Mint Asset Management LLC

ITEM 1 Cover Page DISCLOSURE BROCHURE Part 2A of Form ADV: Firm Brochure An advisory service offered by Mint Asset Management 165 Broadway, 23rd Floor New York, NY 10006 Firm IARD/CRD #: 315568 Tel: 908.777.1717 Mint Asset Management LLC REGISTERED INVESTMENT ADV ISO R www.mintassetmanagement.com B R O C H U R E D A T E D This Disclosure Brochure provides information about the qualifications and business practices of Mint Asset Management LLC, which should be considered before becoming a client. You are welcome to contact us if you have any questions about the contents of this brochure – our contact information is listed to the right. Additional information about Mint Asset Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 20 AUGUST 2026 The information contained in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Administrator. Furthermore, the term “registered investment advisor” is not intended to imply that Mint Asset Management LLC has attained a certain level of skill or training. © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com  DISCLOSURE BROCHURE I MATERIAL CHANGES T E M 2 The following is a summary of changes made to this Disclosure Brochure (Form ADV Part 2A) since the last filing dated July 30, 2026:  Item 17 (Voting Client Securities) was updated to disclose the sub-advisor’s proxy voting authority under the SpaceMint Investment Portfolio strategy. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 2 of 18  DISCLOSURE BROCHURE I TABLE OF CONTENTS T E M 3 ITEM 1 Cover Page 1 ITEM 2 Material Changes 2 ITEM 3 Table of Contents 3 ITEM 4 Advisory Business 4 ITEM 5 Fees & Compensation 6 ITEM 6 Performance-Based Fees & Side-By-Side Management 8 ITEM 7 Types of Clients 8 ITEM 8 Methods of Analysis, Investment Strategies & Risk of Loss 9 ITEM 9 Disciplinary Information 11 ITEM 10 Other Financial Industry Activities & Affiliations 11 ITEM 11 Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 12 ITEM 12 Brokerage Practices 14 ITEM 13 Review of Accounts 15 ITEM 14 Client Referrals & Other Compensation 16 ITEM 15 Custody 17 ITEM 16 Investment Discretion 17 ITEM 17 Voting Client Securities 17 ITEM 18 Financial Information 18 Brochure Supplements Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 3 of 18  DISCLOSURE BROCHURE I ADVISORY BUSINESS T E M 4 Who We Are Mint Asset Management LLC1 (hereinafter referred to as “Mint”, “the Company”, “we”, “us” and “our”), is a Delaware Limited Liability Company, and a registered investment advisor2 since February 2022. The Company is committed to helping you, our client, achieve your financial goals. Mint provides investment advisory services through two divisions, Bryan Perry's Private Clients (“BPPC”) and Asset Wise Analytics (“AWA”), as well as directly at the firm level, with various investment strategies available across all three. While BPPC and AWA do not operate as separate legal entities, each maintains its own investment management strategies, overseen by a dedicated investment advisor representative of Mint who will serve as your primary advisor and relationship manager. Information about Mint’s other divisions is provided in a separate brochure and is available upon request. While different investment management strategies are provided through each separately branded division, back-office support, such as marketing, operations, and compliance, is performed on a company-wide basis. Please Note: We are not a law firm, accounting firm, or insurance agency. None of our services constitute comprehensive financial planning, legal advice, insurance advice, or accounting advice. For these types of inquiries, please consult your own lawyer, accountant, insurance agent, or other qualified professional. Owners The following persons are principal owners and/or control persons of Mint Asset Management, LLC: CRD# Name Title Steven Fishman Managing Member, Chief Compliance Officer 2428781 Jeff Greenberg Publishing, Inc. Member N/A Jeffrey G. Greenberg Chief Marketing Officer 7402940 Mission We strive to help you achieve your monetary goals for today’s needs and for tomorrow’s expectations by providing comprehensive money management solutions. Assets Under Management As of December 31, 2025, Mint’s assets under management on a company-wide basis totaled: Discretionary Accounts ...................................................... $64,543,171 1 Mint Asset Management LLC and its investment adviser representatives are a fiduciaries, as defined within the meaning of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any asset management services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or, (ii) the beneficial owner of an Individual Retirement Account (“IRA”). 2 The term “registered investment advisor” is not intended to imply that Mint Asset Management LLC has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” the United States Securities & Exchange Commission (the “SEC”) – and “Notice Filed” with State Regulatory Agencies that have limited regulatory jurisdiction over our business practices. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 4 of 18  DISCLOSURE BROCHURE What We Do We manage wealth. We provide investment management solutions designed to maximize your wealth, meet your income needs, and minimize risk. We will do our best to keep you focused on where you want to go, offer advice on how to get there, and remind you of the importance of maintaining a disciplined investment approach to realize your investment goals. While Mint offers a broad range of portfolio management services through its two divisions, this Disclosure Brochure is limited to the SpaceMint Investment Portfolio, an investment strategy managed directly by Mint Asset Management at the firm level. SpaceMint Investment Portfolio The SpaceMint Investment Portfolio ("SIP") seeks long-term capital appreciation by investing across the publicly traded global space economy ecosystem. Portfolios are tailored to each client's investment objectives, risk tolerance, and time horizon. The strategy may invest in common equities (domestic and foreign), American Depositary Receipts (ADRs), exchange- traded funds (ETFs), open-end mutual funds, listed investment trusts (including foreign-listed), and commodity-linked ETFs and equity securities, each deriving a material portion of their revenue, operations, or asset value from the exploration, commercialization, and industrialization of space-related industries SIP employs a thematic, long-biased, multi-layer approach across the space economy. Rather than concentrating in a single segment, the strategy is constructed across the full vertical supply chain to reduce single-sector concentration risk while maximizing participation in the long-term growth of the space economy. The investment philosophy is guided by four core principles: 1. Supply Chain Completeness — Seeking value at every layer of the space economy: raw materials → components → systems → launch → communications → data → AI applications. 2. Government Contract Defensibility — Prioritizing companies with long-term, recurring contracts with U.S. and allied government agencies, including NASA, the U.S. Space Force, the Department of Defense, and related intelligence and scientific agencies, which provide revenue visibility and business durability. 3. Competitive Moat Identification — Focusing on companies with defensible competitive advantages, including licensed spectrum assets, proprietary orbital positions, exclusive launch contracts, and patented technologies. 4. Catalyst Awareness — Monitoring and positioning around identifiable near-term and medium-term industry catalysts, including government procurement cycles, scheduled launch milestones, and commercial space station development programs. The global space economy represents a long-term growth opportunity driven by expanding government expenditures, increasing commercial participation, and rising demand for satellite- based connectivity, geospatial intelligence, and space-based infrastructure. SIP is designed to capture growth across multiple layers of the space economy supply chain, spanning raw material extraction and component manufacturing to launch services, satellite communications, data analytics, and artificial intelligence applications. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 5 of 18  DISCLOSURE BROCHURE Betterment, LLC Through a sub-advisory arrangement, we have partnered with Betterment, LLC ("Betterment"), an independent SEC-registered investment advisor, to bring the SIP directly to your account through its Wrap Fee Program on its online platform, providing you with secure, real-time access to your account. As a condition of using SIP on the Betterment Platform, you will be required to electronically sign a separate sub-advisory agreement and brokerage agreement directly with Betterment and its affiliated broker-dealer, Betterment Securities (a member of FINRA and SIPC). Once those agreements are in place, we will set or modify investment allocations and risk levels, enable or disable tools such as tax-loss harvesting and rebalancing, and direct Betterment on which investments to use in your account through its platform. We, not Betterment, will serve as your primary investment adviser and point of contact. Betterment will act as a discretionary sub-advisor on your account, meaning it will handle all trading, but only within the specific guidelines we have established for your account. The fees you pay us include a wrap fee charged by Betterment, which covers its investment management services, account custody, and trade execution costs. Betterment’s fees typically range from 0.12% to 0.25% per annum of your account balance and are billed directly to us. You will not receive a separate bill from Betterment; all charges are bundled into the account management fees you pay us, as outlined in Item 5, "Fees & Compensation." Mint and Betterment are independent of one another and are not affiliated with, sponsored, endorsed, or supervised by each other. Our ongoing role in managing your account under the Betterment Wrap Fee Program is described above. Additional terms and conditions for participation in the Betterment Wrap Fee Program are set forth in a separate Disclosure Brochure (Form ADV Part 2) and Betterment Wrap Fee Brochure available at https://www.betterment.com/legal/form-adv-part-2. Betterment will provide you with a copy of its Disclosure Brochure and Wrap Fee Brochure before or at the time of your enrollment in the program. You should also note that the total cost of the wrap fee, relative to an unbundled fee arrangement, will depend on several factors, including the size of Betterment's wrap fee, the level of trading activity in your account, and the overall value of services received. In general, wrap fee arrangements tend to be more cost-effective for accounts with higher trading activity, while accounts with minimal trading activity may incur higher costs under this structure. Unbundled fee arrangements, in which advisory, custodial, and brokerage services are billed separately, are available from other providers. Information about our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation,” and a further description of our investment strategies appears under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” Please see Item 12, “Brokerage Practices” for more information about the custody and execution services provided by Betterment Securities. I FEES & COMPENSATION T E M 5 Portfolio Management Fee The SIP management fee schedule is as follows: Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 6 of 18  DISCLOSURE BROCHURE Portfolio Value Annual Fee Rate Not to Exceed $0 to $5,000 ............................................ 0% Over $5,000 ............................................ 1.14% The management fee is assessed only on assets exceeding $5,000 and accrues daily based on the account's average daily balance, with billing occurring monthly in arrears. We retain the discretion to negotiate, waive, or reduce the management fee on a client-by-client basis, depending on the size, complexity, and nature of the portfolio managed. Protocols for Portfolio Management. Protocols for Portfolio Management The following protocols establish how we handle our Portfolio Management accounts and what you should expect when it comes to: (i) managing your account; (ii) your bill for investment services; (iii) other fees charged to your account(s). Discretion We will establish discretionary trading authority on all management accounts to execute securities transactions without your prior consent or advice. You may, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, etc.). Billing Your account will be billed monthly in arrears based on the management fee schedule above, with the amount deducted from your account. For managed accounts opened between billing periods, our fee will be prorated from inception through the end of the monthly billing period. Management fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. To determine your management fee, we aggregate the account values of all household members living at the same address. This includes your managed account(s) combined with those of your spouse or partner and any dependent children. Other than the management fees listed in Item 5 (Fees & Compensation), we do not charge you any additional fees. Fee Exclusions Fees paid to us for Portfolio Management services are separate from any fees and expenses charged on mutual funds and ETFs by the Investment Company or by the investment advisor managing the mutual fund or ETF portfolios. These expenses generally include management fees and various fund expenses, such as 12b-1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges, and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds and ETFs is contained in each mutual fund’s or ETF’s prospectus. You are encouraged to carefully read the fund prospectus. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 7 of 18  DISCLOSURE BROCHURE Betterment's wrap fee covers sub-advisory, custody, and most trading and transaction costs. It does not cover the mutual fund and ETF expenses noted above, nor any special service fees charged by Betterment Securities, such as paper statements, physical certificates, or outgoing account transfers (ACAT). Termination of Portfolio Management Services To terminate our portfolio management services, either party (you or us), by written notification to the other party, may terminate the Investment Advisory Agreement (“Agreement”) at any time. Such written notification should include the date the termination will go into effect, along with any final instructions on the account (e.g., liquidate the account, finalize all transactions and/or cease all investment activity). Upon termination of the Agreement, you remain responsible for all portfolio management fees incurred through the termination date. If the Agreement is terminated mid-billing period, the applicable fee will be prorated based on the number of days the account was managed during that month and deducted accordingly, unless you instruct us otherwise. I PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT T E M 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts. I TYPES OF CLIENTS T E M 7 Client types and account types are eligible for SIP: Individual taxable accounts Inherited IRA (Traditional and Roth)   Joint taxable accounts (with rights of survivorship)  Traditional IRA  Roth IRA  SEP IRA (self-employed individuals and small-business owners without employees only)  Solo 401(k)   Trust accounts (Cash Reserve) Client types and account types are not eligible for SIP:  Clients residing outside the United States, including U.S. citizens residing and/or working abroad, for whom the firm cannot provide services for regulatory reasons  Clients under the age of 18; all clients must be at least 18 years of age to consent to account agreements  Custodial or minor accounts are not supported  529 accounts are not available through this advisory relationship  Multi-participant SEP IRAs (employer-sponsored plans with employees) are not supported  SIMPLE IRAs are not supported There is no minimum account size required to participate in this strategy. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 8 of 18  DISCLOSURE BROCHURE I METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS T E M 8 Methods of Analysis In analyzing securities to develop an efficient asset allocation portfolio, we will use a combination of analysis techniques to gather information and to guide us in our management decisions. Fundamental Analysis Fundamental analysis considers: efficiency ratios, growth rates, enterprise value, economic conditions, earnings, cash flow, book value projections, industry outlook, politics (as it relates to investments), historical data, price-earnings ratios, dividends, general level of interest rates, company management, debt ratios, and tax benefits. RISKS – Fundamental analysis places greater value on the long-term financial structure and health of a company, which may have little to no bearing on what is actually happening in the marketplace. Investing in companies with sound financial data/strength and a history of healthy returns can be a good long-term investment to hold in your portfolio; however, such fundamental data does not always correlate to the trading value of the stock on the exchanges. In the short-term, the stock can decrease in value as investors trade in other market sectors. Technical Analysis Technical analysis utilizes current and historical pricing information to help us identify trends in the broader domestic and foreign equity and fixed income markets, and in the underlying assets themselves. This may involve the use of various technical indicators, such as moving averages and trend-lines, among others. RISKS – Technical analysis is charting the historical market data of a stock, taking into consideration current market conditions, to forecast the direction of a future stock price rather than using fundamental tools for evaluating a company’s financial strength. Technical analysis focuses on the price movement of a security trading in the marketplace. This is an ideal tool for short-term investing to identify ideal market entry/exit points. However, no market indicator is absolutely reliable, and your investment portfolio can underperform in the short-term should the market indicators be incorrect. Fundamental analysis provides us with a broad long-term view of a security that begins with determining a company’s value and the strength of its financials while technical analysis is short- term, focusing on the statistics generated by market activity. Investment Strategies As part of the SIP strategy, the following categories of publicly traded securities may be included: Domestic and Foreign Equities SIP may invest in equities spanning the full breadth of the space economy, including launch services and spacecraft manufacturers; satellite communications and connectivity providers; telecommunications companies with satellite infrastructure divisions; optical and laser communications technology providers; geospatial intelligence, Earth observation, and mapping Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 9 of 18  DISCLOSURE BROCHURE companies; cloud infrastructure and orbital computing companies; artificial intelligence and data analytics platforms with government space contracts; aerospace and defense companies with significant space-related operations; space technology component and systems manufacturers; insurance, reinsurance, and risk management companies with space industry practices; companies holding licensed radio frequency spectrum used in satellite operations; and critical materials, rare earth, lithium, and uranium producers supplying the space industry. Exchange-Traded Funds (ETFs) SIP may invest in ETFs across several categories, including pure-play space and space exploration ETFs; aerospace and defense sector ETFs; and commodity ETFs covering space- critical materials such as rare earth and strategic metals, lithium and battery technology, critical and energy transition minerals, and uranium and nuclear energy. Mutual Funds SIP may invest in mutual funds with meaningful exposure to the space economy, including aerospace and defense sector mutual funds, technology sector mutual funds with material space economy exposure, and specialty investment trusts focused on space technology companies." American Depositary Receipts (ADRs) SIP may invest in ADRs, which are U.S. exchange-listed certificates representing shares in foreign companies, providing access to internationally domiciled space economy companies without the complexities of direct foreign market trading. Listed Investment Trusts (Including Foreign-Listed) SIP may invest in listed investment trusts, which are closed-end pooled investment vehicles traded on stock exchanges that hold a portfolio of underlying assets. This includes foreign- listed trusts domiciled outside the United States, particularly those traded on international exchanges such as the London Stock Exchange, providing additional exposure to space economy companies and assets across global markets Other Investment Strategies In addition, we may use long-term purchases, short-term purchases, and trading when managing your assets. Long-term purchases are investments held for at least a year. Short-term purchases are investments sold within a year. Trading involves holding securities for less than 30 days. Please note that SIP accounts on the Betterment platform may experience additional trading due to automatic rebalancing and tax-loss harvesting, which may increase taxable gains and losses. We will use these tools only if they align with your overall tax situation and investment objectives. You should be aware that frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 10 of 18  DISCLOSURE BROCHURE Managing Risk The biggest risk to you is the risk that the value of your investment portfolio will decrease due to moves in the market. This risk is referred to as the market risk factor, also known as variability or volatility risk. Other important risk factors:  Interest Rate Risk – Interest rate risk affects the value of bonds more than stocks. Essentially, when the interest rate on a bond begins to rise, the value (bond price) begins to drop; and vice versa, when interest rates on a bond fall, the bond value rises.  Equity Risk – Equity risk is the risk that the value of your stocks will depreciate due to stock market dynamics causing one to lose money.  Currency Risk – Currency risk is the risk that arises from the change in price of one currency against that of another. Investment values in international securities can be affected by changes in exchange rates.  Foreign Currency Risk - Foreign-listed securities, ADRs, and foreign ETFs are subject to exchange rate fluctuations that may reduce returns when converted to U.S. dollars. Inflation Risk – The reduction of purchasing power of investments over time.   Commodity Risk – Commodity risk refers to the uncertainties of future market values and the size of future income caused by the fluctuation in the prices of commodities (i.e., grains, metals, food, electricity, etc.). The risk factors we have cited here are not intended to be an exhaustive list but are the most common risks your portfolio will encounter. Other risks that we have not defined could be political, over-concentration, and liquidity to name a few. However, notwithstanding these risk factors, the most important thing for you to understand is that regardless of how we analyze securities or the investment strategy and methodology we use to guide us in the management of your investment portfolio, investing in a security involves a risk of loss that you should be willing and prepared to bear. Furthermore, past market performance is no guarantee that you will see equal or better future returns on your investment. I DISCIPLINARY INFORMATION T E M 9 Although Mint Asset Management is not subject to the regulatory oversight of FINRA, the following event is being disclosed to comply with the Company’s duty of full and fair disclosure to its clients. In 1999, the NASD (now FINRA) alleged that Mr. Fishman operated a broker-dealer without an introducing broker-dealer financial operations principal (FINOP) and failed to maintain written supervisory procedures that addressed the receipt of client checks, thus resulting in a violation of SEC net capital rules. Without admitting or denying the allegations, Mr. Fishman consented to the NASD Letter of Acceptance, Waiver, and Consent and agreed to a $5,000 fine, a six-month suspension from associating with any broker-dealer as a general securities principal (i.e., function in a supervisory capacity), and to requalify by examination as a general securities principal. Mr. Fishman has since paid the fine and successfully passed the Series 24 (general securities principal exam). No further action was taken by FINRA and Mr. Fishman has since been operating in good standing with securities regulators. I OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS T E M 1 0 Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 11 of 18  DISCLOSURE BROCHURE Financial Industry Activities One of our supervised persons authors articles, blogs, and other social media content (collectively “newsletters”) in his individual capacity as an independent contractor for Eagle Publishing, an investment news publisher, and Navellier & Associates, Inc., a registered investment advisor (both entities are collectively herein referred to as “Newsletter Publishers”). Newsletters authored by him in this capacity are published regularly, providing subscribers with access to market commentary, various investment strategies, and recommendations, which can have a short-term, medium-term, or long-term focus. The ideas, thoughts, and opinions reflected in the newsletters are his own and do not purport to meet the investment objectives or financial needs of specific individuals or accounts. From time to time, strategies and recommendations discussed in the newsletters will be implemented in our personal accounts and, if deemed suitable, client accounts managed by Mint. This creates a conflict of interest in that our supervised persons will have knowledge of the recommendations before their publication. Therefore, to prevent our supervised persons from misusing and misappropriating any information that they become aware of before the publication of the newsletters, we have adopted a trading policy that, among other things, (i) prohibits supervised persons from front- running client trades and (ii) allows our Chief Compliance Officer to restrict trading in certain investments before and/or following the publication of a newsletter. The investment strategies, performance, and opinions in the newsletters should not be used to evaluate Mint’s investment advisory services, which can be separate and different from the newsletters, and should not be considered indicative of potential future investment performance for any client account managed by Mint. Any questions concerning the newsletters, including any newsletter subscriptions, advertising, or performance claims (calculated solely by the Newsletter Publishers, not Mint), should be referred to the Newsletter Publisher. You are under no obligation to subscribe to these newsletters. Under a written solicitor agreement between Mint and Navellier, this supervised person also receives compensation for marketing Navellier’s investment advisory services to prospective investors derived from Navellier’s other marketing efforts. This supervised person’s marketing and newsletter activities represent a substantial source of his income and involve a substantial amount of his time, which could impact his ability to manage your account effectively and provide objective recommendations. To address these conflicts, client portfolios are regularly reviewed to ensure consistency with the client’s investment objectives and selected strategies. In addition, as part of our fiduciary duty to you, we prioritize your interests, and investment recommendations will only be made to the extent that they are reasonably believed to be in your best interests. Mint, Eagle Publishing, and Navellier are separate legal entities with no common ownership or control. On occasion, we will engage Eagle Publishing to advertise our investment advisory services to their newsletter subscribers. We do not share your personal information with Eagle Publishing or Navellier for marketing or any other purposes. I CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING T E M 1 1 Code of Ethics As a fiduciary, the Company has an affirmative duty to render continuous, unbiased investment advice, and at all times act in your best interest. To maintain this ethical responsibility, we have adopted a Code of Ethics that establishes the fundamental principles of conduct and professionalism expected by all personnel in discharging their duties. This Code is a value-laden Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 12 of 18  DISCLOSURE BROCHURE guide committing such persons to uphold the highest ethical standards, rooted in the most elementary maxim. Our Code of Ethics is designed to deter inappropriate behavior and heighten awareness as to what is right, fair, just and good by promoting:  Honest and ethical conduct.  Full, fair and accurate disclosure.  Compliance with applicable rules and regulations.  Reporting of any violation of the Code.  Accountability. To help you understand our ethical culture and standards, how we control sensitive information and what steps have been taken to prevent personnel from abusing their inside position, a copy of our Code of Ethics is available for review upon request. Client Transactions We have a fiduciary duty to ensure that your welfare is not subordinated to any interests of ours or of our personnel. The following disclosures are internal guidelines we have adopted to assist us in protecting all of our clientele. Participation or Interest It is against our policies for any owners, officers, directors and employees to invest with you or with a group of clients, or to advise you or a group of clients to invest in a private business interest or other non-marketable investment unless prior approval has been granted by our Chief Compliance Officer, and such investment is not in violation of any SEC and/or State rules and regulations. Insider Trading Policy We comply with the Insider Trading and Securities Fraud Enforcement Act of 1988. We do not share any non-public information with anyone who does not need to know and have established internal controls to guard your personal information. Personal Trading Employees of ours are permitted to personally invest their own monies in securities, which may also be, from time to time, recommended to you. Sometimes, such investment purchases are independent of, and not connected in any way to, the investment decisions made on your behalf. However, there may be instances where investment purchases for you may also be made, at or about the same time, in an employee’s account. This practice creates a conflict of interest as our employees may benefit from the sale and purchase of those securities. In these situations, we have implemented the following guidelines in order to ensure our fiduciary integrity: 1. No employee acting as an Investment Advisor Representative (“IAR”), or who has discretion over your account, shall buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment, unless the information is also available to the investing public on reasonable inquiry. No employee of ours shall prefer his or her own interest to that of yours or any other advisory client. 2. Our Chief Compliance Officer, or a designated supervisor, reviews securities holdings for all our access employees on a regular basis. 3. We require that all employees act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 13 of 18  DISCLOSURE BROCHURE 4. Any individual not in observance of the above may be subject to termination. Personal trading activities are monitored by our Chief Compliance Officer to ensure that such activities do not impact upon your security or create conflicts of interest. I BROKERAGE PRACTICES T E M 1 2 Custodial Services When you engage us to manage your assets under the SIP strategy, we will recommend that you separately engage Betterment's sub-advisory services and the custodial and trade execution services of its affiliated broker-dealer, Betterment Securities, as part of your participation in the Betterment Wrap Fee Program. We do not open these accounts for you, although we may assist you in completing the account-opening paperwork required by Betterment and Betterment Securities. If you do not wish to place your assets with Betterment, then we cannot manage your account under our SIP strategy on the Betterment platform. If you agree to engage their services, Betterment Securities will hold your assets in a brokerage account held in your name and buy and sell securities automatically as directed by Betterment according to the SIP strategy used in your account. As described in Item 5, “Fees and Compensation”, the management fee we charge you covers the cost of Betterment’s wrap fee, resulting in no additional costs to you. Our recommendation for you to custody your assets with Betterment Securities has no direct correlation to the services we receive from them and the investment advice we offer you, although we do receive economic benefits for which we do not have to pay through our relationship with Betterment Securities that are typically not available to Betterment Securities retail clients. This creates an incentive for us to recommend Betterment Securities based on the economic benefits we receive rather than on your best interests. To address this conflict, we are committed to acting in your best interest at all times. Our custodian recommendation is made based on the quality, reliability, and value of services provided to you, not on the economic benefits we receive. These economic benefits received from Betterment Securities include the following products and services provided without cost or at a discount:  Receipt of duplicate client statements and confirmations;  Research related products, tools, and consulting services;  Access to a dedicated trading desk;  Access to batch trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to accounts);  The ability to have advisory fees deducted directly from accounts; and  Access to an electronic communications network for order entry and account information. We are not a subsidiary of, or an affiliated entity of, Betterment or Betterment Securities. Securities may have been influenced by The support services we receive from Betterment Securities create an economic benefit to us, and a potential conflict of interest to you; in that, our recommendation to custody your these account(s) with Betterment arrangements/services. However, this is not the case. We have a fiduciary duty to put your Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 14 of 18  DISCLOSURE BROCHURE interests before our own. We have selected Betterment as our custodian/broker-dealer for the SIP strategy based on: 1. Their competitive transaction charges, trading platform, and online services for account administration and operational support. 2. Their general reputation, trading capabilities, investment inventory, their financial strength, and our personal experience in working with their staff. We generally do not permit you to direct us to use a particular custodian/broker-dealer other than Betterment Securities to execute your account transactions. Since we do not recommend, suggest, or make available any custodians or broker-dealers other than Betterment Securities, favorable execution of your account transactions may not always be achieved, and you may pay higher transaction fees. Not all investment advisers require clients to use a particular custodian or broker-dealer. Please note that Betterment offers a cash sweep program to hold uninvested funds in client accounts until they are used for securities transactions or withdrawn. Betterment will receive payments from cash sweep program banks, which creates a conflict of interest. Neither Mint nor its investment advisor representatives receive revenue from this program. Please refer to Betterment's Form ADV Part 2A and Wrap Fee Brochure for details. Aggregating Trade Orders Betterment’s Sub‑Advisory Agreement separately permits Betterment to aggregate orders for multiple clients (including Mint advisers’ clients, other advisors’ clients, Betterment retail accounts, and Betterment employee accounts) and allocate average prices on a pro‑rata basis. There is a risk that other Betterment client segments (e.g., retail, model‑portfolio clients) may receive different or more favorable execution in particular circumstances, though Betterment’s policy is to allocate fairly among all accounts. For additional information about Betterment’s trade practices, please see the Betterment Form ADV Part 2A and Wrap Fee Brochure available at https://www.betterment.com/legal/form-adv-part-2. I REVIEW OF ACCOUNTS T E M 1 3 Portfolio Management Reviews Your investment strategies are monitored on an ongoing basis by our Managing Member, Steven Fishman, and Portfolio Manager, Bryan Perry. At the strategy level, Mint regularly reviews model allocations, screens for exceptions, and evaluates periodic drift reports from Betterment to confirm that trading activity remains consistent with Mint's guidelines. Day-to-day rebalancing and trade execution within those parameters are handled automatically by Betterment's system. Reviews are conducted more frequently in response to significant changes in general economic conditions, market conditions, or tax law. Material changes in your personal or financial situation, or in your investment objectives, will prompt additional review and evaluation to ensure our advice and services remain appropriate. However, it is your responsibility to communicate such changes so that we may make the necessary adjustments to your account. You will receive statements, at least quarterly, from the custodian where your account(s) are held in custody that identify your current investment holdings, the cost of each of those investments, and their current market values. In addition to receiving account statements from the custodian, we may provide you with a monthly or quarterly written report summarizing your Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 15 of 18  DISCLOSURE BROCHURE portfolio. You are encouraged to carefully review and compare your account statements with reports that we may send to you. It is important for you to review these documents for accurate reporting and to determine whether we are meeting your investment expectations. I CLIENT REFERRALS & OTHER COMPENSATION T E M 1 4 Referral Compensation We may directly compensate persons/firms for client referrals, provided those persons are qualified and have entered a solicitation agreement with us. Under such arrangements, if a solicitor referred you to us, you will be provided with complete information on our relationship and the compensation that solicitor will receive should you choose to open an account. In no case will the fee that you pay be higher than it would be if you had dealt directly with us. In addition, we will adhere to each State’s rules and regulations where the Solicitor resides prior to entering into any solicitation agreement with that person/firm. We have engaged a third-party lead-generation, marketing, and appointment-setting service to help identify and connect prospective clients with our firm. This service is not an investment adviser or wealth management firm and does not provide investment advice to prospects. We pay this service a flat monthly fee that is not contingent on the number of leads generated, appointments set, or whether any prospect becomes a client of our firm. If you were referred to us through this service, the fee you pay for our advisory services is not increased as a result of this arrangement, and you will pay the same fee you would have paid had you come to us directly. Other Compensation (Indirect Benefit) The Company receives an indirect economic benefit from Betterment Securities (See “Custodial Services” above under Item 12, “Brokerage Practices” for more detailed information on what these services and products could be.). Retirement Transfer Compensation When it comes to your retirement account, you have four options to consider when transitioning employment from one employer to another, or for when you are seeking full retirement:  Leave the account assets in the former employer’s plan, if permitted;  Transfer the assets to the new employer’s plan, if one is available and transfers are permitted;  Transfer the account assets to an Individual Retirement Account (an “IRA”); or,  Cash out the retirement account assets (There will be tax consequences and/or IRS penalties depending on your age.). Should you approach us to advise you on which option would be the best for your particular situation, we have an economic incentive to recommend you transfer your retirement account to a managed IRA account with us where we would earn a management fee on the assets. This creates a conflict of interest because the advice we render can be subjective and a cost to you. Therefore, if we recommend you transfer your retirement account to an IRA account, you are under no obligation to engage us to manage your assets. You are free to take your account anywhere. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 16 of 18  DISCLOSURE BROCHURE I CUSTODY T E M 1 5 Management Fee Deduction We do not take possession of or maintain custody of your funds or securities but will simply monitor the holdings within your portfolio and trade your account based on your stated investment objectives and guidelines. Physical possession and custody of your funds and/or securities are maintained with a qualified custodian as indicated above in Item 12, “Brokerage Practices.” We do however, meet the definition of custody since you have authorized us to deduct our advisory fees directly from your account. Therefore, to comply with the custody requirements for investment advisers under SEC Rule 206(4)-2, and to protect you as well as to protect our advisory practice, we have implemented the following regulatory safeguards:  Your funds and securities will be maintained with a qualified custodian (Betterment Securities) in a separate account in your name.  Authorization to withdraw our management fees directly from your account will be approved by you prior to engaging in any portfolio management services. In addition, the custodian is required by law to send you, at least quarterly, brokerage statements summarizing the specific investments currently held in your account, the value of your portfolio, and account transactions. You are encouraged to compare and review the financial data contained in our reports and fee invoices to the account statement received from the custodian to verify the accuracy of our reporting and billing. The account custodian does not verify the accuracy of the portfolio management fee calculation. I INVESTMENT DISCRETION T E M 1 6 We provide investment management services on a discretionary basis, with authority shared between Mint and Betterment in different capacities. Mint sets and adjusts the investment strategy, while Betterment executes trades through its automated platform within the parameters set by Mint. By executing an investment advisory agreement, you grant Mint the authority necessary to manage your account, while Betterment's discretionary authority is established through a separate sub-advisory agreement. You retain full ownership rights at all times and may place reasonable written limitations on our discretionary authority, provided they do not adversely affect our ability to properly manage your account. You may revoke Mint's authority by terminating your advisory agreement, or revoke Betterment's authority by closing your Betterment account; however, either action may require the liquidation and transfer of your assets. I VOTING CLIENT SECURITIES T E M 1 7 For accounts managed under the SpaceMint Investment Portfolio Strategy, the client has granted Betterment, under the sub-advisory agreement, the authority to vote proxies on securities held in the account. This delegation is separate from our advisory relationship with the client, and we do not oversee or exercise Betterment’s proxy voting authority. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 17 of 18  DISCLOSURE BROCHURE Part 2) and Betterment Wrap Fee Brochure available Accordingly, we do not vote proxies for securities held in these accounts. Clients should refer to their sub-advisory agreement with Betterment, and to Betterment’s Disclosure Brochure (Form at ADV https://www.betterment.com/legal/form-adv-part-2, for information regarding how proxies are voted and how conflicts of interest are addressed in connection with proxy voting. Clients with questions about how a specific proxy was voted, or who wish to obtain a copy of Betterment’s proxy voting policies and procedures, should contact Betterment. We are glad to assist in this process. You shall maintain exclusive responsibility for all legal proceedings or other types of events pertaining to the assets, including, but not limited to, class-action lawsuits. I FINANCIAL INFORMATION T E M 1 8 We are not required to include financial information in our Disclosure Brochure since we will not take physical custody of client funds or securities or bill client accounts six (6) months or more in advance for more than $1,200. We are not aware of any current financial conditions that are likely to impair our ability to meet our contractual commitments to you. In addition, the Company has not, nor have any of our officers and directors, been the subject of a bankruptcy petition at any time during the past ten years. END OF DISCLOSURE BROCHURE Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 18 of 18  ITEM 1 – COVER PAGE This Brochure Supplement provides information about Bryan A. Perry that is an accompaniment to the Disclosure Brochure for our firm, Mint Asset Management, LLC. You should have received both of these together as a complete disclosure packet. If you did not receive our Disclosure Brochure or if you should have questions about this Brochure Supplement for Mr. Perry, you are welcome to contact us – our contact information is listed to the left. Additional information about Mint Asset Management, LLC and Bryan A. Perry is also available on the SEC’s website at www.adviserinfo.sec.gov. FORM ADV: PART 2B BROCHURE SUPPLEMENT Bryan A. Perry CRD#: 1232078 Year of Birth: 1959 ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Education 1982 – Virginia Tech: Bachelor of Arts in Political Science Licenses FINRA Exams: Series 65 – Uniform Investment Advisor Law Examination Business Background 01/2023 – Present ...... Mint Asset Management LLC Position: Portfolio Manager 03/2015 – Present ...... Eagle Financial Publications Position: Independent Contractor 09/2007 – Present ...... Kona Body Care, LLC Position: Managing Member 07/1999 – Present ...... Alexander Perry Corporation Position: President 01/2016 – 01/2023 ..... Navellier & Associates, Inc. Position: Sr. Director Private Client Services ITEM 3 - DISCIPLINARY INFORMATION Mr. Perry has reportable disclosure events, the details of which can be found on FINRA’s BrokerCheck website at https://brokercheck.finra.org or the SEC IAPD website at www.adviserinfo.sec.gov by performing a name search. CONTACT INFORMATION ITEM 4 - OTHER BUSINESS ACTIVITIES 165 Broadway, 23rd Floor New York, NY 10006 Tel: 908.777.1717 In addition to his role with Mint Asset Management LLC, Mr. Perry is a (i) Managing Member with Kona Body Care, LLC, a personal care products manufacturer; (ii) President with Alexander Perry Corporation, a freelance editor for various media outlets; and (iii) Independent Contractor with Eagle Financial Publications (“EFP”), an investment news publisher, and Navellier & Associates, Inc., a registered investment advisory firm. These businesses provide a substantial source of Mr. Perry’s income and involve a substantial amount of his time. www.mintassetmanagement.com Mr. Perry may spend up to 60% of his time engaged in these other business activities. His responsibility to these other business activities may occasionally create a time management conflict that you should consider. However, Mr. Perry feels his responsibilities relating to these business activities will not distract from his duty to monitor your investment portfolio. For more information regarding Mr. Perry’s outside business activities, the conflicts of interest they present, and how we address them, please see Item 10 (Other Financial Industry Activities & Affiliations) and Item 11 (Code of Ethics, Participation or Interest in Client Transactions & Personal Trading) in our Firm Brochure (Form ADV Part 2A). ITEM 5 - ADDITIONAL COMPENSATION Mr. Perry does not receive any economic benefit, incentives, sales awards, prizes or bonuses that are based on the number or amount of sales, client referrals, or from opening new accounts. ITEM 6 - SUPERVISION Steven Fishman Managing Member & Chief Compliance Officer Tel: 908.777.1717 Mr. Fishman is responsible for the regulatory oversight of our advisory practice – ensuring our business activities are compliant with all federal and state regulations and that we are operating in compliance with our written policies and procedures. BROCHURE SUPPLEMENT DATED © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com 20 AUGUST 2026 Page 1 of 1  ITEM 1 – COVER PAGE This Brochure Supplement provides information about Steven Fishman that is an accompaniment to the Disclosure Brochure for our firm, Mint Asset Management, LLC. You should have received both of these together as a complete disclosure packet. If you did not receive our Disclosure Brochure or if you should have questions about this Brochure Supplement for Mr. Fishman, you are welcome to contact us – our contact information is listed to the left. Additional information about Mint Asset Management, LLC and Steven Fishman is also available on the SEC’s website at www.adviserinfo.sec.gov. FORM ADV: PART 2B BROCHURE SUPPLEMENT Steven Fishman CRD#: 2428781 Year of Birth: 1968 ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Education 1994 – City University of NY – College of Staten Island: Bachelor of Science in Finance Licenses FINRA Exams: Series 65 – Uniform Investment Advisor Law Examination Business Background 03/2020 – Present ...... Mint Asset Management LLC Position: Managing Member & Chief Compliance Officer 01/2012 – Present ...... Savvy Investor LLC Position: Partner 11/2011 – Present ...... Green Earth Merchants LLC Position: General Partner 04/2008 – Present ...... Danimax LLC Position: General Partner ITEM 3 - DISCIPLINARY INFORMATION Mr. Fishman has not been the subject of any legal or disciplinary action by any court, regulatory agency, or self-regulatory organization in the past ten years. ITEM 4 - OTHER BUSINESS ACTIVITIES CONTACT INFORMATION 165 Broadway, 23rd Floor New York, NY 10006 In addition to his role with Mint Asset Management LLC, Mr. Fishman is a (i) Partner with Savvy Investor LLC, a marketing consulting firm for publishing companies and financial institutions; (ii) General Partner with Green Earth Merchants LLC, a credit card processing company; and (iii) General Partner with Danimax LLC, the holding company for Savvy Investor LLC and Green Earth Merchants LLC. These businesses provide a substantial source of Mr. Fishman’s income and involve a substantial amount of his time. Tel: 908.777.1717 Potential Time Management Conflict www.mintassetmanagement.com Mr. Fishman may spend approximately 25 hours per month engaged in these other business activities. His responsibility to these other business activities may occasionally create a time management conflict that you should consider. However, Mr. Fishman feels his responsibilities relating to these business activities will not distract from his duty to monitor your investment portfolio. ITEM 5 - ADDITIONAL COMPENSATION Mr. Fishman does not receive any economic benefit, incentives, sales awards, prizes or bonuses that are based on the number or amount of sales, client referrals, or from opening new accounts. ITEM 6 - SUPERVISION Steven Fishman Managing Member & Chief Compliance Officer Tel: 908.777.1717 Mr. Fishman is responsible for the regulatory oversight of our advisory practice – ensuring our business activities are compliant with all federal and state regulations and that we are operating in compliance with our written policies and procedures. His other duties include, but are not limited to, meeting periodically with all employees to impress upon them their fundamental principles of conduct and professionalism in following our Code of Ethics and confirming they are acting in our clients’ best interests in discharging their duties. BROCHURE SUPPLEMENT DATED 20 AUGUST 2026 © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com Page 1 of 1