ASPIRE WEALTH ARCHITECTS

DISCLOSURE DOCUMENT – FORM ADV PART 2A Aspire Wealth Architects IARD/CRD Number: 297090 Main Office Mailing Address: 150 N Meadows Dr, Suite 220, Wexford, PA 15090 Main Business Phone: (412) 415-1140 Primary Website: www.AspireWealthArchitects.com March 30, 2026 This Brochure provides information about the qualifications and business practices of Aspire Wealth Architects. If you have any questions about the content of this Brochure, please contact Caitlin Cully Ross of Aspire Wealth Architects’ Compliance Department at (412) 879-0584 or at Caitlin@Aspirewealtharchitects.com . The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Aspire Wealth Architects is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications distributed by Aspire Wealth Architects provide you with information to assist you in determining whether to hire Aspire Wealth Architects as your Investment Advisor. You can find additional information about Aspire Wealth Architects by viewing our Form ADV Part I on the SEC’s website, www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm’s is 297090. Aspire Wealth Architects P a g e | 1  Item 2 – Material Changes The Material Changes section of this brochure will be updated annually and/or when material changes have occurred since the previous release of the Firm Brochure. The following changes have been incorporated into this version of the Brochure since our last annual amendment: Item 4 (Advisory Business) – Changes were made to reflect our ownership change. The principal owners of our firm are John J. Cully III, Caitlin Cully and Walter A. Laub. Item 4 was also updated to further clarify our investment advisory services. Please see Item 4 for additional details. Item 5 (Fees and Compensation) – Updated language to further clarify how the Firm calculates it’s fee for investment advisory services and that our fee for these services will not exceed 1.25%. Please see Item 5 for additional details. Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) – Updated the investment strategies section to further clarify our investment strategy. Please see Item 8 for additional details. Item 12 – Brokerage Practices – Language was added to further describe our relationship with Schwab, including the services they provide Aspire Wealth Architects to help service our clients and manage our firm and the conflict this may present. Please see Item 12 for additional details. Additional changes were made throughout for language consistency and clarification. Aspire Wealth Architects P a g e | 2  Item 3 – Table of Contents Contents Item 2 – Material Changes ......................................................................................................... 2 Item 3 – Table of Contents ......................................................................................................... 3 Item 4 – Advisory Business ........................................................................................................ 4 Item 5 – Fees and Compensation .............................................................................................. 5 Item 6 – Performance-Based Fees and Side-by-Side Management ........................................... 6 Item 7 – Types of Clients ........................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 6 Item 9 – Disciplinary Information ................................................................................................ 8 Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 9 Item 12 – Brokerage Practices ................................................................................................... 9 Item 13 – Review of Accounts .................................................................................................. 11 Item 14 – Client Referrals and Other Compensation ................................................................ 11 Item 15 – Custody .................................................................................................................... 12 Item 16 – Investment Discretion ............................................................................................... 12 Item 17 – Voting Client Securities ............................................................................................ 12 Item 18 – Financial Information ................................................................................................ 12 Aspire Wealth Architects P a g e | 3  Item 4 – Advisory Business Aspire Wealth Architects (“Firm”) is a Pennsylvania corporation headquartered in Wexford, Pennsylvania. The company was founded in 2018, and the principal owners of the firm are; John J. Cully III, Caitlin Cully, and Walter A. Laub. Aspire Wealth Architects’ mission is to provide comprehensive planning to clients as an ongoing relationship to ensure they achieve their goals and aspirations. Our goal is to develop a deep understanding of what matters to our clients. Our value is delivering advice relative to one’s life and building a comprehensive plan that provides a map to accomplish their goals. Our process is designed to ensure our clients can feel confident in the goals, aspirations and legacy they wish to achieve by measuring the uncertainty of the markets and managing the controllables: fees, taxes, and level of risk. We adhere to a detailed level of portfolio management that is based on a deep understanding of the impact that fees, taxes, and unnecessary investment risk has on clients’ lives. Our portfolio management encompasses the use of diversified funds that meet our criteria to minimize portfolio expenses and taxes. Aspire Wealth Architects’ value proposition to its clients consists of the following: • Continual collaboration and communication with the client to develop and maintain a comprehensive plan encompassing their goals and aspirations. • Ongoing monitoring and measurement of a client’s financial plan. • Ongoing portfolio management adhering to an evidence-based process and achievement of certain criteria to ensure minimal impact from expenses and taxes. In all our efforts to deliver the best planning and management for our clients we remain objective and unbiased, continually seeking to advance our methods, supporting tools, and research while attempting to establish ourselves as the standard by which our industry measures quality, honesty, and integrity. INVESTMENT ADVISORY SERVICES Aspire Wealth Architects offers investment advisory services to individuals, trusts, institutions and endowments. As a client of Aspire Wealth Architects you will sign an Investment Advisory Agreement directly with our firm. At the onset of our relationship, we will conduct an initial review of your financial picture, including your specific goals, aspirations, and legacy objectives. As we progress through the stages of planning we will prioritize each of your financial and related non-financial goals relative to others. Your goals and the priority of your goals will make your plan holistically unique to you. Your investment portfolio is determined by your unique financial plan and the goals you are aspiring to achieve. Ongoing planning will include maintaining up-to-date information, proactive communication, and continuous analysis of material factors that may impact your financial plan. Aspire Wealth Architects performs ongoing reviews of your financial goals to adjust, if necessary, current aspirational, recommended, and tolerable goal ranges and priorities. We provide ongoing monitoring of your financial plan’s funded status as it relates to its level of confidence. We provide monitoring of all portfolios for variances between actual allocations and those required by the recommended target allocations. Exceptions may be allowed indefinitely when tax consequences, transaction costs, expected cash flows, or input from the client outweigh or override the benefits of rebalancing. Clients also have the option to give Aspire Wealth Architects permission to view and give advice as to invest and reinvest on accounts held with an outside custodian, referred to as “Held Away“ assets. Discretionary authorization will allow us to determine the specific securities and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. For Held Away assets, Aspire Wealth Architects gives advice and clients can grant Limited Power of Attorney for trading purposes only. Aspire Wealth Architects P a g e | 4  Clients may impose restrictions on investing in certain securities or types of securities. Such request must be in writing. Wrap Fee Programs Aspire Wealth Architects does not participate directly or indirectly in any wrap fee programs. Assets Under Management As of December 31, 2025, Aspire Wealth Architects manages $290,263,807 in regulatory assets under management and $16,872,637 in assets under advisement. IRA Rollover Recommendations 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 of interests, so we operate under a special rule that requires us to act in your best interest and not put our interest 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 a fiduciary, we only recommend a rollover when we believe it is in your best interest. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. Aspire Wealth Architects encourages you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. Item 5 – Fees and Compensation Aspire Wealth Architects provides independent, fee-only investment management services. We receive no commissions from trading marketable securities or compensation for financial products and services that we recommend to our clients. The advisory fee is calculated and billed quarterly, in advance, meaning we collect the fee at the beginning of the quarter’s billing period. The advisory fee will be based upon the custodian reported account value as of the last business day of the previous quarter. Fees will be deducted directly from your account(s) based on the Aspire Wealth Architects P a g e | 5  client’s authorization to the qualified custodian holding your assets. The initial billing period’s management fee will be billed at the time of inflow and plan establishment. The initial bill will be prorated for the remaining days in the quarter based on the current value. Aspire Wealth Architects does not generally adjust bills for inflows and outflows from Client accounts during the quarter. However, if a material contribution is received during the quarter the Firm will pro-rate the portion of any significant capital contribution for the remaining days in the quarter at the time of receipt and adoption of the plan. Held-Away assets managed by us are invoiced and paid by check or other agreed upon method, not to include direct debiting of the account itself. In the event of termination of a relationship, any prepaid, unearned fees associated with this Agreement are refunded. Aspire Wealth Architects advisory fees will not exceed 1.25% per annum for advisory relationships with natural persons or non-benefit plan institutional relationships. The fee for investment advisory services is negotiable based on the sole discretion of management. Each client’s effective fee, based on their level of assets, is outlined in their advisory agreement. A typical fee schedule adheres to a tier based schedule, categorized as legacy or individual. All Advisory Fees are exclusive of brokerage commissions, transactions fees and other related costs and expenses which shall typically be incurred by the client as charged by the custodian. Mutual funds, exchange traded funds, and annuities all charge internal management fees and other expenses, which are disclosed in a fund’s or annuities’ prospectus or equivalent disclosure document and are directly deducted from the value of such investment vehicles. Such charges, fees and commissions are exclusive of and in addition to Aspire Wealth Architects’ fee. Aspire Wealth Architects and/or its Advisors do not receive any portion of these commissions, fees and costs and do not have any affiliation with the sponsors or providers of these investment vehicles. Item 6 – Performance-Based Fees and Side-by-Side Management Aspire Wealth Architects does not charge any performance-based fees (fees based on a share of capital gains or on capital appreciation of the assets of a client) or provide side by side management. Item 7 – Types of Clients Aspire Wealth Architects provides portfolio management services to individuals, high net worth individuals, trusts, estates, and business entities. Aspire does not require an account minimum to engage our services. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss INVESTMENT STRATEGIES The investment philosophy of Aspire Wealth Architects is based on the premise that the capital markets are continuously uncertain, and that the duty to our clients is to focus on areas of wealth management that can be controlled and measured. Per our evidence-based methodology, we manage the amount of uncertainty assumed by the client’s investment assets as a function of statistical likelihood of accomplishing goals in their financial plan. Our portfolios are designed to achieve a financial plan’s goals as efficiently as possible with low expenses, a high degree of tax efficiency, and an observable history of measurable data. Our security selection is based on the evidence that a broadly diversified, low-cost index portfolio provides greater outcomes for our clients over long periods of time as compared to actively managed funds. Primary criteria for our investment selections is that they behave as closely as possible to our capital market assumptions in order to provide the highest level of confidence in our clients financial plans. Additional criteria for our investments include low expenses (relative to comparable funds tracking the same benchmark) and tax efficient capabilities. Aspire Wealth Architects P a g e | 6  Our client’s investment portfolios are largely invested in exchange traded funds (ETFs) that are benchmarked to: • A broad-based domestic equity index • A broad-based foreign equity index • A 7-10-year maturity intermediate US government securities index • Money market fund(s) The diversification benefit is apparent in both depth and breadth by holding over 6,000 underlying stocks and 15-20 U.S. Government Treasury securities. If necessary, we offer advice on a number of other investments including: mutual funds, securities traded over-the-counter, corporate debt securities, variable annuities, municipal securities and individual foreign and domestic equities. This is typical of an account with limited investment choices, such as a 401(k), or an existing investment account in which tax considerations would play a critical role in management of these holdings. In certain cases that qualify, we may invest a portion of the client’s portfolio using a direct indexing strategy. This involves purchasing many individual domestic equities which offers greater opportunity for tax loss harvesting while maintaining a low level of tracking error relative to the broad-based domestic equity index fund. This approach is also beneficial to those clients who may have concentrated positions with large, unrealized capital gains. This is an extension of Aspire Wealth Architects investment philosophy. We do not engage in active investment strategies such as market timing or security/sector selection. We discourage our clients from engaging in active management strategies or investing in actively managed investment products. Our security selection is judged on the basis of tracking error relative to the appropriate benchmark, the nature of the underlying assets, the liquidity of the fund, the efficiency of trading the fund, and how the weighting of the index is constructed. Trading in accounts is limited to rebalancing, client deposit or withdrawal requests, capturing tax loss harvesting opportunities, or to change the allocation of the portfolio when initiated by a client’s financial plan. METHODS OF ANALYSIS We utilize Monte Carlo analysis to simulate 1,000 potential market lifetimes using extensive historical market data. The client’s financial plan is subject to these market simulations and the resulting ending portfolio values are then ranked based on ending dollar value. The result is a statistical confidence that is a measure of how many simulated market lifetimes were successful in achieving or exceeded the client’s stated goals. This method recognizes and includes market uncertainty as an influence on the success of a client’s financial plan. An inherent benefit of this analysis is the ability to reasonably asses the amount of financial assets required in order for the financial plan to achieve a level of confidence associated with success. We can also perceive the impact of potential market lifetimes on the client’s financial plan. This can extend to scenarios or potential alternative financial plans for the client. We measure the success of the client’s financial plan using a statistical measure we refer to as the “Confidence” of the plan. We consider the target level of confidence to be within the band of the 75th percentile and the 90th percentile. In other words, this represents that between 750 to 900 of the 1,000 iterations have met or exceeded the client’s goals. Confidence below 75% is referred to as “Below Confidence Zone” and can initiate either a change of allocation or change of financial plan goals. Confidence above 90% is referred to as “Above Confidence Zone” and can initiate either a change of allocation or a change of financial plan goals. Aspire Wealth Architects cannot and does not guarantee to any client that all possible goals at all aspirational spending levels can be achieved. However, we do monitor account values and their impact on the financial plan’s success on a regular basis. We consider this necessary to communicate to the client the current likelihood of success of his or her financial plan. Confidence can change over time as a result of client- initiated plan changes or changes in portfolio values. Aspire Wealth Architects P a g e | 7  INVESTMENT RISK Risk is the measurement of the degree of unpredictability of a given portfolio’s return in any given period. Risk includes the possibility of losing some or all of your original investment. In plan reports, Aspire Wealth Architects references downside risk at the 95th percentile. This means that for any given 12-month period, only 1 out of 20 periods would have a negative return in excess of the calculated 95th percentile downside risk statistic using 1,000 simulations. All investment strategies have an inherent risk component. We recognize the relationship between individual types of investment risk and their influence on return. For example, systematic, or market risk, is a component involved in all investment products and cannot be completely avoided. As discussed, we primarily use ETFs, which are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments following the fund's investment objective. While ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small- cap or speculative companies, uses leverage - borrows money to a significant degree, or concentrates in a particular type of security rather than balancing the fund with different security types. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on ETFs can be reduced by the costs of managing the funds. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. In our model portfolios we include an exchange traded fund with underlying holdings in foreign stock. We recognize the additional risks associated with such an investment including: Foreign currency fluctuations, differing financial accounting standards, possible political and economic instability in some markets and higher portfolio holding expenses compared to domestic equities. We accept these additional risks to achieve the correlation benefits associated with holding a foreign equity component in our client’s portfolios. Mid and Small cap investing generally involves greater risk and volatility as compared to Large cap investing. In a rising interest rate environment, the value of fixed-income securities typically declines. Aspire Wealth Architects does not guarantee that a client will remain in the “Confidence Zone” for the entire lifetime of the financial plan. In fact, we recognize and embrace the dynamic nature of the plan itself and the impact of an uncertain market on that plan. All investment programs carry the risk of loss and there is no guarantee that any investment strategy will meet its objectives. Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Aspire Wealth Architects or the integrity of Aspire Wealth Architects’ management. Aspire Wealth Architects has no disciplinary events that meet this requirement for disclosure. Aspire Wealth Architects P a g e | 8  Item 10 – Other Financial Industry Activities and Affiliations Aspire Wealth Architects and its employees are not registered, nor have an application pending to register, as a broker-dealer or registered representatives of a broker-dealer. Additionally, Aspire Wealth Architects and its employees are not registered, nor have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, insurance agent or as an associated person of any entity engaged in the foregoing fields. Aspire Wealth Architects does not have any arrangements with related persons, nor do we select or recommend other investment advisers for our clients. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The employees of Aspire Wealth Architects have committed to a Code of Ethics that establishes a high standard of integrity and professional ethics in conducting business with the firm, its clients and its business vendors and partners. All Aspire Wealth Architects associates are required to review and sign a formal Code of Ethics adopted to comply with Rule 204(A)-1. Aspire Wealth Architects may recommend or conduct a transaction for a client in a security in which the Firm, its employees, or other clients may have a position. This conflict is addressed in Aspire Wealth Architects’ Code of Ethics. The Code of Ethics provides for a high ethical standard of conduct, compliance with all federal and state securities laws, and policies and procedures for the reporting of certain personal securities transactions on a quarterly basis as well as upon hire and annually for all Aspire Wealth Architects’ professionals and employees. Employee transactions are submitted and reviewed each quarter. These reviews help ensure that the personal trading of employees complies with Aspire Wealth Architects’ Code of Ethics. Due to the nature of Aspire Wealth Architects’ recommended portfolios, we believe it would be very unusual for employees’ personal trades in individual securities to present any ethical conflicts with any ETF portfolio recommendations or trades made on behalf of clients given the huge degree of market diversification represented by our domestic, international, and fixed income ETFs. Aspire Wealth Architects does not recommend to clients any securities in which Aspire Wealth Architects or its related persons have a material financial interest. The primary securities invested in by Aspire Wealth Architects on behalf of its clients are passive ETFs and indexed mutual funds (for accounts with limited investment selections), although portfolio management and advice on prior client positions that stay in a client’s portfolio for some time for tax or other personal client reasons is sometimes required. Aspire Wealth Architects does not typically recommend the purchase of privately-placed individual stocks, bonds, master limited partnerships, hedge funds, or limited liability companies to its clients. A copy of Aspire Wealth Architects’ Code of Ethics is available to advisory clients upon written request to the Compliance Officer at Aspire Wealth Architects’ principal office address or by email request to Caitlin.Cully@AspireWealthArchitects.com. Item 12 – Brokerage Practices Broker Selection Clients select the broker-dealer and custodian for their accounts. We currently recommend the clearing and custody services of Charles Schwab & Co., Inc. (“Schwab”), a registered unaffiliated broker-dealer and member of FINRA/SIPC as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as the custodian/broker, you will decide whether to do so and open an account with Schwab by entering into an account agreement directly with Aspire Wealth Architects P a g e | 9  them; we do not open the account for you. If you do not wish to place your assets with Schwab, then we cannot manage the account. Please Note: You may be able to obtain lower commissions and fees from other brokers, and the value of products, research and services given to the applicant is not a factor in determining the selection of broker- dealers or the reasonableness of their commissions. Schwab Institutional We participate in the institutional advisor program offered by Schwab (“Schwab Institutional”). Schwab provides Aspire Wealth Architects with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Aspire Wealth Architects client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to Aspire Wealth Architects other products and services that benefit the Firm but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab’s products and services that assist Aspire Wealth Architects in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of the Firm’s fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help Aspire Wealth Architects manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to the Firm. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment for Firm personnel. In evaluating whether to recommend or require that client’s custody their assets at Schwab, Aspire Wealth Architects may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Soft Dollar Arrangements Aspire Wealth Architects does not have any soft dollar arrangements or commitments to obtain any research or research related products or services in connection with client securities transactions. Brokerage for Client Referrals Aspire Wealth Architects does not receive client referrals from broker-dealers. Directed Brokerage If a client directs Aspire Wealth Architects to trade the account’s transactions at a particular broker with whom Aspire Wealth Architects does not have a business relationship, this has the potential to result in greater transaction expenses for the account than for other accounts Aspire Wealth Architects manages. The directed Aspire Wealth Architects P a g e | 10  accounts will potentially pay higher commissions and/or receive less favorable trade execution than the non- directed accounts. Aggregation of Orders The aggregation or blocking of client transactions allows an advisor to execute transactions in a more timely, equitable, and efficient manner and seeks to provide, when feasible based on similar time frames of information required to make a trade decision, the same execution price for clients at the same custodian and executing broker. Our firm’s policy is to aggregate client transactions where possible and when advantageous to clients. In these instances, clients participating in any aggregated transactions will receive an average share price and transaction costs will be charged separately based upon each custodian’s commission schedule. In the event transactions for Aspire Wealth Architects, its employees, or principals are aggregated with client transactions and conflicts arise, Aspire Wealth Architects will always defer to the benefit of the client in the transaction. Mutual Fund Share Class Selection As described in Item 8, Investment Strategies, our client portfolios are primarily invested in exchange-traded funds. However, in a client were to be invested in a mutual fund, we would explore the options to move the assets to the least expensive and most favorable share class for the client that is available to the firm. Aspire Wealth Architects periodically reviews the mutual funds held in client accounts to select the most appropriate share classes in light of its duty to obtain best execution. Item 13 – Review of Accounts Review of Client Accounts Aspire Wealth Architects continually monitors the underlying securities within client portfolios. We also monitor all portfolios for variances between actual allocations and those required by the recommended target allocations on an ongoing basis. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. We encourage you to notify us if any changes occur in financial situation, goals or objectives. Financial Plan Review Our team will meet with a client for a full comprehensive review of their plan on an annual basis at a minimum. In addition to the annual review, there will be the need to schedule plan reviews due to planning needs, goal changes, or change in plan confidence. Regular Reports Aspire Wealth Architects clients can view daily, quarterly or on demand reports from Aspire Wealth Architects either directly via the Orion portal, by email, by physical mail, or as needed for client meetings that occur at least once a year. These reports show portfolio holdings, performance, values, and the “Confidence Zone” status of their financial goal objectives, which is a statistical measure of a client’s financial plan status. Item 14 – Client Referrals and Other Compensation Aspire Wealth Architects and its employees do not receive any sales awards or prizes as compensation from third parties. The receipt of such gifts would be a violation of Aspire Wealth Architects’ Code of Ethics. As a matter of policy and practice, Aspire Wealth Architects does not compensate any third-party persons, either individuals or entities, for the referral of advisory clients to the firm. Aspire Wealth Architects P a g e | 11  Item 15 – Custody While Aspire Wealth Architects does not have or take physical custody of client assets, the firm does have custody in that they are able to deduct advisory fees directly from client accounts. All client assets are held and maintained with a qualified custodian, and clients receive statements from the custodian on at least a quarterly basis. The statements include a list of all securities held in the portfolio, their market value as of the last day of the previous month and all trade activity taking place since the last statement. Statements also reflect Aspire Wealth Architects’ advisory fee charges to the custodial account. Method of delivery is determined by the individual client when he or she completes the custodial account application. We urge clients to carefully review such statements and compare the official custodial records to any report that Aspire Wealth Architects provides. If you are not receiving a statement from your custodian, please contact our Compliance Department at Caitlin.Cully@AspireWealthArchitects.com. Item 16 – Investment Discretion Aspire Wealth Architects receives discretionary trading authority from most of its clients at the outset of an advisory relationship to select the security and quantity of securities to be bought or sold within the client’s accounts. Clients execute the Aspire Wealth Architects Investment Advisory Agreement which grants Aspire Wealth Architects a limited power of attorney. Additionally, the custodian requires the client to execute a limited power of attorney (“LPOA”) with the custodian when opening the account. The LPOA grants Aspire Wealth Architects the authority to: trade securities on the client’s behalf in the account, authorize the disbursement of Aspire Wealth Architects’ quarterly investment advisory fee and instruct the custodian to disburse a check from the client’s custodial account to their address of record or, with additional paperwork signed by the client, to a bank account registered in the client’s name. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives and/or the Financial Goal Plan for each client’s account. For Held Away accounts, Aspire Wealth Architects is typically only authorized to give advice to clients in order to invest and reinvest their assets held with another custodian. Aspire Wealth Architects does not have discretion for these accounts. In some cases, the client gives Limited Power of Attorney for Aspire Wealth Architects to have trading authority only. Item 17 – Voting Client Securities As a matter of firm policy, Aspire Wealth Architects does not have the authority to vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients may contact Aspire Wealth Architects for assistance regarding proxy issues at our principal place of business. Item 18 – Financial Information Registered investment advisors are required to provide clients with certain financial information or disclosures about their financial condition. Aspire Wealth Architects has no financial commitment or condition that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. A balance sheet is not required to be provided because Aspire Wealth Architects does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1200 per client six months or more in advance. Aspire Wealth Architects P a g e | 12