure since the annual amendment filing on January 29, 2025. Future Changes From time to time, Aspen may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 307424. You may also request a copy of this Disclosure Brochure at any time by contacting us at (303) 421-1113 or by email at info@aspenwealthstrategies.com. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 2 www.aspenwealthstrategies.com  Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Services A. Firm Information B. Advisory Services Offered C. Client Account Management D. Wrap Fee Programs E. Assets Under Management Item 5 – Fees and Compensation A. Fees for Advisory Services B. Fee Billing C. Other Fees and Expenses D. Advance Payment of Fees and Termination E. Compensation for Sales of Securities Item 6 – Performance-Based Fees and Side-By-Side Management Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis B. Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics B. Personal Trading with Material Interest C. Personal Trading in Same Securities as Clients D. Personal Trading at Same Time as Client Item 12 – Brokerage Practices A. Recommendation of Custodian[s] B. Aggregating and Allocating Trades Item 13 – Review of Accounts A. Frequency of Reviews B. Causes for Reviews C. Review Reports Item 14 – Client Referrals and Other Compensation A. Compensation Received by Aspen B. Compensation for Client Referrals Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information Privacy Policy 1 2 3 4 4 4 6 6 6 6 6 8 8 8 9 9 9 9 9 10 12 13 13 13 13 13 14 14 14 14 15 15 15 15 15 15 16 16 17 17 17 18 Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 3 www.aspenwealthstrategies.com  Item 4 – Advisory Services A. Firm Information Aspen Wealth Strategies, LLC (“Aspen” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the State of Colorado. Aspen was founded in April 2013 and became a registered investment advisor in October 2020. Aspen is owned and operated by Andy McClafin (Chairman, Manager, Member), and Amber K. Anderson (Chief Compliance Officer, Manager, Member). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Aspen. B. Advisory Services Offered Aspen offers wealth management and related services to individuals, high net worth individuals, trusts, estates, businesses and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. The Advisor’s fiduciary commitment is further described in the Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Aspen Private Wealth Services Aspen Private Wealth Services generally includes a combination of discretionary or non-discretionary investment management services in connection with a broad range of financial planning services. These services are described below. Investment Management Services Aspen provides customized investment management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management services. Aspen 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. Aspen will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, options contracts, and alternative investments to meet the needs of its Clients. The Advisor may retain other types of investments from the Clients legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Aspen’s investment approach 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. Aspen will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Aspen evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Aspen may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Aspen 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. Aspen 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 4 www.aspenwealthstrategies.com  which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Participant Account Management (Pontera) As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform, Pontera Solutions, Inc. (“Pontera”), to facilitate management of held away assets such as defined contribution plan participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client account without having access through the Client’s credentials. This independent advisor access ensures that the Advisor will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is not affiliated with the platform in any way and receives no compensation from the platform. A link will be provided to the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access. At no time will Aspen accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Aspen will provide a variety of financial planning and consulting services to Clients. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. 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 planning, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the 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 contribute to charitable giving programs. Aspen may also refer Clients to an accountant, attorney 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 (6) 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 would pose a conflict, as it would 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 implement the transaction through the Advisor. Financial Institution Consulting Services Aspen provides investment consulting services to brokerage customers (“Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with Aspen. Consulting services Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 5 www.aspenwealthstrategies.com  are strictly on products where MSI serves as the broker-dealer. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. Non-Purpose Loans and Lines of Credit The Advisor may introduce certain Clients to US Bank Select, a non-purpose loan program made available through US Bank (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. C. Client Account Management Prior to engaging Aspen to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Aspen, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Aspen will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. ● Portfolio Construction – Aspen will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Aspen will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Aspen does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Aspen. E. Assets Under Management As of December 31, 2024 Aspen manages $279,717,057 in Client assets, $273,274,259 of which are managed on a discretionary basis and $6,442,798 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Aspen Private Wealth Services Wealth management fees are paid monthly, in advance of each month, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees are based on the following tiered schedule: Assets Under Management ($) Annual Rate (%) $0-$499,999 $500,000 - $999,999 $1,000,000 - $1,499,999 1.60% 1.40% 0.90% Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 6 www.aspenwealthstrategies.com  $1,500,000 - $1,999,999 $2,000,000 - $2,499,999 $2,500,000 - $2,999,999 $3,000,000+ 0.70% 0.65% 0.45% Negotiable Certain clients may be on a legacy fee schedule that may differ from the one above. The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor and inclusion of financial planning or other consulting services. All securities held in accounts managed by Aspen will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Aspen Model Portfolios: The Advisor also provides two specific model portfolios to Clients which deter from the investment advisory fee schedule listed above. Clients who utilize these models will pay the Advisor a monthly investment advisory fee in accordance with the fee schedule listed below. Furthermore, specific accounts within these models will be listed out in Schedule A. Annual Rate (%) Model Portfolio Aspen Rainy Day Portfolio 0.25% Aspen Municipal Bond Portfolio 0.40% Investment Management Services Aspen typically offers investment management services as a component of the Aspen Private Wealth services described above. Aspen may also offer its investment management services as a standalone service. Investment management fees are paid monthly, in advance of each month, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior month. Investment management fees are based on the following tiered schedule: Assets Under Management ($) Annual Rate (%) $0-$499,999 $500,000 - $999,999 $1,000,000 - $1,499,999 $1,500,000 - $1,999,999 $2,000,000 - $2,499,999 $2,500,000 - $2,999,999 $3,000,000+ 1.25% 0.65% 0.55% 0.45% 0.35% 0.25% Negotiable Financial Planning Services Aspen typically offers financial planning services as a component of the wealth management services described above. Aspen may also offer its financial planning services as a standalone service at an hourly rate of $275, or on an ongoing basis for $99 per month. On-going fees are paid monthly in advance of each calendar month pursuant to the terms of the financial planning agreement. 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 overall costs will be provided to the Client prior to engaging for these services. Financial Institution Consulting Services Aspen receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who have provided written consent to MSI to receive the consulting service from Aspen. The consulting fee is calculated from the assets under MSI’s management as of the end of a calendar quarter period multiplied by the annualized rate of 61 basis points. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with MSI. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 7 www.aspenwealthstrategies.com  B. Fee Billing Aspen Private Wealth Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] 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 month. The amount due is calculated by applying the monthly rate (annual rate divided by 365/366) to the total assets under management with Aspen at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory 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. Clients provide written authorization permitting advisory fees to be deducted by Aspen to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Investment Management Services Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] 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 month. The amount due is calculated by applying the monthly rate (annual rate divided by 365/366) to the total assets under management with Aspen at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory 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. Clients provide written authorization permitting advisory fees to be deducted by Aspen to be paid directly from their account[s] held by the Custodian as part of the investment management agreement and separate account forms provided by the Custodian. Financial Planning Services Fees for standalone financial planning services may be invoiced up to fifty percent (50%) 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]. Fees for on-going financial planning services are invoiced monthly at the beginning of each month. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Aspen, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian typically does not charge securities transaction fees for ETF and equity trades in a Client's account[s], provided that the respective account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Aspen are separate and distinct from these custody and execution fees. In addition, all fees paid to Aspen for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Aspen, but would not receive the services provided by Aspen which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Aspen to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Aspen Private Wealth Services Aspen may be compensated for its services in advance of the month in which wealth management services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 8 www.aspenwealthstrategies.com  days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Investment Management Services Aspen may be compensated for its services in advance of the month in which investment management services are rendered. Either party may terminate the investment management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Aspen may require an advance deposit for financial planning services, as described above. For ongoing financial planning services Aspen is compensated for ongoing financial planning services at the beginning of each month. Either party may terminate the financial planning agreement by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination of an hourly contract, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. The Advisor will refund any unearned, prepaid planning fees. Upon termination of an ongoing planning engagement, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Aspen does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Aspen does not charge performance-based fees for its investment advisory services. The fees charged by Aspen are as described in Item 5 – Fees and Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client. Aspen does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Aspen offers investment advisory services to, high net worth individuals, trusts, and estates businesses. Aspen generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Aspen primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Aspen are 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. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 9 www.aspenwealthstrategies.com  Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of 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. Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement patterns (trend following or mean reversion). The resulting strategies may involve high-frequency trading. The results of the analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. As noted above, Aspen generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Aspen 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, Aspen 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. Aspen 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. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. 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[s]. 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 part of the portfolio construction process. Following are some of the risks associated with certain components of the Advisor’s strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 10 www.aspenwealthstrategies.com  based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Private Investments If the Advisor recommends a private investment, there are additional risks to consider, which will be detailed in the respective private investment’s offering documents. These include the risk that the investment strategy of a private investment may not be as specific to your needs as a separately managed account. Investors in a private investment will likely not have access to the same liquidity as in a separately managed account. Diversification of assets within a private investment will also not be comparable to a separately managed account. For a more complete discussion of risks associated with a private investment, Clients should thoroughly review the investment’s offering documents. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Non-Purpose Loans and Lines of Credit Non-Purpose Loans and Lines of Credit: Non-Purpose loans and lines of credit carry a number of risks, including but not limited to the risk of market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the lender, that the Client deposit additional funds or securities in the Client’s account[s], or a forced sale of securities in the Client’s collateral account[s]. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 11 www.aspenwealthstrategies.com  Quantitative Investing The Advisor’s investment recommendations are based on proprietary algorithms. The risks associated with this type of investing are as follows: • Quantitative Risk: The risk that the effectiveness of the quantitative strategy can dissipate over time as • similar strategies are adopted and as the market becomes more efficiently priced. Input Data Risk: The risk that the information and data supplied to the algorithm is subject to input and quality errors. The Advisor’s strategies depend on the accuracy and reliability of the data and the strategies may not function properly if the data proves to be incorrect or incomplete, or is input incorrectly. • Programming Risk: The Advisor’s research and strategy development process is extremely complex and the results of that process must then be translated into computer code. Although the Advisor seeks to hire individuals skilled in each of these functions and to provide appropriate levels of oversight, the complexity of the individual tasks, the difficulty of integrating such tasks, and the limited ability to perform “real world” testing of the end product raises the chances that the finished algorithm may contain an error; one or more of such errors could adversely affect a client’s portfolio. • System Risk: The Advisor relies extensively on computer programs and systems in its proprietary algorithms to evaluate securities, to monitor its portfolio, and to generate reports that are critical to oversight of its activities. In addition, certain systems are operated by third party service providers. The Advisor may not always be in the best position to verify the risks or reliability of such third-party systems. These programs or systems, whether operated by a third party or not, may be subject to certain defects, Failures or interruptions, including, but not limited to, those caused by computer “worms,” viruses and power failures. Any such defect or failure could have a material adverse effect on the Advisor’s activities. For example, such failures could cause settlement of trades to fail, lead to inaccurate accounting, recording or processing of trades, and cause inaccurate reports, which may affect the Advisor’s ability to monitor its investment portfolios and its risks. • Operational Risk: The Advisor has developed systems and procedures to control operational risk. Operational risks arising from mistakes made in the trading confirmation or settlement of transactions, from transactions not being properly booked, evaluated or accounted for or other similar disruption in The Advisor’s operations may cause The Advisor to suffer financial loss; the disruption of its business; liability to Clients or third parties; regulatory intervention; or reputational damage. The Advisor relies heavily on its financial, accounting and other data processing systems. Derivative Risks Derivatives are difficult to define but are present in a wide variety of investments. In finance, derivatives refer to contracts whose value is derived from another asset, which include stocks, bonds, currencies, interest rates, commodities, and related indexes. Oftentimes derivatives are used as a hedge to protect against downside risk but derivatives can also be used to speculate. Purchasers of derivatives are essentially wagering on the future performance of that asset. Derivatives include such widely accepted products as futures and options. Due to the speculative nature of derivatives, even when they are being employed to hedge, unique risks are present including a party’s misunderstanding of the contract, inability of the derivative to match or derive its value from the other asset, and the counter-party risk between the parties to the transaction. 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. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Aspen or any of its management persons. Aspen values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The background of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#307424. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 12 www.aspenwealthstrategies.com  Item 10 – Other Financial Industry Activities and Affiliations Financial Institution and Consulting Services Aspen has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in Item 4 above. MSI compensates Aspen for providing consulting services to Brokerage Customers who have purchased products through MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers includes a general review of Brokerage Customers’ investment holdings, which will result in Aspen’s Advisory Persons making specific securities recommendations or offering general investment advice. This relationship presents conflicts of interest. Conflicts are mitigated by Brokerage Customers consenting to receive consulting services from Aspen. In addition, Aspen will not accept or bill for additional compensation on asset under MSI’s management, beyond the consulting fees disclosed in Item 5 above. Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct commission based activities under a broker-dealer. Security Claims Class Action Litigation Aspen has engaged a third-party service provider, Chicago Clearing Corporation (“CCC”), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the Firm’s clients. Aspen does not receive any fees or remuneration in connection with this service nor does it receive any fees from the third-party provider(s). CCC earns a fee based on a flat percentage of all claims it collects on behalf of Aspen's clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. Clients may opt out of this service at any time. If a client opts out, Aspen does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a client’s account. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Aspen has implemented a Code of Ethics (the “Code”) that defines the fiduciary commitment to each Client. This Code applies to all persons associated with Aspen (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding Aspen’s duties to you, the Client. Aspen and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Aspen’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 the Code, please contact the Advisor at (303) 421-1113 or via email at info@aspenwealthstrategies.com. B. Personal Trading with Material Interest Aspen allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Aspen does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Aspen does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Aspen allows 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 are recommended (purchase or sell) to you presents a conflict of interest that, as fiduciaries, Aspen must disclose to you and mitigate through policies and procedures. As noted above, Aspen has 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, Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can 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 Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 13 www.aspenwealthstrategies.com  mitigated by Aspen requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). Aspen has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Aspen allows 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 Aspen, or any Supervised Person of Aspen, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Aspen does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Aspen to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Aspen does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade- by-trade basis. Where Aspen does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian will not incur any extra fee or cost associated with using a Custodian not recommended by Aspen. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Aspen may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Aspen will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions of Fidelity Investments, Inc. (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC or recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Fidelity or Schwab will serve as the Client’s “qualified custodian”. Aspen maintains an institutional relationship with Fidelity or Schwab, whereby the Advisor receives economic benefits from Fidelity (Please see Item 14 – Client Referrals and Other Compensation below). Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Aspen does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 – Client Referrals and Other Compensation. 2. Brokerage Referrals - Aspen does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Aspen 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]). Aspen 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 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 the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Aspen will execute its transactions through the Custodian as Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 14 www.aspenwealthstrategies.com  authorized by the Client. Aspen 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 Advisory Persons of Aspen and periodically by Amber Anderson (Chief Compliance Officer, Manager, Member). Formal reviews are generally conducted at least annually. Additional formal, in-person meetings and reviews may occur more frequently depending on the needs and service level engaged by the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request or based on services rendered. Accounts may be reviewed 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[s]. The Client is encouraged to notify Aspen if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the 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 Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Aspen Aspen may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Aspen may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Aspen has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor has the following benefits from Fidelity: financial support from to assist the Advisor in the launch of its advisory firm, reimbursement to Clients for transfer costs to the platform/Custodian; financing services, receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 15 www.aspenwealthstrategies.com  Aspen has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Aspen. As a registered investment advisor participating on the Schwab Advisor Services platform, Aspen receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Aspen that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Aspen believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Aspen does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Aspen does not accept or maintain custody of any Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Aspen exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Aspen to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Aspen to ensure accuracy, as the Custodian does not perform this review Money Movement Authorization - For instances where Clients authorize Aspen to move funds between their accounts, Aspen and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Aspen 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 Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 16 www.aspenwealthstrategies.com  specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Aspen. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Aspen will be in accordance with each Client's investment objectives and goals. Where Aspen does not have discretionary authority for an account, an Advisory Person with the Advisor will contact the Client and obtain formal approval for each investment transaction prior to executing the purchase, sale or reallocation trade[s]. Such communications may be verbal or via email. For these accounts, the Advisor cannot place a trade without formal approval for each trade. Item 17 – Voting Client Securities Aspen 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. Item 18 – Financial Information Neither Aspen, nor its management, have any adverse financial situations that would reasonably impair the ability of Aspen to meet all obligations to its Clients. Neither Aspen, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Aspen is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 17 www.aspenwealthstrategies.com  Privacy Policy Effective: December 22, 2025 Our Commitment to You Aspen Wealth Strategies, LLC (“Aspen” 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. Aspen (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. Aspen 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 Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents 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. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 18 www.aspenwealthstrategies.com  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. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients 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. No Not Shared Marketing Purposes Aspen 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 Aspen 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. Yes Yes 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). No Not Shared Information About Former Clients Aspen 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 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 (303) 421-1113 or via email at info@aspenwealthstrategies.com. Aspen Wealth Strategies, LLC 8333 Ralston Road, Suite 2, Arvada, CO 80002 Phone: (303) 421-1113 * Fax: (303) 421-2301 Page 19 www.aspenwealthstrategies.com