ASSET STRATEGY CONSULTANTS LLC

3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS Primary Business Name: ASSET STRATEGY CONSULTANTS LLC CRD Number: 110800 Annual Amendment - All Sections Rev. 10/2021 3/25/2024 1:31:15 PM WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4. Item 1 Identifying Information Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration. A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): ASSET STRATEGY CONSULTANTS LLC B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A. ASSET STRATEGY CONSULTANTS LLC List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business. (2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser. C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is of your legal name or your primary business name: D. (1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-55215 (2) If you report to the SEC as an exempt reporting adviser, your SEC file number: (3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information Filed E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 110800 If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates. (2) If you have additional CRD Numbers, your additional CRD numbers: No Information Filed F. Principal Office and Place of Business (1) Address (do not use a P.O. Box): Number and Street 1: Number and Street 2: SIX NORTH PARK DRIVE SUITE 208 City: State: Country: ZIP+4/Postal Code: HUNT VALLEY Maryland United States 21030 If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying for registration, or are registered, with one or more state securities authorities, https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 1/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] you must list all of your offices in the state or states to which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year. (2) Days of week that you normally conduct business at your principal office and place of business: Monday - Friday Other: Normal business hours at this location: 8AM-5PM (3) Telephone number at this location: 410-528-8282 (4) Facsimile number at this location, if any: 410-528-8305 (5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your most recently completed fiscal year? 1 G. Mailing address, if different from your principal office and place of business address: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: If this address is a private residence, check this box: H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: Yes No I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)? If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social media platforms. J. Chief Compliance Officer (1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below. Name: ALFRED J. MORRISON Other titles, if any: PRINCIPAL Telephone number: 410-528-8282 Facsimile number, if any: 410-528-8305 Number and Street 1: Number and Street 2: SIX NORTH PARK DRIVE SUITE 208 City: HUNT VALLEY State: Maryland Country: United States ZIP+4/Postal Code: 21030 Electronic mail (e-mail) address, if Chief Compliance Officer has one: MORRISON@ASSETSTRATEGYCONSULTANTS.COM (2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any): Name: https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 2/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] IRS Employer Identification Number: K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, you may provide that information here. Name: Titles: KATHY MAKI OFFICE MANAGER Telephone number: 410-528-8282 Facsimile number, if any: 410-528-8305 Number and Street 1: Number and Street 2: SIX NORTH PARK DRIVE SUITE 208 City: HUNT VALLEY State: Maryland Country: United States ZIP+4/Postal Code: 21030 Electronic mail (e-mail) address, if contact person has one: MAKI@ASSETSTRATEGYCONSULTANTS.COM Yes No L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than your principal office and place of business? If "yes," complete Section 1.L. of Schedule D. Yes No M. Are you registered with a foreign financial regulatory authority? Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes," complete Section 1.M. of Schedule D. Yes No N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934? Yes No O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets: $1 billion to less than $10 billion $10 billion to less than $50 billion $50 billion or more For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shown on the balance sheet for your most recent fiscal year end. P. Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier. SECTION 1.B. Other Business Names No Information Filed SECTION 1.F. Other Offices Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 3/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: 3500 MARKET STREET Number and Street 2: SUITE 102 City: State: Country: ZIP+4/Postal Code: CAMP HILL Pennsylvania United States 17011 If this address is a private residence, check this box: Telephone Number: Facsimile Number, if any: 717-602-1100 866-304-7936 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker- dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? 2 Are other business activities conducted at this office location? (check all that apply) (1) Broker-dealer (registered or unregistered) (2) Bank (including a separately identifiable department or division of a bank) (3) Insurance broker or agent (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) (5) Registered municipal advisor (6) Accountant or accounting firm (7) Lawyer or law firm Describe any other investment-related business activities conducted from this office location: SECTION 1.I. Website Addresses List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform. Address of Website/Account on Publicly Available Social Media Platform: https://www.facebook.com/Asset-Strategy-Consultants Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/asset-strategy-consultants/ Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.ASSETSTRATEGYCONSULTANTS.COM SECTION 1.L. Location of Books and Records No Information Filed SECTION 1.M. Registration with Foreign Financial Regulatory Authorities https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 4/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 5/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 2 SEC Registration/Reporting Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only. A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you may affirmatively respond to each of these items. You (the adviser): (1) are a large advisory firm that either: (a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or (b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registered with the SEC; (2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either: (a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or (b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business; Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority. (3) Reserved (4) have your principal office and place of business outside the United States; (5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940; (6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management; (7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a); (8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser; If you check this box, complete Section 2.A.(8) of Schedule D. (9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days; If you check this box, complete Section 2.A.(9) of Schedule D. (10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d); If you check this box, complete Section 2.A.(10) of Schedule D. (11) are an Internet adviser relying on rule 203A-2(e); (12) have received an SEC order exempting you from the prohibition against registration with the SEC; If you check this box, complete Section 2.A.(12) of Schedule D. (13) are no longer eligible to remain registered with the SEC. State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 6/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s). Jurisdictions AL IL NE SC AK IN NV SD AZ IA NH TN AR KS NJ TX CA KY NM UT CO LA NY VT CT ME NC VI DE MD ND VA DC MA OH WA FL MI OK WV GA MN OR WI GU MS PA WY HI MO PR ID MT RI If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31). SECTION 2.A.(8) Related Adviser If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information: Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. You must make both of these representations: I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within 120 days after the date my registration with the SEC becomes effective. I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Act from registering with the SEC. SECTION 2.A.(10) Multi-State Adviser If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations: https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 7/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the state securities authorities in those states. I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as an investment adviser with the state securities authorities of those states. If you are submitting your annual updating amendment, you must make this representation: Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states. SECTION 2.A.(12) SEC Exemptive Order If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information: Application Number: 803- Date of order: https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 8/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 3 Form of Organization If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only. A. How are you organized? Corporation Sole Proprietorship Limited Liability Partnership (LLP) Partnership Limited Liability Company (LLC) Limited Partnership (LP) Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4. B. In what month does your fiscal year end each year? DECEMBER C. Under the laws of what state or country are you organized? State Country Maryland United States If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state or country where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 9/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 4 Successions Yes No A. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g., form of organization or state of incorporation)? If "yes", complete Item 4.B. and Section 4 of Schedule D. B. Date of Succession: (MM/DD/YYYY) If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4. SECTION 4 Successions No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 10/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5. Employees If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs more than one function, you should count that employee in each of your responses to Items 5.B. (1), (2), (3), (4), and (5). A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers. 20 B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)? 16 (2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer? 0 (3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives? 8 (4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you? 0 (5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency? 0 (6) Approximately how many firms or other persons solicit advisory clients on your behalf? 0 In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf. Clients In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recently completed fiscal year? 0 (2) Approximately what percentage of your clients are non-United States persons? 0% D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not include businesses organized as sole proprietorships. The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (1)(d) or (3)(d) below. Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 11/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] clients and assets. If you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable. Type of Client (1) Number of Client(s) (2) Fewer than 5 Clients (3) Amount of Regulatory Assets under Management (a) Individuals (other than high net worth individuals) 5 $ 27,436,361 (b) High net worth individuals 30 $ 139,727,340 (c) Banking or thrift institutions $ (d) Investment companies $ (e) Business development companies $ $ (f) Pooled investment vehicles (other than investment companies and business development companies) 15 $ 828,193,838 (g) Pension and profit sharing plans (but not the plan participants or government pension plans) (h) Charitable organizations 23 $ 1,656,255,198 4 $ 342,657,677 (i) State or municipal government entities (including government pension plans) (j) Other investment advisers $ (k) Insurance companies 1 $ 2,316,021,744 $ (l) Sovereign wealth funds and foreign official institutions (m) Corporations or other businesses not listed above $ 4 $ 96,782,186 (n) Other: INCLUDES DONOR ADVISED & OP RESERVES Compensation Arrangements E. You are compensated for your investment advisory services by (check all that apply): (1) A percentage of assets under your management (2) (3) Hourly charges Subscription fees (for a newsletter or periodical) Fixed fees (other than subscription fees) Commissions Performance-based fees (4) (5) (6) (7) Other (specify): ONE-TIME PROJECTS, WITH NEGOTIATED FEE Item 5 Information About Your Advisory Business - Regulatory Assets Under Management Regulatory Assets Under Management Yes No F. (1) Do you provide continuous and regular supervisory or management services to securities portfolios? (2) If yes, what is the amount of your regulatory assets under management and total number of accounts? U.S. Dollar Amount Total Number of Accounts Discretionary: (a) $ 457,834,306 (d) 10 Non-Discretionary: (b) $ 4,949,240,038 (e) 72 Total: (c) $ 5,407,074,344 (f) 82 Part 1A Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item. (3) What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United States persons? $ 0 Item 5 Information About Your Advisory Business - Advisory Activities https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 12/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Advisory Activities G. What type(s) of advisory services do you provide? Check all that apply. (1) Financial planning services (2) (3) Portfolio management for individuals and/or small businesses Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940) (4) (5) (6) (7) Portfolio management for pooled investment vehicles (other than investment companies) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles) Pension consulting services Selection of other advisers (including private fund managers) Publication of periodicals or newsletters Security ratings or pricing services (8) (9) (10) Market timing services (11) Educational seminars/workshops (12) Other(specify): Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advice in Section 5.G.(3) of Schedule D. H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year? 0 1 - 10 11 - 25 26 - 50 51 - 100 101 - 250 251 - 500 More than 500 If more than 500, how many? (round to the nearest 500) In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes No I. (1) Do you participate in a wrap fee program? (2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as: (a) sponsor to a wrap fee program $ (b) portfolio manager for a wrap fee program? $ (c) sponsor to and portfolio manager for the same wrap fee program? $ If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes No J. (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments? https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 13/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] (2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets under management? K. Separately Managed Account Clients Yes No (1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)? If yes, complete Section 5.K.(1) of Schedule D. (2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section 5.K.(2) of Schedule D. (3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section 5.K.(2) of Schedule D. (4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of this remaining amount of regulatory assets under management? If yes, complete Section 5.K.(3) of Schedule D for each custodian. L. Marketing Activities Yes No (1) Do any of your advertisements include: (a) Performance results? (b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))? (c) Testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii))? (d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))? (e) Third-party ratings? (2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in connection with the use of testimonials, endorsements, or third-party ratings? (3) Do any of your advertisements include hypothetical performance ? (4) Do any of your advertisements include predecessor performance ? SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies No Information Filed SECTION 5.I.(2) Wrap Fee Programs No Information Filed SECTION 5.K.(1) Separately Managed Accounts https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 14/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bank instruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you report internally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relating to this Section. (a) Asset Type Mid-year End of year (i) Exchange-Traded Equity Securities % % (ii) Non Exchange-Traded Equity Securities % % (iii) U.S. Government/Agency Bonds % % (iv) U.S. State and Local Bonds % % (v) Sovereign Bonds % % (vi) Investment Grade Corporate Bonds % % (vii) Non-Investment Grade Corporate Bonds % % (viii) Derivatives % % (ix) Securities Issued by Registered Investment Companies or Business Development Companies % % (x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or % % Business Development Companies) (xi) Cash and Cash Equivalents % % (xii) Other % % Generally describe any assets included in "Other" (b) Asset Type End of year (i) Exchange-Traded Equity Securities 0 % (ii) Non Exchange-Traded Equity Securities 0 % (iii) U.S. Government/Agency Bonds 0 % (iv) U.S. State and Local Bonds 0 % (v) Sovereign Bonds 0 % (vi) Investment Grade Corporate Bonds 0 % (vii) Non-Investment Grade Corporate Bonds 0 % (viii) Derivatives 0 % (ix) Securities Issued by Registered Investment Companies or Business Development Companies 0 % (x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business 0 % Development Companies) https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 15/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] (xi) Cash and Cash Equivalents 0 % (xii) Other 100 % Generally describe any assets included in "Other" MUTUAL FUNDS, SEPARATE ACCOUNTS AND PRIVATE FUNDS ARE MANAGED BY THIRD PARTY ADVISORS. SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2) If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b). (a) In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 with respect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. (i) Mid-Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures (a) Interest Rate Derivative (b) Foreign Exchange Derivative (c) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative $ $ % % % % % % Less than 10% $ $ % % % % % % 10-149% $ $ % % % % % % 150% or more Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (ii) End of Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 16/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] (a) Interest Rate Derivative (b) Foreign Exchange Derivative (c) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative $ $ % % % % % % Less than 10% $ $ % % % % % % 10-149% $ $ % % % % % % 150% or more Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings $ $ Less than 10% $ $ 10-149% $ $ 150% or more Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed Accounts No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 17/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 6 Other Business Activities In this Item, we request information about your firm's other business activities. A. You are actively engaged in business as a (check all that apply): (1) broker-dealer (registered or unregistered) (2) (3) (4) (5) (6) (7) registered representative of a broker-dealer commodity pool operator or commodity trading advisor (whether registered or exempt from registration) futures commission merchant real estate broker, dealer, or agent insurance broker or agent bank (including a separately identifiable department or division of a bank) trust company (8) registered municipal advisor (9) registered security-based swap dealer (10) (11) major security-based swap participant (12) accountant or accounting firm lawyer or law firm (13) (14) other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D. Yes No B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)? (2) If yes, is this other business your primary business? If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name. Yes No (3) Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name. SECTION 6.A. Names of Your Other Businesses No Information Filed SECTION 6.B.(2) Description of Primary Business Describe your primary business (not your investment advisory business): If you engage in that business under a different name, provide that name: SECTION 6.B.(3) Description of Other Products and Services Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. If you engage in that business under a different name, provide that name: https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 18/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 7 Financial Industry Affiliations In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you and your clients. A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and any person that is under common control with you. You have a related person that is a (check all that apply): (1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) other investment adviser (including financial planners) (2) registered municipal advisor (3) (4) registered security-based swap dealer (5) major security-based swap participant (6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration) futures commission merchant banking or thrift institution trust company (7) (8) (9) (10) accountant or accounting firm (11) lawyer or law firm insurance company or agency real estate broker or dealer (12) (13) pension consultant (14) (15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles (16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. SECTION 7.A. Financial Industry Affiliations No Information Filed Item 7 Private Fund Reporting Yes No B. Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 19/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information Filed SECTION 7.B.(2) Private Fund Reporting No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 20/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 8 Participation or Interest in Client Transactions In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the next year. Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates. Proprietary Interest in Client Transactions A. Do you or any related person: Yes No (1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? (2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? (3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? Sales Interest in Client Transactions B. Do you or any related person: Yes No (1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? (2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any related person serves as underwriter or general or managing partner? (3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer)? Investment or Brokerage Discretion C. Do you or any related person have discretionary authority to determine the: Yes No (1) securities to be bought or sold for a client's account? (2) amount of securities to be bought or sold for a client's account? (3) broker or dealer to be used for a purchase or sale of securities for a client's account? (4) commission rates to be paid to a broker or dealer for a client's securities transactions? D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? E. Do you or any related person recommend brokers or dealers to clients? F. If you answer "yes" to E. above, are any of the brokers or dealers related persons? G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions? (2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934? H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals? (2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cash compensation in addition to the employee's regular salary)? I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for client referrals? In your response to Item 8.I., do not include the regular salary you pay to an employee. In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 21/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 9 Custody In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940) assets and about your custodial practices. A. (1) Do you have custody of any advisory clients': Yes No (a) cash or bank accounts? (b) securities? If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person. (2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody: U.S. Dollar Amount Total Number of Clients (a) $ (b) If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2). B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your Yes No advisory clients': (a) cash or bank accounts? (b) securities? You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b). (2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody: U.S. Dollar Amount Total Number of Clients (a) $ (b) C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply: (1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage. (2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools. (3) An independent public accountant conducts an annual surprise examination of client funds and securities. (4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities. If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the private funds you advise in Section 7.B.(1) of Schedule D). D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide Yes No to clients? (1) you act as a qualified custodian (2) your related person(s) act as qualified custodian(s) https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 22/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced: F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients? SECTION 9.C. Independent Public Accountant No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 23/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 10 Control Persons In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filing adviser only. If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C. Yes No A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies? If yes, complete Section 10.A. of Schedule D. B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information Filed SECTION 10.B. Control Person Public Reporting Companies No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 24/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 11 Disclosure Information In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration. Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are. If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in responding to Items 11.A. (1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed. You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11. Yes No Do any of the events below involve you or any of your supervised persons? For "yes" answers to the following questions, complete a Criminal Action DRP: A. In the past ten years, have you or any advisory affiliate: Yes No (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony? (2) been charged with any felony? If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currently pending. B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses? (2) been charged with a misdemeanor listed in Item 11.B.(1)? If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currently pending. For "yes" answers to the following questions, complete a Regulatory Action DRP: C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No (1) found you or any advisory affiliate to have made a false statement or omission? (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes? (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? (4) entered an order against you or any advisory affiliate in connection with investment-related activity? (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity? D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical? (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes? (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 25/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity? (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity? E. Has any self-regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission? (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)? (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities? F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended? G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.? For "yes" answers to the following questions, complete a Civil Judicial Action DRP: H. (1) Has any domestic or foreign court: Yes No (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity? (b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations? (c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority? (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)? https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 26/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Item 12 Small Businesses The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of "small business" or "small organization" under rule 0-7. Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC to state registration. For purposes of this Item 12 only: Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger). Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumed to control the other person. Yes No A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year? If "yes," you do not need to answer Items 12.B. and 12.C. B. Do you: (1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F. (2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? C. Are you: (1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 27/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Schedule A Direct Owners and Executive Officers 1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C to amend this information. 2. Direct Owners and Executive Officers. List below the names of: (a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions; (b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of your capital; (d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of your capital, the trust and each trustee; and (e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and (ii) if managed by elected managers, all elected managers. 3. Do you have any indirect owners to be reported on Schedule B? Yes No 4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executive officer is an individual. 5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75% A - 5% but less than 10% C - 25% but less than 50% E - 75% or more 7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c) Complete each column. DE/FE/I Title or Status Ownership Code Control Person FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name) Date Title or Status Acquired MM/YYYY PR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No. MORRISON, ALFRED, JAMES I 07/1992 C Y N 1361862 MANAGING MEMBER & CHIEF COMPLIANCE OFFICER MEEHAN, JOHN, FRANCIS I 09/2007 A Y N 5427246 MEMBER & DIRECTOR OF RESEARCH HERNANDEZ, ANNE, BENSON I 12/2019 NA N N 2861210 PRINCIPAL & SR. RESEARCH ANALYST DE OWNER 03/2023 D Y N 45-5471707 ASSET STRATEGY CONSULTANTS OF FLORIDA https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 28/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Schedule B Indirect Owners 1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information. 2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below: (a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of a class of a voting security of that corporation; For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in- law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 25% or more of the partnership's capital; (c) in the case of an owner that is a trust, the trust and each trustee; and (d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers. 3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) is reached, no further ownership information need be given. 4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is an individual. 5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6. Ownership codes are: C - 25% but less than 50% E - 75% or more D - 50% but less than 75% F - Other (general partner, trustee, or elected manager) 7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c) Complete each column. No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 29/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Schedule D - Miscellaneous You may use the space below to explain a response to an Item or to provide any other information. https://www.linkedin.com/company/asset-strategy-consultants/ https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 30/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Schedule R No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 31/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] DRP Pages CRIMINAL DISCLOSURE REPORTING PAGE (ADV) No Information Filed REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV) No Information Filed CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV) No Information Filed https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 32/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Part 2 Exemption from brochure delivery requirements for SEC-registered advisers SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a brochure to all of your advisory clients, you do not have to prepare a brochure. Yes No Are you exempt from delivering a brochure to all of your clients under these rules? If no, complete the ADV Part 2 filing below. Amend, retire or file new brochures: Brochure ID Brochure Name Brochure Type(s) 364696 ADV PART 2 BROCHURE 3-24-2023 High net worth individuals, Pension plans/profit sharing plans, Pension consulting, Foundations/charities, Government/municipal, Financial Planning Services https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 33/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Part 3 CRS Type(s) Affiliate Info Retire Investment Adviser Investment Adviser https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 34/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] Execution Pages DOMESTIC INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: ALFRED J. MORRISON Date: MM/DD/YYYY 03/25/2024 Printed Name: ALFRED J. MORRISON Title: PRINCIPAL Adviser CRD Number: 110800 NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. 1. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing. 2. Appointment and Consent: Effect on Partnerships If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of attorney and consent shall be in effect for any action brought against you or any of https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 35/36  3/25/24, 4:50 PM IARD - All Sections [User Name: kmaki3, OrgID: 110800] your former partners. 3. Non-Resident Investment Adviser Undertaking Regarding Books and Records By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and managing agents. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: Date: MM/DD/YYYY Printed Name: Title: Adviser CRD Number: 110800 © 2024 FINRA. All rights reserved. FINRA is a registered trademark of the Financial Industry Regulatory Authority, Inc. Privacy Legal Terms & Conditions https://crd.finra.org/Iad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=&viewChanges=N&FLNG_PK=1843460 36/36 

Six North Park Drive, Suite 208 Hunt Valley, MD 21030 Phone: 410-528-8282 Fax: 410-528-8305 www.assetstrategyconsultants.com March 25, 2025 This brochure provides information about the qualifications and business practices of Asset Strategy Consultants, LLC. Should you have any questions about the contents of this brochure, please contact us at (410) 528-8282 or contact: Alfred J. Morrison Chief Compliance Officer Asset Strategy Consultants 6 North Park Drive, Suite 208 Hunt Valley, MD 21030 morrison@assetstrategyconsultants.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Asset Strategy Consultants, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. References herein to Asset Strategy Consultants, LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training.  Material Changes Annual Update Asset Strategy Consultants, LLC (“ASC”) is providing this information as part of our annual updating amendment which contains material changes from our last annual update. This section discusses only material changes since the last annual update which most recently occurred on March 20, 2024. Material Changes since the Last Update This Brochure dated March 25, 2025 is an updated document prepared according to SEC requirements. Full Brochure Availability This brochure for ASC is available by calling (410) 528-8282 or writing to: Alfred J. Morrison Chief Compliance Officer Asset Strategy Consultants 6 North Park Drive, Suite 208 Hunt Valley, MD 21030 morrison@assetstrategyconsultants.com. 2 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Table of Contents Material Changes Annual Update ........................................................................................................................ Material Changes since the Last Update ............................................................................. Full Brochure Availability ...................................................................................................... 2 2 2 Table of Contents ............................................................................................................................. 3 Advisory Business Firm Description ..................................................................................................................... Types of Advisory Services .................................................................................................. Advisory Services .................................................................................................................. Independent Money Manager Searches............................................................................... Alternative Investments ......................................................................................................... Client Obligations................................................................................................................... Disclosure Statement............................................................................................................. Client Objectives .................................................................................................................... Assets Managed ..................................................................................................................... Investment Discretion............................................................................................................ 4 4 4 4 5 5 6 6 6 6 Fees and Compensation Fee Schedule .......................................................................................................................... Fee Payment ........................................................................................................................... Custodian and Other Fees..................................................................................................... 7 7 8 Performance-Based Fees ................................................................................................................ Types of Clients ............................................................................................................................... 9 9 Methods of Analysis, Investment Strategies and Risk of Loss Asset Allocation ..................................................................................................................... Manager Research ................................................................................................................. Client and Manager Profiles .................................................................................................. Quantitative Screening .......................................................................................................... Qualitative Screening............................................................................................................. Manager Placement on Finalists List ................................................................................... Independent Managers .......................................................................................................... 9 10 10 10 10 11 11 Disciplinary Information .................................................................................................................. 11 12 Other Financial Industry Activities and Affiliations ..................................................................... 13 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... Brokerage Practices ........................................................................................................................ 14 Review of Accounts ......................................................................................................................... 14 Client Referrals and Other Compensation .................................................................................... 15 Custody ............................................................................................................................................. 15 Voting Client Securities................................................................................................................... 15 Financial Information ....................................................................................................................... 16 3 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Advisory Business Firm Description Asset Strategy Consultants is a Securities and Exchange Commission (SEC) registered investment adviser, founded in 1991 in the State of Maryland. At present, the firm has four principal owners: founding partners - Alfred J. Morrison and the Estate of founding partner Charles E. Herget, Jr., who passed away in 2023; and John F. Meehan who was invited to become the third partner in 2007. In December of 2019, Anne B. Hernandez was invited to become partner. Types of Advisory Services Asset Strategy Consultants provides independent investment advisory services to institutional investors - including sponsors of qualified retirement plans (defined benefit and defined contribution plans), endowments, foundations, corporate insurance reserves, trusts, and Private Wealth individuals. Advisory Services The primary investment advisory services provided by ASC are listed below: • Asset allocation analysis • Formulation of investment guidelines, objectives, investment policy statements and spending policy • Fiduciary audit of existing portfolio • Money manager search and selection, traditional and alternative managers • Fee negotiation for money managers, custodians, third-party administration, and other vendors • Portfolio/Plan and retained money managers performance measurement • Portfolio/Plan cost analysis • Commission recapture program search • Fiduciary education • Master custodian search • Third Party Administrator search Independent Money Manager Searches Asset Strategy Consultants will assist clients in the retention of unaffiliated Independent Money Managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Money Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. ASC shall continue to 4 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which ASC shall consider in recommending Independent Money Manager(s) include the client’s designated investment objective(s) and the Independent Money Manager’s management style, performance, risk controls, reputation, financial strength, reporting, pricing, research, and staff continuity. Alternative Investments Asset Strategy Consultants may provide investment advice regarding alternative investment funds. If a client determines to become an alternative product investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of ASC calculating its investment advisory fee. ASC’s clients are under absolutely no obligation to consider or make an investment in an alternative investment fund(s). ASC provides research on alternative investments that are traditionally offered in a partnership structure, such as: • Private Real Estate • Private Natural Resources • Private Equity and Venture Capital • Private Credit • Hedge Funds Please Note: Alternative investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike other liquid investments that a client may maintain, alternative investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that the organization is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Note: In reference to research on hedge fund-of-funds and other alternative fund-of-funds, ASC only conducts due diligence on the hedge fund-of-funds and not the underlying hedge funds that are owned by the hedge fund-of-funds. Please Also Note: Non-Discretionary Service Limitations. Clients that determine to engage ASC on a non-discretionary investment advisory basis must be willing to accept that ASC cannot effect any account transactions without obtaining prior written or verbal consent to any such transaction(s) from the client. Client Obligations In performing its services, ASC shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to 5 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  for the purpose of promptly notify ASC if there is ever any change in their financial situation or investment objectives reviewing/evaluating/revising ASC’s previous recommendations and/or services. Disclosure Statement A copy of ASC’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Client Advisory Agreement. Any client who has not received a copy of ASC’s written Brochure at least 48 hours prior to executing the Client Advisory Agreement shall have five business days subsequent to executing the agreement to terminate ASC’s services without penalty. In addition to ASC’s written disclosure statement, the client shall also receive the Independent Manager(s) written disclosure statement discussing its fees and services. Client Objectives Asset Strategy Consultants shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, ASC shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on ASC’s services. Assets Managed As of December 31, 2024, ASC has $362,241,680 assets under management on a discretionary basis and, at this time, has assets under management on a non- discretionary basis of approximately $4,812,639,467. Investment Discretion ASC provides co-fiduciary and full-fiduciary investment advisory services to our institutional clients. For qualified Retirement Plans, ASC fulfills the role of either co-fiduciary ERISA 3(21) advisor or a full-fiduciary ERISA 3(38) advisor. For our other institutional clients, we provide the option of either a mandate for traditional co-fiduciary service, or the option for ASC to act as the Outsourced Chief Investment Officer (OCIO) for the client. 6 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Fees and Compensation Fee Schedule The client can determine to engage ASC to provide non-discretionary or discretionary institutional and private wealth investment advisory services on a fee-only basis. ASC’s annual investment advisory fee is generally based upon a percentage (%) of the market value of the assets placed under ASC’s management as follows: Traditional Consulting 1st 50 MM 20 bps Next $50 MM (to $100) 15 bps Over $100 MM 12 bps OCIO 1st 100 MM 30 bps Next $150 MM (to $250) 25 bps Next $250 MM (to $500) 20 bps Next $500 MM (to $1B) 15 bps Private Wealth 1st $2 MM & below 125 bps Next $1MM (to $3) 100 bps Next $2 MM (to $5) 85 bps Next $5MM (to $10) 75 bps Over $10 MM - negotiable Asset Strategy Consultants cannot receive any economic benefit from broker-dealers, money managers or other providers of investment services. This includes finders’ fees, 12b-1 fees, commissions, soft-dollar payments, equipment or non-research services. The only source of remuneration is from services provided to ASCs’ clients, thus operating on a basis of total objectivity and avoiding any conflicts of interest. Asset Strategy Consultants will also provide project-based services. This will include one-time consulting projects, under which ASC has not necessarily been retained on a traditional asset-based agreement. The client will be charged an agreed upon project fee. These projects could include portfolio structure analysis, performance analysis, development of Investment Policy Statement, Third Party Administration search and Portfolio/Plan expense analysis. The fee range for project assignments is $2,500 to $25,000, and the standard hourly charge where applicable is $150 to $300, based on the extent and complexity of the required services. The client will receive a written verification of the scope of the project and estimated cost, prior to the initiation of the work. Fee Payment Clients may elect to have ASC’s advisory fees deducted from their custodial account. Both ASC's Client Advisory Agreement and the custodial agreement may authorize the custodian to debit the account for the amount of ASC's investment advisory fee and to directly remit that advisory fee to ASC in compliance with regulatory procedures. In the event that ASC invoices the client directly, payment is due upon receipt of ASC’s invoice. ASC shall deduct fees and/or bill clients quarterly in arrears, based upon the market value of the assets or, on a flat fee basis, the last business day of the previous quarter. 7 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  ASC does not generally require an annual minimum fee for investment advisory services. ASC generally requires a minimum asset level of $10,000,000.00 for Institutional investment advisory clients and $1,000,000 for Private Wealth clients ASC, in its sole discretion, may charge a lesser investment management fee and/or waive or reduce its minimum asset requirement based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). The Client Advisory Agreement between ASC and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Client Advisory Agreement. Upon termination, ASC shall debit the account for the pro-rated portion of the unpaid advanced advisory fee based upon the number of days that services were provided during the billing quarter. Custodian and Other Fees As discussed below, unless the client directs otherwise or an individual client’s circumstances require, ASC shall generally recommend that various custodians, depending upon the clients’ needs and objectives, serve as the custodian for client investment management assets. Clients may also incur fees imposed by third parties, such as custodial, third party administration, and brokerage fees, as well as fees imposed directly at the money manager level. In the case of limited partnership investments, there may be a performance fee imposed by the partnership. Performance-Based Fees 8 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Neither ASC nor any supervised person of ASC accepts performance-based fees. Types of Clients Asset Strategy Consultants provides independent investment advisory services to institutional investors - including sponsors of qualified retirement plans (defined benefit and defined contribution plans), endowments, foundations, corporate insurance reserves, trusts and private wealth. Methods of Analysis, Investment Strategies and Risk of Loss As an investment consulting firm, ASC is not registered to buy or sell individual securities. The firm’s investment consulting focus is on unaffiliated Independent Manager(s). The Independent Manager(s) have day-to-day responsibility for the active discretionary management of the allocated assets. Therefore, our methods of analysis, sources of information and investment strategies are: Asset Allocation Asset Strategy Consultants will provide asset allocation modeling for endowments, foundations, and defined benefit plan clients. Its software program has the ability to utilize an optimization approach based on the Markowitz mean, variance and co- variance methodology as well as also utilize Monte Carlo simulation. We believe this gives our clients the best of both worlds. The process includes an explanation and discussion of the fundamental characteristics of each asset class and sub-class, the basis for expected returns, volatility and correlations with other classes, and modeling to illustrate the impact based on those assumptions. Asset Strategy Consultants utilizes an asset optimization and analysis model designed to provide an understanding of the trade-offs between investment risk and return and to assist the client in determining a set of optimal asset allocation strategies. Model inputs include a set of capital market assumptions, characterizing the expected future market performance of the major asset classes. These performance expectations are based on a five-year outlook for the US and global economies as well as historical asset class performance and include the expected returns and risks for the asset classes and expected correlations between asset classes. Asset mix variables specific to each portfolio are incorporated in the asset allocation model. 9 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  These variables include: • Risk Tolerance • Asset Class Preference • Time Horizon • Expected Return Manager Research Asset Strategy Consultants performs research on a broad range of traditional asset classes as well as research on alternative investment strategies including private real estate, real assets and natural resources, private equity, venture capital, hedge funds and distressed debt and loans. The following summarizes our research process for the strategies we cover. Client and Manager Profiles The first step in our investment manager search process is to develop an accurate description of an “ideal” manager candidate for the client. Finding replacement managers or introducing new asset classes/managers to a portfolio is both an art and a science. We are not simply looking for managers with excellent quantitative results; we are looking for managers that are the right “fit” for the total portfolio. Quantitative Screening Once the Investment Manager Candidate Profile has been created, our analytical team conducts a quantitative evaluation of our independent money manager database to identify candidates that are most compatible with the subject client’s existing or proposed manager structure. Qualitative Screening Qualitative screening further reduces the initial list of candidates that pass the quantitative screens. There are any number of managers with outstanding track records, but when we get to this stage of the search process, we need to really understand how results are achieved. Two managers may have similar records, but one manager may have achieved their returns utilizing more risk/volatility, while the other manager may have achieved the same results with less volatility but better downside protection. This is where we spend the bulk of our time, and further highlights the need to have a true understanding of the profile of the manager candidate as well as the characteristics of the total portfolio. Manager Placement on Finalists List Once investment management firms are identified as potential candidates, ASC interviews 10 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  them personally to ascertain the manager’s interest, and negotiates favorable account size minimums and fee terms on behalf of our client. The finalist candidates are then presented to the client by Asset Strategy Consultants. Our investment analyst team oversees the manager search process. The team conducts the quantitative performance screening necessary to identify managers that have performed well on a risk adjusted basis. The team then conducts qualitative reviews of the managers consisting of meetings and phone conferences to document their processes and determine if the quality of their performance is sustainable. Currently, ASC allocates client investment assets among various Independent Manager(s) and/or private investment funds in accordance with the client’s designated investment objective(s). Independent Managers Asset Strategy Consultants may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated Independent Manager(s) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. ASC shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which ASC shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. In addition to ASC’s written disclosure statement, the client shall also receive the Independent Manager(s) written disclosure statement discussing its fees and services. Disciplinary Information Asset Strategy Consultants has not been the subject of any disciplinary actions. Other Financial Industry Activities and Affiliations • None Code of Ethics, Participation or Interest in 11 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Client Transactions and Personal Trading ASC maintains a policy relative to personal securities transactions. This investment policy is part of ASC’s overall Code of Ethics, which serves to establish a standard of business conduct for all of ASC’s “Access Persons” that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. Neither ASC nor any related person of ASC recommends, buys, or sells for client accounts, securities in which ASC or any related person of ASC has a material financial interest. ASC has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of ASC’s Access Persons. ASC’s securities transaction policy requires that an Access Person of ASC must provide the Chief Compliance Officer or their designee with a written report of the current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or their designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date ASC selects. In accordance with Section 204A of the Investment Advisers Act of 1940, ASC also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by ASC or any person associated with ASC. Brokerage Practices ASC does not have the authority to determine: • Securities to be bought or sold • Amount of securities to be bought or sold • Broker-dealer to be used • Commission rates paid. ASC does not receive referrals from broker/dealers nor does ASC accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). Review of Accounts Client accounts are reviewed at least quarterly, or more frequently as agreed. Reviews of investment accounts typically look at portfolio consistency with regards to a client’s risk 12 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  tolerance, investment time horizon, performance objectives, and asset allocation instructions. Reviews also consist of covering account holdings, transactions, and performance as provided on such statements and other account reports. Client accounts will also be reviewed upon notice of changes in a client's circumstances. ASC may conduct account reviews on another than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request. Accounts are primarily reviewed by the Investment Adviser Representative. In addition, ASC’s compliance program includes the periodic review of a sample of customer accounts for consistency with a client's risk tolerance, investment time horizon, performance objectives, and asset allocation instructions. Clients are provided with monthly or quarterly account statements from the qualified custodian, depending on the activity in the account. Reports include details of client holdings, asset allocation, and other transaction information. Information in these account review reports may be provided by clients or third parties. ASC does not guarantee the accuracy or validity of such information. ASC is not liable in connection with its use of any information provided by a client, a custodian, or other third-party in the account review reports. Client Referrals and Other Compensation If a client is introduced to ASC by either an unaffiliated or an affiliated solicitor, ASC may pay that solicitor a referral fee in accordance with the requirements of Rule 206(4)- 3 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. At present ASC has no existing solicitor, affiliated or unaffiliated, arrangements. Custody Clients will receive monthly statements from a qualified custodian that holds and maintains their assets. ASC does not take physical custody of Client’s funds or securities for the majority of clients. Clients who also receive account review reports from ASC are strongly encouraged to compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of Client accounts. ASC provides other services on behalf of its clients that require disclosure at ADV Part 1, Item 9. In particular, certain clients have signed asset transfer authorizations that permit 13 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  the qualified custodian to rely upon instructions from ASC to transfer client funds to “third parties.” In accordance with the guidance provided in the SEC Staff’s February 21, 2017 Investment Adviser Association No-Action Letter, the affected accounts are not subjected to an annual surprise CPA examination. Voting Client Securities ASC does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients will receive their proxies or other solicitations directly from their custodian. 14 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.  Financial Information • ASC does not receive fees in advance. • ASC has not been the subject of a bankruptcy petition. 15 ASC’s Chief Compliance Officer, Alfred Morrison, is available to address any questions that a client or prospective client may have regarding this Brochure and any corresponding perceived conflict of interest any information or arrangements described herein may create.