Mint Asset Management LLC

ITEM 1 – COVER PAGE FORM ADV PART 2A DISCLOSURE BROCHURE JULY 30, 2026 a division of Registered Investment Advisor Firm CRD# 315568 Branch Office 620 Allendale Road, Suite 125 King of Prussia, PA 19406 Tel: (610) 955-5128 Corporate office 165 Broadway, 23rd Floor New York, NY 10006 This Disclosure Brochure provides information about the qualifications and business practices of Akatsuki Capital, a division of Mint Asset Management, LLC. If you have any questions about the contents of this Disclosure Brochure, please contact us; 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. Tel: (908) 777-1717 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. www.mintassetmanagement.com  FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 2 – MATERIAL CHANGES This Disclosure Brochure has been reviewed and is current as of the date indicated on the cover. Akatsuki Capital Page 2 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 3 – TABLE OF CONTENTS Item 2 – Material Changes ............................................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................................... 4 Item 5 – Fees & Compensation .................................................................................................................................... 5 Item 6 – Performance-Based Fees & Side-By-Side Management ............................................................................... 6 Item 7 – Types of Clients .............................................................................................................................................. 6 Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss ........................................................................... 7 Item 9– Disciplinary Information.................................................................................................................................... 8 Item 10– Other Financial Industry Activities & Affiliations ............................................................................................. 8 Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .................................... 9 Item 12 – Brokerage Practices.................................................................................................................................... 10 Item 13 – Review of Accounts..................................................................................................................................... 11 Item 14 – Client Referrals & Other Compensation ..................................................................................................... 11 Item 15 – Custody ....................................................................................................................................................... 12 Item 16 – Investment Discretion ................................................................................................................................. 12 Item 17 – Voting Client Securities ............................................................................................................................... 12 Item 18 – Financial Information................................................................................................................................... 13 Form ADV Part 2B (Brochure Supplement) Akatsuki Capital Page 3 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 4 – ADVISORY BUSINESS 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 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, each of which offers different investment management strategies. Although neither division is a separate legal entity, their investment management strategies are managed autonomously by an investment advisor representative of Mint, who will serve as your primary advisor and relationship manager. This Brochure provides information about the advisory services offered by Akatsuki Capital, a division of Mint. Information about Mint’s other division 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. The following person owns and controls the Firm: Name Title CRD# 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 Non-Discretionary Accounts: $0 What We Do The Akatsuki Capital division of Mint offers both discretionary and non-discretionary investment management through privately managed separate accounts. Our current offerings include four strategies: equity market-neutral, low-volatility equity hedge, multi- asset dividend and income, and leveraged absolute return. Each strategy is designed to pursue distinct risk and return objectives across different market environments using a mix of asset classes, including but not limited to equity (“stock”) positions, fixed income securities (bonds, U.S. Treasuries, and mortgage backed securities), options, investment company (“mutual fund”) products, exchange traded funds (“ETFs”), Real Estate Investment Trusts (“REITs”), cash, cash equivalents, other securities and investment instruments, Please see Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for further information regarding our investment strategies. We tailor our advisory services to your specific objectives, risk tolerances, and investment horizons, with a focus on disciplined portfolio construction, active risk management, and transparency. If you grant us discretionary authority, we make investment decisions, including the selection of securities and the timing and size of transactions, without obtaining your prior approval for each transaction. You may, at any time, impose reasonable restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, etc.). If we have non-discretionary authority, we provide investment recommendations but do not execute transactions without your prior approval. Clients in non-discretionary arrangements direct the execution of all transactions and bear responsibility for the investment decisions made in their accounts. As a result, non-discretionary clients may experience different investment outcomes than discretionary clients pursuing the same strategy, due to differences in timing, execution, or the client's decision to accept, modify, or reject recommendations. 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” with the United States Securities & Exchange Commission (the “SEC”) – and “Notice Filed” with State Regulatory Agencies that have limited regulatory jurisdiction over our business practices. Akatsuki Capital Page 4 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE The basis on which we manage your account - discretionary or non-discretionary - is set forth in your Investment Advisory Agreement. ITEM 5 – FEES & COMPENSATION Investment management services are offered on an asset-based, tiered fee schedule. The management fee is billed in arrears and is calculated using the market value of your account - including investments/securities, cash, and cash equivalents - as reported by the account’s custodian on the last business day of the month, multiplied by one-twelfth of the corresponding annual percentage rate (e.g., 1.00% ÷ 12 = 0.0833%). Our fee schedule for managed accounts is as follows: Account Value Annual Fee Rate Not to Exceed 2.50% Up to $500,000 1.50% 1.25% 1.00% $500,001 - $750,000 .............................................. $750,001 - $1,000,000 .............................................. Over $1,000,000 .............................................. We charge a one-time account setup fee between $250 and $750 to establish an investment profile and plan that assesses investment goals and risks. This fee also includes the time and resources needed to set up the client’s account(s) with the custodian. The amount depends on the complexity of the client's investment style, the number of accounts, the assets to be managed, and other relevant factors. For managed accounts opened between billing periods, our management fee will be prorated from inception through the end of the monthly billing period. Our management fees will be withdrawn from your account monthly by the custodian following our instructions. These fees will be taken first from any money market funds or cash balances. If these assets are insufficient to cover the fees, a portion of the account assets will be liquidated to cover the fees. Unless otherwise agreed to in writing, we will combine the account values of family members living in the same household to determine the applicable management fee. For example, we will combine the value of your managed account(s) with the values of managed accounts held by your spouse or partner and dependent children. Combining account values may increase the total managed assets, which could result in a reduced management fee based on the breakpoints in our tiered fee schedule. In certain circumstances, we charge performance-based fees in addition to, or in lieu of, our management fees. Performance- based fees are charged only to clients who qualify as "qualified clients" as defined under Rule 205-3 of the Investment Advisers Act of 1940. Please see Item 7 – Types of Clients for a general definition of “qualified client.” Performance-based compensation is calculated as a percentage (generally 15%) of net profits, net capital appreciation, or returns exceeding a specified benchmark or hurdle rate. The specific terms, including the applicable percentage, measurement period, hurdle rate, high-water mark provisions, and any clawback or loss carry-forward mechanisms, are negotiated on a client-by-client basis and set forth in each client's Investment Advisory Agreement. The Performance Fee shall be calculated and assessed annually at the end of each calendar year (the “Performance Period”) and shall be based solely on net realized and unrealized capital appreciation of the client’s account’s assets above a pre-agreed benchmark or hurdle rate (the “Hurdle Rate”), as specified in the Investment Management Agreement. The Performance Fee shall apply only to the portion of net gains exceeding the Hurdle Rate and shall not be charged in any Performance Period in which the account’s net return fails to exceed the Hurdle Rate. A high-water mark (“High-Water Mark”) shall apply to the Performance Fee. The High-Water Mark shall equal the highest net asset value of the client’s account at the end of any prior Performance Period for which a Performance Fee was assessed. No Performance Fee shall be payable in any Performance Period unless the account’s net asset value at the end of such period exceeds both the Hurdle Rate and the High-Water Mark. The High-Water Mark shall be adjusted to account for material client contributions to or withdrawals from the account during the Performance Period. At our discretion, we reserve the right to negotiate, waive, or reduce the initial account setup fee, management fee, and/or performance-based fee on a per-client basis, depending on the size and complexity of the managed account. Pre-existing advisory clients are subject to our minimum account requirements and advisory fee arrangements in effect at the time they entered into the advisory relationship. Therefore, some clients may be subject to a more favorable fee schedule than the one shown above. Akatsuki Capital Page 5 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE Cash Balances Cash is considered to be an asset class and is included in our fee calculations. At times, our fees will exceed the money market yield on the cash balance of your account. When this happens, the advisory fee will be higher than the interest a client will earn on their cash balance or the return on money market funds. Deposits & Withdrawals For existing management accounts, pro-rated adjustments will not be made for deposits and withdrawals between billing cycles. Fee Exclusions The fees for our account management services do not include any charges imposed by the custodian holding your account. This includes but is not limited to: (i) any exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges such as postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials, and mutual fund short-term redemption fees; and (iv) brokerage and execution costs related to securities in your managed account. Other fees may be charged to your account that are not related to our management services. In addition to our management fee, you will also pay all mutual fund and ETF charges that are directly imposed by the mutual funds and ETFs. These expenses include management fees, and, if applicable, 12b-1 fees, redemption fees, contingent deferred sales charges, and other related fees. A detailed explanation of these costs imposed by the mutual funds and ETFs can be found in each mutual fund or ETF prospectus. You are encouraged to review these prospectuses carefully. Termination of Account Management Services You may terminate your Investment Advisory Agreement with us within 5 business days of signing the agreement without penalty. After that, either party may cancel the agreement at any time by providing written notice to the other party. This notice should specify the date when the termination will take effect and may include final instructions for the account, such as liquidate the account, complete all transactions, or stop all investment activity. If termination does not occur at the end of a month, you will be charged a prorated amount based on the number of days the account was managed during that period. Other than the management and performance-based fees listed in Item 5 - Fees & Compensation, we do not charge you any additional fees. ITEM 6 – PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT As disclosed in Item 5 – Fees and Compensation above, the Firm will earn performance-based compensation (i.e., performance- based fees) from client accounts under the Firm’s management. All performance-based compensation arrangements will be structured in compliance with the applicable requirements under state and federal rules and regulations, including the requirement under SEC Rule 205-3 to only enter into such arrangements with “qualified clients” (defined in Item 7 – Types of Clients below). The terms of performance-based compensation (if any) are provided in the Investment Management Agreement. When entering into a performance-based compensation arrangement, you should understand the following:  Performance-based compensation may create an incentive for the Firm to make investments that involve more risk and are more speculative than would be the case in the absence of performance-based compensation.  Performance-based compensation may create an incentive for the Firm to overvalue investments that lack a market quotation.  Because the Firm will serve as the investment adviser to client accounts with different fee structures, the potential for conflicts of interest may arise. Such conflicts of interest include the incentive for the Firm and its supervised persons to favor the accounts for which the Firm receives performance-based compensation. To mitigate potential conflicts of interest, the Firm has created policies and procedures designed to promote ethical conduct by addressing client trading, aggregation, trade allocation, best execution, and the requirement to fairly value securities that do not have a readily ascertainable value. In addition, the Firm’s management team reviews accounts on an ongoing basis to ensure that investments are suitable and that accounts are being managed appropriately in light of the relevant investment objectives and risk tolerance. ITEM 7 – TYPES OF CLIENTS We primarily offer financial services to individuals, high-net-worth individuals, and their families. We may also advise foundations, charitable organizations, corporations, small businesses, trusts, guardianships, estates, or other entities we choose to advise. We generally require a minimum initial investment of $100,000 to open or maintain a managed account with us. We retain the right to waive or reduce this minimum if we feel circumstances warrant. Because the Firm will earn performance-based compensation, clients are required to complete a suitability questionnaire to determine whether the investor is a qualified client. Akatsuki Capital Page 6 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE A “qualified client” is defined in Rule 205-3 under the Investment Advisers Act of 1940 and generally includes:    a natural person or institution that immediately after entering into an investment advisory contract has at least $1.1million under the management of the investment adviser; or has a net worth (excluding primary residence and certain debt secured by the property) of more than $2.2 million at the time the contract is entered into; a natural person with $5 million in investments (i.e., qualified purchaser); and an officer or director of the fund manager, or an employee who participates in the investment activities of an investment adviser. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS When selecting investments for your account, we use several methods of analysis, including: Methods of Analysis 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, overall interest rate levels, company management, debt ratios, and tax benefits. Fundamental analysis focuses on the long-term financial structure and overall health of a company, which may have limited relevance to current market conditions. Investing in companies with robust financial data and a history of consistent returns can be a prudent long-term strategy for portfolio inclusion; however, such fundamental indicators do not necessarily correspond to the stock's market trading value. In the short term, the stock's value may decline. Additionally, the risks of fundamental analysis may include incomplete or inaccurate information, unexpected market reactions, and the inability to predict future events or changes in market sentiment accurately. Economic, political, or industry shifts can also undermine the validity of fundamental assessments. Fundamental analysis offers a comprehensive long-term perspective on a security, starting with the assessment of a company’s value and the robustness of its financial position. Technical Analysis Technical analysis uses current and historical price data to help us identify trends in the broader domestic and foreign equity and fixed-income markets, as well as in the underlying assets themselves. This may involve using various technical indicators, such as moving averages and trendlines. Technical analysis involves charting a stock’s historical market data, taking into account current market conditions, to forecast the direction of a future stock price rather than using fundamental tools to evaluate 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 optimal market entry and exit points. However, no market indicator is absolutely reliable, and your investment portfolio can underperform in the short term if market indicators are incorrect. Investment Strategies The Firm currently offers four investment strategies: 1. Equity Market-Neutral Strategy - This strategy seeks to generate returns that are largely independent of broad equity market movements by holding offsetting long and short equity positions. The strategy is designed to maintain low net market exposure; however, there is no guarantee that market neutrality will be achieved at all times. 2. Low-Volatility Equity Hedge Strategy - This strategy invests primarily in equity securities selected with the objective of maintaining lower price volatility relative to broad market indices, while incorporating hedging techniques to seek to reduce downside risk. Lower volatility relative to the market is an objective, not a guaranteed outcome. 3. Multi-Asset Dividend and Income Strategy - This strategy invests across multiple asset classes, including equity and fixed income securities, with an emphasis on dividend-paying and income-generating instruments. The strategy seeks current income and, secondarily, capital appreciation. Income generation is not guaranteed, and the value of investments may decline. 4. Leveraged Absolute Return Strategy - This strategy employs leverage and may use derivatives in pursuit of positive returns across varying market environments. The use of leverage magnifies both potential gains and potential losses and involves significant risk of loss, including the possible loss of more than the amount invested. Other Investment Strategies In addition, we may use long-term purchases, short-term purchases, trading, short sales, margin transactions, and options when managing your assets. Long-term purchases are investments held at least a year.   Short-term purchases are investments sold within a year. Akatsuki Capital Page 7 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE  Trading involves holding securities for less than 30 days. You should be aware that frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes.  Short sales involve selling securities that the investor does not own and delivering the borrowed securities to the purchaser, with an obligation to replace the borrowed securities at a later date. The securities are borrowed from a third party, typically a broker-dealer. If the price of the securities declines between the date of sale and the date of repurchase, the investor will profit to the extent that the decline in price exceeds the investor’s transaction and borrowing expenses. The investor will incur a loss if the price of the securities rises.  Margin transactions involve the use of current holdings as collateral to buy additional securities.  Options are contracts that give the owner the right to buy or sell a security at a specific price and period of time. When an investor sells (writes) an option, the investor must deliver to the buyer a specified number of shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a particular time) in exchange for writing the option. When buying an option, the investor has the right to purchase or sell a security at a specified price until the option's expiration date. Managing Risks The biggest risk to you is the chance that your account’s value will decline due to market movements. This risk is known as market risk, also called variability or volatility risk. Other significant risk factors generally include:  Interest Rate Risk – Interest rate risk impacts bond values more than stocks. Essentially, when interest rates rise, bond prices fall; when interest rates decline, bond prices increase.  Equity Risk – Equity risk is the chance that your stocks will decrease in value due to stock market fluctuations, potentially leading to a loss of money.  Currency Risk – Currency risk is the risk that results from fluctuations in the value of one currency compared to another. Investment values in international securities can be influenced by changes in exchange rates. Inflation Risk – The decrease in the purchasing power of investments over time.   Commodity Risk – Commodity risk refers to the uncertainties of future market values and the potential variation in future   income caused by fluctuations in commodity prices (such as grains, metals, food, electricity, etc.). Liquidity Risk – A financial risk where a company is unable to meet short-term financial obligations without selling either hard assets or finding another way to reduce the discrepancy between cash flow and debt obligations. Foreign Securities Risk - Foreign securities come with risks not typically found in domestic investments, such as currency fluctuations, political instability, economic turmoil, trade restrictions, and weaker regulation. They may also face limited market liquidity, less transparency, and greater volatility.  Margin Risk - Margin transactions may result in losses greater than the amount deposited in the investor’s margin account. This may require additional funds to be deposited or securities to be sold at a disadvantage to the investor.  Options Risk - Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. The risk factors identified herein are not intended to be an exhaustive list but rather the most prevalent risks that your account may encounter. Additional risks not explicitly outlined may include political instability, over-concentration, and liquidity concerns, among others. Nevertheless, notwithstanding these risk factors, it is imperative that you comprehend that, regardless of the analytical methods or investment strategies employed in managing your account, investing in securities involves a risk of loss that you should be prepared to bear. Furthermore, it is important to note that past market performance does not guarantee similar or superior future returns on your investments. ITEM 9– DISCIPLINARY INFORMATION 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 STEVEN Fishman, MINT’S MANAGING MEMBER, 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., FUNCTIONING 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. ITEM 10– OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS One of Mint’s 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 Akatsuki Capital Page 8 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE 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. Because a separate division of Mint employs this individual, we do not believe that his role as a solicitor creates a conflict of interest with clients under the Akatsuki Capital division of Mint. 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. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING Code of Ethics As a fiduciary, we have an affirmative duty to provide continuous, unbiased investment advice and always act in your best interest. To uphold this ethical responsibility, we have adopted a Code of Ethics that sets forth the fundamental principles of conduct and professionalism expected from all personnel in performing their duties. This Code of Ethics serves as a value-driven guide that obligates individuals to uphold the highest ethical standards, based on the simplest maxim. Our Code of Ethics is designed to discourage inappropriate behavior and increase awareness of 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 of Ethics; and accountability. To help you understand our ethical culture and standards, how we manage sensitive information, and what steps have been taken to prevent personnel from abusing their positions with the Firm, 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. The following disclosures are internal guidelines we have adopted to help us protect all our clients. 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 pre- approved by our Chief Compliance Officer and such investment is not in violation of any federal or state securities laws. Insider Trading Policy We have implemented an Insider Trading Policy to prevent misuse of material non-public information by our Firm and employees, whether for client or personal gain. Employees must not disclose or act on such information, as defined by securities laws and our policy. This applies to all employees, both in professional and personal activities. Personal Trading Employees 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, as 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: Akatsuki Capital Page 9 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE  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 shall prefer his or her own interest to that of yours or any other advisory client.  Our Chief Compliance Officer, or a designated supervisor, reviews securities holdings for all our access employees on a regular basis.  We require that all employees act in accordance with all applicable Federal and State regulations governing registered investment advisory practices.  Bunched orders (See “Aggregating Trade Orders” below under Item 12, “Brokerage Practices”) may include employee accounts. In such cases, all client and employee accounts will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner.  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 your security or create conflicts of interest. ITEM 12 – BROKERAGE PRACTICES Custodial Services We typically require that you establish your account with Charles Schwab & Company, Inc. (“Schwab”), a registered broker- dealer (member FINRA/SIPC) and qualified custodian. Schwab offers us services that include custody of securities, trade execution, clearance, and settlement of transactions. Our recommendation that you custody your assets with Schwab is not directly correlated with the services we receive or the investment advice we offer you, although we do receive economic benefits, which we do not have to pay for, through our relationship with Schwab that are typically not available to retail clients. This creates an incentive for us to recommend Schwab based on the economic benefits we receive rather than on your interest in receiving most favorable execution. These economic benefits 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;   Access to an electronic communications network for order entry and account information; and,  Access to mutual funds and ETFs with no transaction fees and to certain institutional money managers. The advisory support services we receive from Schwab provide an economic benefit to us and could create a potential conflict of interest for you because our recommendation to custody your account with Schwab might be influenced by these arrangements or services. However, this is not the case. We have a fiduciary duty to prioritize your interests above our own. We chose Schwab as our qualified custodian based on: 1. Their competitive transaction fees, trading platform, and online services for account management and operational support. 2. Their overall reputation, trading capabilities, investment holdings, financial strength, and our personal experience working with their back-office staff. Since we do not recommend or suggest custodians or broker-dealers other than Schwab, best execution may not always be achieved, which could cost you more money. Therefore, you are not required to accept our recommendation to use Schwab as your custodian or broker-dealer. Not all investment advisors direct clients to specific custodians or broker-dealers. If you choose to direct us to use another custodian or broker-dealer, we may not be able to provide you with full institutional services, and such services might cost you more in transaction fees. We are not a subsidiary or affiliated entity of Schwab. We have sole responsibility for the investment advice we provide, and our advisory services are given separately and independently from Schwab. Aggregating Trade Orders Our objective in order execution is to act fairly and impartially and to take all reasonable steps to obtain the best possible results (known as “best execution”) for our clients. Therefore, we typically bunch (aggregate) orders for a block trade when: (i) the bunching of orders is done for the purpose of achieving best execution; and (ii) no client is systematically advantaged or disadvantaged by bunching the orders. Client accounts participating in the bunched order will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner. Akatsuki Capital Page 10 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE In consideration of these objectives, we will take into account the unique execution factors of the buy/sell order before bunching accounts for a block trade. A few of those factors are:  Security Trading Volume – Bunching orders in a block trade can secure price parity and continuity for our clients during heavy trading activity.   Number of Clients – The fewer the number of client accounts involved in the bunched order, the less likely it may be to yield better pricing or order execution; it may be more advantageous to perform an individual market order for each client. In addition, preparing individual market orders for the small number of accounts involved may be quicker to complete than preparing a bunch order. Financial Instruments – The type of security involved, as well as the complexity of the order, can affect our ability to achieve best execution. ITEM 13 – REVIEW OF ACCOUNTS Account Management Reviews Your investment strategies and investments are monitored and reviewed on an ongoing basis by Al Graves, Portfolio Manager. The general economy, market conditions, and/or changes in tax law can trigger more frequent reviews. Cash needs will be adjusted as necessary. Material changes in your personal/financial situation and/or investment objectives will require additional review and evaluation for us to properly advise you on revisions to previous recommendations and/or services. However, it is your responsibility to communicate these changes for us to make the appropriate corrections to your management account(s). You will receive statements, at least quarterly, from the custodian where your account(s) is/are held. Such statements will identify your current investment holdings, the cost of each of those investments, and their current market values. You are encouraged to review the trading activities disclosed on your account statements, which summarize your portfolio account value, current holdings, and all account transactions made during the quarter. It is important for you to review these documents for accurate reporting and to determine whether we are meeting your investment expectations. ITEM 14 – CLIENT REFERRALS & OTHER COMPENSATION Referral Compensation We may directly compensate persons/firms for client referrals, provided those persons are qualified and have entered into 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 the solicitor will receive should you choose to open an account. In no case will the fee 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) Please refer to Item 12 - Brokerage Practices for more detailed information on the indirect economic benefits received from Schwab. Retirement Rollover Compensation When leaving an employer, you have four options to consider for your existing retirement plan: Leave the account assets in the former employer’s plan, if permitted;   Rollover the assets to the new employer’s plan, if one is available and rollovers are permitted;  Rollover the account assets to an Individual Retirement Account (an “IRA”); or,  Cash out the retirement account assets (There may be tax consequences and/or IRS penalties depending on your age). You may also engage in a combination of the options listed above. 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. Akatsuki Capital Page 11 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 15 – CUSTODY We do not take possession of or maintain custody of your funds or securities, but will simply monitor the holdings within your account 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 the 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 state-registered investment advisers under state securities laws, 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 in a separate account in your name.  Authorization to withdraw our management fees directly from your account must be obtained from you before engaging in any account management services.  Before deducting our management fee, we will notify the qualified custodian of the amount to be deducted and send  you an invoice that itemizes the fee, including the formula used to calculate it, the value of the assets under management on which the fee is based, and the time period covered by the fee. In addition, the qualified 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 account, and account transactions. You are encouraged to compare the financial data contained in our report to the account statement from the qualified custodian to verify the accuracy of our reporting. ITEM 16 – INVESTMENT DISCRETION We provide account management services primarily on a discretionary basis, but can also provide services on a non-discretionary basis3. If you engage us for discretionary account management services, we will have the authority to determine the types and amounts of securities to buy or sell in your account. You may place limitations, in writing, on our discretionary authority to the extent that the limitations do not adversely affect our ability to manage your account properly. Before we exercise discretionary authority in your account, you will be required to execute an investment advisory agreement or a limited power of attorney granting authority to buy, sell, or otherwise execute investment transactions in your account. ITEM 17 – VOTING CLIENT SECURITIES Unless otherwise agreed to in writing, we do not vote client proxies. You understand and agree that you retain the right to vote all proxies solicited for securities held in your managed accounts. The custodian of your managed accounts will send you all proxy solicitations. Any proxy solicitations we inadvertently receive will be promptly forwarded to you for your evaluation and decision. However, if you have specific questions about an action being solicited by the proxy that you do not understand or need clarification, you may contact us, and we will explain the details. Please note that we will not advise you on how to vote; the final decision on your vote is yours to make. If a client delegates proxy voting authority to us, we will vote proxies in a manner that serves the client’s best interests, as determined by us in our discretion, taking into account the following factors and any other factors that may be appropriate under the circumstances:  Whether the proposal is a routine proposal or a non-routine proposal;     The impact the proposal will have on the value of the security, or on the value of the returns to the client’s account; The costs associated with the proxy; The impact the proposal may have on the liquidity of the investment; and The impact the proposal may have on shareholder rights. Clients may obtain a copy of these proxy voting policies, as well as information on how we voted their proxies, by contacting us. Class Action Lawsuits We do not participate in class action proceedings on your behalf. Such decisions are your own or are made in conjunction with an entity you designate. However, if you have specific questions, you may contact us, and we will assist in clarifying the details. Any final decision regarding participation, as well as the completion and monitoring of any related documentation, shall be your responsibility. 3 Managing your account on a non-discretionary basis means we cannot execute securities transactions in your account without first obtaining your verbal consent to perform the trades. Therefore, you understand that in the event of a market correction, if we are unable to communicate our intent, your account could experience greater market volatility than accounts managed on a discretionary basis. Akatsuki Capital Page 12 of 13  FORM ADV PART 2A: DISCLOSURE BROCHURE ITEM 18 – FINANCIAL INFORMATION We are not required to include financial information in this Disclosure Brochure, as we do not take physical custody of client funds or securities, nor do we bill client accounts six (6) months or more in advance for an amount exceeding $1,200. We are unaware of any current financial conditions that could impair our ability to fulfill our contractual commitments to you. Additionally, neither the Firm nor any of our officers or directors has been the subject of a bankruptcy petition in the past 10 years. Akatsuki Capital Page 13 of 13  ITEM 1 – COVER PAGE This Brochure Supplement provides information about Alfred W. Graves that supplements the Disclosure Brochure for Akatsuki Capital, a division of Mint Asset Management, LLC. You should have received a copy of that brochure. If you did not receive our Disclosure Brochure or if you have any questions about this Brochure Supplement, you are welcome to contact us; our contact information is listed at the bottom of this page. FORM ADV PART 2B information about Alfred W. Graves is available on the SEC’s website at BROCHURE SUPPLEMENT Additional www.adviserinfo.sec.gov. July 30, 2026 ALFRED W. GRAVES Portfolio Manager CRD #: 7889866 Birth Year: 1989 ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Education   2014 – Cornell University: Bachelor of Arts (BA) in Government, Economics 2023 – Yale University, Yale School of Management: Master of Business (MBA) in Investment Management, Security Analysis FINRA Examinations   Series 65 – Uniform Investment Adviser Law Examination Securities Industry Essentials (SIE) Business Background 07/2026 – Present: Mint Asset Management, LLC / Portfolio Manager 01/2025 – Present: Akatsuki Capital, LLC / Managing Member 03/2024 – 07/2024: BMO Capital Markets Corp. / Equity Research Associate 06/2023 – 02/2024: Unemployed 08/2021 – 05/2023: Yale School of Management / MBA Student 02/2020 – 06/2022: SEI Investments / Fund Accounting Analyst ITEM 3 – DISCIPLINARY INFORMATION Mr. Graves 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 Mr. Graves is not involved in any other business activities outside of his employment with Mint Asset Management, LLC that provide a substantial source of income or involve a substantial amount of time. ITEM 5 – ADDITIONAL COMPENSATION Mr. Graves does not receive any financial incentives, sales awards, bonuses, or other forms of compensation based on the volume of sales, client referrals, or the opening of new accounts. Akatsuki Capital a division of Mint Asset Management, LLC ITEM 6 – SUPERVISION Steven Fishman Managing Member & Chief Compliance Officer Tel: (908) 777-1717 Branch Office 620 Allendale Road, Suite 125 King of Prussia, PA 19406 Tel: (610) 955-5128 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. Corporate office 165 Broadway, 23rd Floor New York, NY 10006 Tel: (908) 777-1717 www.mintassetmanagement.com Page 1 of 1 

ITEM 1 Cover Page DISCLOSURE BROCHURE Part 2A of Form ADV: Firm Brochure ASSET WISE ANALYTICS a division of BRANCH OFFICE 3 Arlington Road West Hartford, CT 06107 Tel: 551.201.1250 CORPORATE OFFICE Firm IARD/CRD #: 315568 165 Broadway, 23rd Floor New York, NY 10006 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. 30 JULY 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 While there are no material changes to report since the March 20, 2026, amendment filing, Item 14 of this Disclosure Brochure has been amended with additional disclosures related to client referrals. 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 8 ITEM 9 Disciplinary Information 11 ITEM 10 Other Financial Industry Activities & Affiliations 12 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 15 ITEM 15 Custody 16 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 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, each of which offers different investment management strategies. Although neither division is a separate legal entity, their investment management strategies are managed autonomously by an investment advisor representative of Mint, who will serve as your primary advisor and relationship manager. This Brochure provides information about the advisory services offered by Asset Wise Analytics, a division of Mint. Information about Mint’s other division 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. 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 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 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” with 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 maintaining a disciplined investment approach to realize your investment goals. Our services include: Portfolio Management Services Striving to achieve the best return on your investment capital, Asset Wise Analytics focuses its portfolio management services on designing and managing a portfolio tailored to your investment goals, risk tolerance, and income needs using a mix of investment strategies and asset classes, including but not limited to mutual funds, exchange-traded funds (“ETFs”), cash, and cash equivalents. We may also use individual stocks, bonds, and other securities and investment instruments to meet your needs. Held-Away Retirement Plan Assets We have entered a third-party agreement with Pontera Solutions, Inc. (“Pontera”), enabling us to manage and trade on assets held in employer-sponsored retirement plans and qualified tuition plans, such as defined contribution plan participant accounts (i.e., 401(k) and 403(b)), annuities, 457 deferred compensation plans, and 529 education savings plans (collectively herein referred to as “Held-Away Assets”). The Pontera platform links these Held-Away Assets in a single interface; providing a more comprehensive view of your retirement assets and allowing us the ability to implement asset allocation and opportunistic rebalancing strategies that would otherwise be constrained due to regulatory limitations related to federal and state custody laws. Upon engagement, Pontera will provide a secure link for you to gain access to their platform. There, you will provide detailed information relating to your Held-Away Assets and establish the login credentials to those accounts. We will not have direct login capability to those held-away assets. You maintain personal autonomy, allowing us only to allocate and trade those accounts you linked to the Pontera platform. Other disclosures related to our arrangement with Pontera are as follows:  Pontera charges an asset-based annual fee of 0.30% for each retirement account we manage on their platform. The fee is calculated at the beginning of each calendar quarter (i.e., 0.30% ¸ 4 = 0.075%) and billed to us – you do not pay directly for this service. This will NOT result in you paying a management fee higher than what we have currently disclosed in our fee schedule in Item 5, “Fees & Compensation.”  Our investment advice is limited by the investment choices available within your retirement or tuition plan. We are not responsible for any costs, expenses, transaction fees, redemption fees, penalties, or otherwise resulting from any account transactions.  We will not have, nor will we accept, any authority to change beneficiaries or effect account disbursements, or to process transfers of any funds to/from your retirement or tuition account.  We are independent of and not owned by, affiliated with, or supervised by Pontera.  We do not accept responsibility to provide ongoing review, monitoring or performance   evaluation of any Held-Away Assets not linked to the Pontera platform. If requested by you, we may consult or assist you regarding Held-Away Assets in matters that include, but are not limited to, disposition of assets, transferring of non-managed funds to/from the account(s), or assist with trades within the non-managed account(s), but only as directed by you. You remain responsible for all decisions and consequences regarding the Held-Away Assets. It is your exclusive obligation and sole responsibility to immediately notify us, in writing, if there is a change in your financial situation or investment objective(s) including, but not limited to, personal/financial situation, goals, needs or concerns/views regarding economic/political/financial climate as well as any changes 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 in investment alternatives, restrictions, etc. for the purpose of reviewing, evaluating or revising any of our previous recommendations and/or services, or if you want to impose, add or modify any reasonable restrictions to our investment advisory services. Please Note: Unless you advise, in writing, to the contrary, there are no restrictions on our services, other than to manage the account in accordance with your designated investment objective. Information regarding our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation,” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” I FEES & COMPENSATION T E M 5 Portfolio Management Fee Portfolio management services under Asset Wise Analytics are provided on an asset-based fee arrangement. Management fees are calculated based on the average daily balance3 of your account for each day in the previous calendar month multiplied by one-twelfth of the corresponding annual percentage rate. We retain discretion to negotiate, waive, or reduce the management fee within each tier on a client-by-client basis, depending on the size, complexity, and nature of the portfolio managed. Therefore, some clients may pay different fees for the same level of services provided by us. The portfolio management fee schedules for Asset Wise Analytics are as follows: Investment Strategies: Conservative Dynamic Growth, Moderate Dynamic Growth, & Dynamic Growth Portfolio Value Annual Fee Rate Not to Exceed Up to $500,000 ......................................... 1.50% Next $500,000 .......................................... 1.25% Next $1,500,000 ....................................... 1.00% Next $2,500,000 ....................................... 0.75% Over $5,000,000 ....................................... 0.50% Investment Strategy: Short Duration Income Strategy Portfolio Value Annual Fee Rate Not to Exceed Any Account Size 1.00% 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) deposits and withdrawals of funds, and (iv) other fees charged to your account(s). 3 The average daily balance is calculated by taking the sum of your account balance at the end of each day of the billing cycle and then dividing that sum by the number of days in the billing cycle. 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 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 average daily balance of your account throughout the calendar. For accounts opened between billing periods, our fee will be pro-rated 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. You have the option to pay us by check or electronically via ACH. Unless otherwise agreed to in writing, we will combine the account values of family members living in the same household to determine the applicable management fee. For example, we will combine the value of your managed account(s) with the values of managed accounts held by your spouse or partner and dependent children. Combining account values may increase the managed assets total, which could result in a reduced management fee based on the breakpoints in our tiered fee schedule. Other than the management fees listed in Item 5 (Fees & Compensation), we do not charge you any additional fees. Fee Exclusions The above fees for all of our Portfolio Management services are exclusive of any charges imposed by the custodial firm who has custody of your account; including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There may also be other fees charged to your account that are unaffiliated with our management services. In addition, all 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 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. For more information on the custodial firm that we will recommend to custody your portfolio accounts, see Item 12, “Brokerage Practices.” Termination of Portfolio Management Services At any time, either party (you or us) may terminate the Investment Advisory Agreement, and our Portfolio Management services, by written notification to the other party. Such written 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 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). In the event termination does not fall on the last day of a calendar month, we shall bill your account a pro-rated management fee based on the number of days during the calendar month we managed your portfolio. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice, and you become responsible for making your own investment decisions. 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 We primarily offer financial services to individuals and their families. We may also advise a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, or any other type of entity to which we choose to give investment advice. We generally require a minimum initial investment of $500,000 to open a managed account; however, we retain the right to waive or reduce this minimum if we feel circumstances are warranted. I METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS T E M 8 Asset Wise Analytics’ portfolio management services are designed to build long-term wealth while maintaining risk tolerance levels acceptable to you. We combine your financial needs and investment objectives, time horizon, and risk tolerance to yield an effective investment strategy and portfolio allocation. Your portfolio is then tailored to these unique investment parameters, primarily using a diversified mix of mutual funds, ETFs, cash, and cash equivalents. We may also use individual stocks, bonds, and other securities and investment instruments. 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. 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 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 market place. 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 Asset Wise Analytics may utilize the following investment strategies when managing your assets: Short Duration Income This model is designed for investors who have defined needs for their portfolio over the immediate to the next several years time frame. The model is constructed using money market instruments, short-duration ETFs, and defined maturity ETFs, laddered to match the client's objective. Conservative Dynamic Growth This model is designed as an "all-weather" approach for investors who desire current income and growth of capital and are willing to accept drawdowns in the range of 5-10%. The portfolio is constructed using a thoughtful combination of tactical growth and income strategies, a hedged equity core, and trend-following strategies that provide expanded diversification. The tactical growth and income will generally be a blend of 40% of a tactical growth model and 60% of a tactical income model. Each model is a separate, 100% rules-based model that systematically selects the top-ranked ETFs from a targeted universe of ETFs, each month. The hedged equity core will be approximately 20% of the overall model and be composed of ETFs that may hedge downside risk and write options for additional income against a basket of large- cap US stocks. The overall model may be comprised of 10%-15% systematic, trend-following strategies utilizing both ETFs and mutual funds that follow such approaches. It is anticipated that these funds will provide additional diversification as they seek opportunities in a wide range of additional asset classes such as currencies, metals, agriculture, energy, global equities, and fixed income. 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 Moderate Dynamic Growth This model is designed as an "all-weather" balanced approach for investors who desire current income and growth of capital and are willing to accept drawdowns in the range of 8-12%. The portfolio is constructed using a thoughtful combination of tactical growth and income strategies, a hedged equity core, focused equities strategies, and trend-following strategies that provide expanded diversification. The tactical growth and income will generally be a blend of 60% of a tactical growth model and 40% of a tactical income model. Each model is a separate, 100% rules-based model that systematically selects the top-ranked ETFs from a targeted universe of ETFs, each month. The hedged equity core will be approximately 20% of the overall model and be composed of ETFs that may hedge downside risk and write options for additional income against a basket of large-cap US stocks. The overall model may be comprised of 10%- 15% systematic, trend-following strategies utilizing both ETFs and mutual funds that follow such approaches. It is anticipated that these funds will provide additional diversification as they seek opportunities in a wide range of additional asset classes such as currencies, metals, agriculture, energy, global equities, and fixed income. The Moderate Dynamic Growth model may also make a 10% allocation to a focused equity strategy that may select up to 10 individual stocks from among a broader basket of large-cap US equities, using a 100% systematic, rules- based ranking methodology. Dynamic Growth trend-following strategies This model is designed as an "all-weather" approach for investors who desire growth of capital and are willing to accept drawdowns in the range of 10-15%. The portfolio is constructed using a thoughtful combination of tactical growth and income strategies, a hedged equity core, focused equity strategies, and that provide expanded diversification. The tactical growth and income will generally be a blend of 80% of a tactical growth model and 20% of a tactical income model. Each model is a separate, 100% rules-based model that systematically selects the top-ranked ETFs from a targeted universe of ETFs, each month. The hedged equity core will be approximately 20% of the overall model and be composed of ETFs that may hedge downside risk and write options for additional income against a basket of large-cap US stocks. The overall model may be comprised of 10%-15% systematic, trend-following strategies utilizing both ETFs and mutual funds that follow such approaches. It is anticipated that these funds will provide additional diversification as they seek opportunities in a wide range of additional asset classes such as currencies, metals, agriculture, energy, global equities, and fixed income. The Dynamic Growth model may also make a 10% allocation to a focused equity strategy that may select up to 10 individual stocks from among a broader basket of large-cap US equities, using a 100% systematic, rules-based ranking methodology. Other Investment Strategies In addition, we may use long term purchases, short-term purchases, trading, short sales, margin transactions, options, and alternative assets when managing your assets. Long-term purchases are investments held at least a year. Short-term purchases are investments sold within a year. Trading involves holding securities for less than 30 days. 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. 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.).  Margin Risk - Margin transactions may result in losses greater than the amount deposited in the investor’s margin account. This may require additional funds to be deposited or securities to be sold at a disadvantage to the investor.  Options Risk - Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. 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. 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 I OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS T E M 1 0 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. Because a separate division of Mint employs this individual, we do not believe that his role as a solicitor creates a conflict of interest with clients under the Asset Wise Analytics Division of Mint. 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 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: 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  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 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, as 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. 4. Bunched orders (See “Aggregating Trade Orders” below under Item 12, “Brokerage Practices”) may include employee accounts. In such cases, all client and employee accounts will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner. 5. Any individual not in observance of the above may be subject to termination. 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 Personal trading activities are monitored by our Chief Compliance Officer to ensure that such activities do not impact your security or create conflicts of interest. I BROKERAGE PRACTICES T E M 1 2 Custodial Services The Company typically recommends the custodial services of Charles Schwab & Company, Inc. (“Schwab”) and Interactive Brokers, LLC (“Interactive Brokers”), both of which are registered broker-dealers and members of FINRA and SIPC. Schwab and Interactive Brokers offer us services, which include custody of securities, trade execution, clearance, and settlement of transactions. Our recommendation for you to custody your assets with Schwab or Interactive Brokers has no direct correlation to the services we receive from the Custodians 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 the Custodians that are typically not available to Schwab and Interactive Brokers retail clients. This creates an incentive for us to recommend Schwab and Interactive Brokers based on the economic benefits we receive rather than on your interest in receiving the most favorable execution. These economic benefits include the following products and services provided without cost or at a discount:  Receipt of duplicate client statements and confirmations;  Research related products and 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, Schwab or Interactive Brokers. We are solely responsible for investment advice rendered, and our advisory services are provided separately and independently from Schwab and Interactive Brokers. Direction of Transactions and Commission Rates (Best Execution) We have a fiduciary duty to put your interests before our own. The advisory support services we receive from these custodians create an economic benefit to us, and a potential conflict of interest to you in that our recommendation to custody your account(s) with Schwab or Interactive Brokers may have been influenced by these arrangements/services. This is not the case; we have selected Schwab and Interactive Brokers as our custodian of choice 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, financial strength, and our personal experience in working with Schwab and Interactive Brokers staff. We do not generally permit you to direct us to use a particular broker-dealer outside of Schwab or Interactive to execute your account transactions. Since we do not recommend, suggest, or make available a selection of broker-dealers/custodians other than Schwab or Interactive Brokers, 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 broker-dealer. 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 Aggregating Trade Orders Our objective in order execution is to act fairly and impartially and to take all reasonable steps to obtain the best possible results (known as “best execution”) for our clients. Therefore, we typically bunch (aggregate) orders for a block trade when: (i) the bunching of orders is done for the purpose of achieving best execution; and (ii) no client is systematically advantaged or disadvantaged by bunching the orders. Client accounts participating in the bunched order will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner. In consideration of these objectives, we will take into account the unique execution factors of the buy/sell order before bunching accounts for a block trade. A few of those factors are:  Security Trading Volume – Bunching orders in a block trade can secure price parity and continuity for our clients during heavy trading activity.  Number of Clients – The fewer the number of client accounts involved in the bunched order may not yield better pricing or order execution; it may be more advantageous to perform an individual market order for each client. In addition, preparing individual market orders for the small number of accounts involved may be quicker to complete than preparing a bunch order.  Financial Instruments – The type of security involved, as well as the complexity of order, can affect our ability to achieve best execution. I REVIEW OF ACCOUNTS T E M 1 3 Portfolio Management Reviews Your investment strategies and investments are monitored and reviewed on an ongoing basis by our Managing Member, Steven Fishman, and Portfolio Manager, Michael Reilly. The general economy, market conditions, and/or changes in tax law can trigger more frequent reviews. Cash needs will be adjusted as necessary. Material changes in your personal/financial situation and/or investment objectives will require additional review and evaluation for us to properly advise you on revisions to previous recommendations and/or services. It is your responsibility to communicate these changes for us to make the appropriate corrections to your management account(s). You will receive statements, at least quarterly, from the custodian where your account(s) are held in custody which 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 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 into 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 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 and the compensation that the solicitor will receive should you choose to open an account. In no case will the fee 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 Schwab and Interactive Brokers (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 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. 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 protect our advisory practice, we have implemented the following regulatory safeguards: 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  Your funds and securities will be maintained with a qualified custodian (Schwab or Interactive Brokers) 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. If you engage us for such services, you may place limitations, in writing, on our discretionary authority to the extent that the limitations do not adversely affect our ability to properly manage your account. Prior to us exercising discretionary authority in your account, you will be required to execute an investment advisory agreement or limited power of attorney, granting us full authority to supervise and direct the investments in your account. Although we have this authority, you retain all rights of ownership of the account and may revoke this authority at any time. I VOTING CLIENT SECURITIES T E M 1 7 Unless otherwise indicated in writing to you, we are responsible for voting your proxy solicitations, and shall do so in conjunction with the proxy voting administrative and due diligence services provided by ProxyEdge, an unaffiliated nationally recognized proxy voting service of Broadridge Financial Solutions, Inc. (“Broadridge”). We, in conjunction with the services provided by ProxyEdge, shall monitor corporate actions of individual issuers and investment companies consistent with our fiduciary duty to vote proxies in your best interest. With respect to individual issuers, we may be solicited to vote on matters including corporate governance, adoption or amendments to compensation plans (including stock options), and matters involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual funds), we may be solicited to vote on matters including the approval of advisory contracts, distribution plans, and mergers. We (in conjunction with the services provided by ProxyEdge) shall maintain records pertaining to proxy voting as required under the Advisers Act. Information pertaining to how we voted on any specific proxy issue is also available upon written request. If you have any questions regarding our proxy voting policy, you may contact our office. 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. We have identified an unaffiliated service provider (Broadridge) to assist you, for a fee (generally 20% of the recovery), with class-action matters. We will not receive any compensation from the service provider. You are under no obligation to use Broadridge for class-action matters. Please notify us in writing if you do not wish to use Broadridge for its class-action service. Please note: We do not participate in class-action proceedings on behalf of our clients. Thus, if you choose not to use Broadridge, you will be exclusively responsible to pursue and monitor all class-action claims. 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 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 Michael J. Reilly 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. Reilly, you are welcome to contact us – our contact information is listed to the left. Additional information about Mint Asset Management, LLC and Michael J. Reilly is also available on the SEC’s website at www.adviserinfo.sec.gov. FORM ADV: PART 2B BROCHURE SUPPLEMENT Michael J. Reilly CRD#: 2006998 Year of Birth: 1964 ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Education 1986 – Southern Connecticut State University: Bachelor of Science in Economics Licenses FINRA Exams: Series 65 – Uniform Investment Advisor Law Examination Business Background 03/2024 – Present ...... Mint Asset Management LLC Position: Investment Adviser Representative 11/2015 – 03/2024 ..... Rowe Wealth Management, LLC d/b/a Avalon Position: Principal, CCO, & Investment Adviser Representative 01/2009 –11/2015 ...... LPL Financial LLC Position: Registered Representative 03/1997 01/2009 ....... Securities America Advisors Inc. Position: Investment Adviser Representative ITEM 3 - DISCIPLINARY INFORMATION Mr. Reily 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. ITEM 4 - OTHER BUSINESS ACTIVITIES BRANCH OFFICE Mr. Reilly is not involved in any other business activities outside of his employment with Mint Asset Management, LLC that provides a substantial source of income or involves a substantial amount of time. 3 Arlington Road West Hartford, CT 06107 ITEM 5 - ADDITIONAL COMPENSATION Tel: 551-201.1250 Mr. Reilly 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. CORPORATE OFFICE 165 Broadway, 23rd Floor New York, NY 10006 ITEM 6 - SUPERVISION Steven Fishman Managing Member & Chief Compliance Officer Tel: 908.777.1717 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. www.mintassetmanagement.com BROCHURE SUPPLEMENT DATED 30 JULY 2026 © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com 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 BRANCH OFFICE 3 Arlington Road West Hartford, CT 06107 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: 551-201.1250 Potential Time Management Conflict CORPORATE OFFICE 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. 165 Broadway, 23rd Floor New York, NY 10006 ITEM 5 - ADDITIONAL COMPENSATION Tel: 908.777.1717 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. www.mintassetmanagement.com 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 30 JULY 2026 © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com Page 1 of 1 

ITEM 1 Cover Page DISCLOSURE BROCHURE Part 2A of Form ADV: Firm Brochure Bryan Perry’s Private Clients a division of 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. 30 JULY 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 While there are no material changes to report since the March 20, 2026, amendment filing, Item 14 of this Disclosure Brochure has been amended with additional disclosures related to client referrals. 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 21  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 7 ITEM 6 Performance-Based Fees & Side-By-Side Management 9 ITEM 7 Types of Clients 9 ITEM 8 Methods of Analysis, Investment Strategies & Risk of Loss 10 ITEM 9 Disciplinary Information 13 ITEM 10 Other Financial Industry Activities & Affiliations 14 ITEM 11 Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 14 ITEM 12 Brokerage Practices 16 ITEM 13 Review of Accounts 18 ITEM 14 Client Referrals & Other Compensation 18 ITEM 15 Custody 19 ITEM 16 Investment Discretion 20 ITEM 17 Voting Client Securities 20 ITEM 18 Financial Information 20 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 21  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 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, each of which offers different investment management strategies. Although neither division is a separate legal entity, their investment management strategies are managed autonomously by an investment advisor representative of Mint who will serve as your primary advisor and relationship manager. This Brochure provides information about the advisory services offered by the Bryan Perry’s Private Clients division of Mint. Information about Mint’s other division 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. 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 21  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. Our services include: Portfolio Management Services Striving to achieve the best return on your investment capital, Bryan Perry’s Private Clients focuses its portfolio management services on designing and managing a portfolio tailored to your investment goals, risk tolerance, and income needs using a mix of investment strategies and asset classes, including but not limited to equity (“stock”) positions, fixed income securities (bonds, U.S. Treasuries, and mortgage backed securities), options, investment company (“mutual fund”) products, exchange traded funds (“ETFs”), Real Estate Investment Trusts (“REITs), cash, cash equivalents, other securities and investment instruments, and third- party money managers and programs. Inverse & Leveraged Investments We may utilize inverse mutual funds and/or ETFs that are designed to perform in an inverse (opposite) relationship to certain market indices (at a rate of one or more times the inverse result of the corresponding index). In addition, we may also use leveraged (enhanced) mutual funds or ETFs that provide an enhanced relationship to certain market indices (at a rate of more than one times the actual result of the corresponding index). These strategies involve a higher level of inherent risk, and therefore, you may direct us, in writing, not to employ any or all such investment strategies. See Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss” for a more detailed description of the risks associated with using inverse/enhanced investments. Third-Party Money Managers We may use the services of a third-party money manager or program (“TPM”) to manage all or a portion of your investment portfolio. Factors that we take into consideration when selecting a TPM include, but are not limited to, the following: the TPM’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPM’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPM will actively manage your portfolio on a discretionary basis. We will assume discretionary authority to hire and fire the TPM and/or reallocate your assets to other TPM’s where we deem such action appropriate. Held-Away Retirement Plan Assets We have entered a third-party agreement with Pontera Solutions, Inc. (“Pontera”), enabling us to manage and trade on assets held in employer-sponsored retirement plans and qualified tuition plans, such as defined contribution plan participant accounts (i.e., 401(k) and 403(b)), annuities, 457 deferred compensation plans, and 529 education savings plans (collectively herein referred to as “Held-Away Assets”). The Pontera platform links these Held-Away Assets in a single interface; providing a more comprehensive view of your retirement assets and allowing us the ability to implement asset allocation and opportunistic rebalancing strategies that would otherwise be constrained due to regulatory limitations related to federal and state custody laws. 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 21  DISCLOSURE BROCHURE Upon engagement, Pontera will provide a secure link for you to gain access to their platform. There, you will provide detailed information relating to your Held-Away Assets and establish the login credentials to those accounts. We will not have direct login capability to those held-away assets. You maintain personal autonomy, allowing us only to allocate and trade those accounts you linked to the Pontera platform. Other disclosures related to our arrangement with Pontera are as follows:  Pontera charges an asset-based annual fee of 0.30% for each retirement account we manage on their platform. The fee is calculated at the beginning of each calendar quarter (i.e., 0.30% ¸ 4 = 0.075%) and billed to us – you do not pay directly for this service. This will NOT result in you paying a management fee higher than what we have currently disclosed in our fee schedule in Item 5, “Fees & Compensation.”  Our investment advice is limited by the investment choices available within your retirement or tuition plan. We are not responsible for any costs, expenses, transaction fees, redemption fees, penalties, or otherwise resulting from any account transactions.  We will not have, nor will we accept, any authority to change beneficiaries or effect account disbursements, or to process transfers of any funds to/from your retirement or tuition account.  We are independent of and not owned by, affiliated with, or supervised by Pontera.  We do not accept responsibility to provide ongoing review, monitoring or performance   evaluation of any Held-Away Assets not linked to the Pontera platform. If requested by you, we may consult or assist you regarding Held-Away Assets in matters that include, but are not limited to, disposition of assets, transferring of non-managed funds to/from the account(s), or assist with trades within the non-managed account(s), but only as directed by you. You remain responsible for all decisions and consequences regarding the Held-Away Assets. It is your exclusive obligation and sole responsibility to immediately notify us, in writing, if there is a change in your financial situation or investment objective(s) including, but not limited to, personal/financial situation, goals, needs or concerns/views regarding economic/political/financial climate as well as any changes in investment alternatives, restrictions, etc. for the purpose of reviewing, evaluating or revising any of our previous recommendations and/or services, or if you want to impose, add or modify any reasonable restrictions to our investment advisory services. Please Note: Unless you advise, in writing, to the contrary, there are no restrictions on our services, other than to manage the account in accordance with your designated investment objective. Referral Services In situations where we determine that a TPM’s investment advisory services are more suitable for your needs than ours, we will recommend that you directly engage the TPM to provide ongoing investment advisory services. You are under no obligation to accept our recommendation, but should you do so, you will be required to enter into an investment advisory agreement with the TPM. When your relationship is established with the TPM, we step away and have no further interaction with you in an advisory capacity, unless otherwise agreed to in writing. As compensation for the referral, we receive a fee from the TPM which is based on a portion (up to 20%) of your advisory fee collected by the TPM. The TPM’s fee schedule and referral fees shared with us are detailed in the TPM’s Disclosure Brochure (Form ADV Part 2) and other required disclosure documents that we will provide to you when we make the recommendation. 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 21  DISCLOSURE BROCHURE Information regarding our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss”. I FEES & COMPENSATION T E M 5 Portfolio Management Fee Portfolio Management services are primarily provided on an asset-based fee arrangement. The management fee will be calculated based on the aggregate market value of your portfolio account(s) on the last business day of the previous quarter (i.e., March 31st, June 30th, September 30th, and December 31st) multiplied by one-fourth the corresponding annual fee rate for each portion of your portfolio assets that fall within each tier. We retain discretion to negotiate, waive, or reduce the management fee within each tier on a client-by-client basis depending on the size, complexity, and nature of the portfolio managed. In addition, as your portfolio value exceeds each tier level, either through additional deposits or asset growth, a fee break will occur. Our standard fee schedule is as follows: Portfolio Value Annual Fee Rate Not to Exceed Up to $500,000 ......................................... 1.50% Next $500,000 .......................................... 1.25% Next $500,000 .......................................... 1.00% Next $1,000,000 ....................................... 0.75% Next $2,500,000 ....................................... 0.50% Over $5,000,000 ....................................... 0.35% For any portion of your account managed by a TPM, this management fee schedule and the “Protocols for Portfolio Management” listed below may not apply. If the TPM’s fee schedule and protocols apply, the TPM will disclose their fee schedule for management services in their Disclosure Brochure (the money manager’s ADV Part 2A: Firm Brochure), which we will provide you prior to engaging the TPM to manage your account. The money manager will bill your account for management services based on their fee schedule and split a portion of that management fee with us as agreed. Our portion of the management fee received from the TPM will generally range between 0.50% and 1.25% of the portfolio’s market value. If our fee schedule and protocols apply, we will bill your account accordingly and share a portion of the management fee with the TPM. The TPM’s portion of the management fee will generally range between 0.25 and 1.00% of the portfolio’s market value. For example, if your account value was $250,000 at the end of quarter, our quarterly fee would be $937.50 ($250,000 multiplied by 1.50% divided by four). If we engaged a TPM to manage the account based on our fee schedule at an agreed upon annual fee of 0.25% of the account value, the TPM’s share of the quarterly fee would be $156.25 ($250,000 multiplied by 0.25% divided by four) and our share would be $781.25 ($937.50 minus $156.25). The management fee split between the Company and TPM will not result in you paying a higher management fee. Additional Details regarding the fee split arrangement will be provided to you prior to engaging the TPM to manage your account. 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 21  DISCLOSURE BROCHURE The TPM’s Disclosure Brochure contains all pertinent disclosures relating to their management services, the fee structure for such services, and termination provisions – you are encouraged to carefully review their document. Please note that the fee schedules among TPMs will vary and may be higher or lower than our fee schedule. Therefore, client accounts managed by a TPM may pay a higher or lower fee than those managed solely by us. 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) deposits and withdrawals of funds; and (iv) 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 quarterly (i.e., March 31st, June 30th, September 30th, and December 31st) in advance based on the aggregate, fair market value of your portfolio (i.e., investments/securities, cash, and cash equivalents) and where it falls within our tiered fee schedule. For managed accounts opened between billing periods, our fee will be pro-rated from inception through the end of the quarterly 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. You have the option to pay us by check or electronically via ACH. Unless otherwise agreed to in writing, we will combine the account values of family members living in the same household to determine the applicable management fee. For example, we will combine the value of your managed account(s) with the values of managed accounts held by your spouse or partner and dependent children. Combining account values may increase the managed assets total, which could result in a reduced management fee based on the breakpoints in our tiered fee schedule. Other than the management fees listed in Item 5 (Fees & Compensation), we do not charge you any additional fees. Deposits and Withdrawals Assets deposited by you into your portfolio management account between billing cycles will not result in additional management fees being billed to your account. We do not want to discourage you from investing additional capital for your future., We do not make partial refunds of our quarterly fee for withdrawals you make during a calendar quarter. 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 21  DISCLOSURE BROCHURE Fee Exclusions The above fees for all of our Portfolio Management services are exclusive of any charges imposed by the custodial firm who has custody of your account; including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. In addition, all 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. For more information on the custodial firm that we will recommend to custody your portfolio accounts, see Item 12, “Brokerage Practices”. 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 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). In the event termination does not fall on the last day of a calendar quarter, you shall be entitled to a pro-rated refund of the prepaid quarterly management fee based on the number of days remaining in the quarter after the termination notice goes into effect. If your portfolio account is managed by a TPM, your portfolio account may be billed in advance or in arrears and shall adhere to the termination policies set forth in the TPM’s ADV Part 2A: Firm Brochure. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and you become responsible for making your own investment decisions. 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 We primarily offer financial services to individuals and their families. We may also advise a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, or any other type of entity to which we choose to give investment advice. 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 21  DISCLOSURE BROCHURE We generally require a minimum initial investment of $500,000 to open a managed account; however, we retain the right to waive or reduce this minimum if we feel circumstances are warranted. I METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS T E M 8 Bryan Perry’s Private Clients’ portfolio management services are designed to build long-term wealth while maintaining risk tolerance levels acceptable to you. We combine your financial needs and investment objectives, time horizon, and risk tolerance to yield an effective investment strategy and portfolio allocation. Your portfolio is then tailored to these unique investment parameters using a diversified mix of asset classes such as stocks, fixed income securities, options, mutual funds, ETFs, REITs, cash, cash equivalents, other securities and investment instruments, and third-party money managers. 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 market place. 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. 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 21  DISCLOSURE BROCHURE Investment Strategies We strive for higher equity growth and income than the S&P with a target of having lower beta, income assets with attractive yields and a defensive strategy focused on protecting assets during market downturns. Bryan Perry’s Private Clients’ investment strategies are as follows: Total Return Portfolio Primary Goal: Our total return strategy is designed to focus on maximize returns while striving to manage risks by investing in leading companies in their respective fields with growth potential, offering innovative products and services to a rapidly expanding marketplace. We focus on identifying companies with sustainable competitive advantages, strong management teams, and a proven track record of delivering consistent growth. By investing in such companies, we believe we can generate superior returns over the long term. Investment Process:  Active management of high-growth stocks and high-beta ETFs that are characterized by higher risk/reward ratios.  Market hedges through the use of cash or -1X inverse index ETFs.  We may elect to maintain up to a 100% cash position of total assets, depending on market conditions.  Managing a diversified-by-sector portfolio consisting of large-cap, mid-cap and small- cap equities targeting inefficiently priced high-growth companies with significant potential for long-term price appreciation.  As higher-multiple stocks carry a higher degree of volatility, a larger emphasis is placed  on technical analysis in the course of portfolio management. Identify sector rotation sensitive to ETF fund flows whereby stock and ETF selection is validated by fundamental quantitative sales and earnings momentum analysis, technical overlays.  Length of trades are based on directional trading discipline that depends on various technical indicators and analysis. Conservative Portfolio Primary Goal: The goal for a conservative investment strategy is to create a diversified portfolio that balances income and growth while also managing risk. The emphasis is on generating income through dividends, interest, and other sources, while also seeking some capital appreciation over the long term. This strategy strives to provide investors with a steady stream of income. Covered call option strategies may be employed to enhance income. Overall, this strategy aims to provide a stable return on investment while managing risk through diversification and income generation. Investment Process: We will focus on a mix of different asset classes, such as:  Treasuries and government agency notes and bonds: These could make up a portion of  the portfolio to provide a low-risk foundation and preserve capital. Investment grade short duration corporate bonds: These could be included to add some yield potential and diversification.  Government insured money markets: These could be included for liquidity and short-  term cash management. investment grade preferred stocks: This asset class could be included for its high dividend yield and potential for capital appreciation.  Real Estate Investment Trusts (REITs): These could be included to provide exposure to the real estate market and generate additional income.  Dividend stocks that are hedged via a covered call option strategy: These could be included to provide further diversification and the potential for additional income through a covered call option strategy. 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 21  DISCLOSURE BROCHURE Income Portfolio Primary Goal: To provide current income, with capital appreciation as a secondary objective to investors with a higher risk tolerance for income generation that exceeds that of short-term conventional investment grade fixed income assets. Investment Process: The strategy seeks to achieve its investment objectives by utilizing a dynamic asset allocation strategy deployed among multiple fixed and non-fixed income sectors in the global markets, including corporate debt, mortgage-related and other asset-backed securities, government and sovereign debt, floating-rate income-producing securities, REITs and common stocks. Other Investment Strategies In addition, we may use long term purchases, short-term purchases, trading, short sales, margin transactions, options, and alternative assets when managing your assets. Long-term purchases are investments held at least a year. Short-term purchases are investments sold within a year. Trading involves holding securities for less than 30 days. You should be aware that frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales involve selling securities that the investor does not own and delivering the borrowed securities to the purchaser, with an obligation to replace the borrowed securities at a later date. The securities are borrowed from a third party, typically a broker-dealer. If the price of the securities declines between the date of sale and date of repurchase, the investor will profit to the extent that the decline in price exceeds the investor’s transaction and borrowing expenses. The investor will incur a loss if the price of the securities rises. Margin transactions involve the use current holdings as collateral to buy additional securities. Options are contracts that give the owner the right to buy or sell a security at a specific price and period of time. When an investor sells (writes) an option, the investor must deliver to the buyer a specified number of shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a particular time) in exchange for writing the option. When buying an option, the investor has the right to purchase or sell a security at a specified price until the expiration date of the option. 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. Inflation Risk – The reduction of purchasing power of investments over time. 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 21  DISCLOSURE BROCHURE  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.).  Margin Risk - Margin transactions may result in losses greater than the amount deposited in the investor’s margin account. This may require additional funds to be deposited or securities to be sold at a disadvantage to the investor.  Options Risk - Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks.   Leveraged Funds – Leveraged mutual funds and ETFs seek to provide leveraged returns at multiples of the underlying benchmark or index they track. Leveraged funds generally seek to provide a multiple of the daily return of an index or other benchmark for a single day excluding fees and other expenses. In addition to using leverage, these funds often use derivative products such as options, futures contracts, and swaps to accomplish their objectives. The use of leverage and derivative instruments can cause leveraged funds to be volatile and subject to extreme price movements. Inverse Funds - Inverse mutual funds and ETFs seek to provide the opposite of the performance of the index or benchmark they track. Their objective is to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use leverage when seeking to achieve a return that is a multiple of the opposite performance of the underlying index or benchmark. These funds may also use derivative instruments to accomplish their investment objectives. Inverse funds are volatile and provide the potential for significant losses. 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. 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 21  DISCLOSURE BROCHURE I OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS T E M 1 0 Financial Industry Activities Bryan Perry 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 Mr. Perry 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 Mr. Perry and other supervised persons will have knowledge of the recommendations before their publication. Therefore, to prevent Mr. Perry and other 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 the newsletters authored by Mr. Perry. Under a written solicitor agreement between Mint and Navellier, Mr. Perry receives compensation for marketing Navellier’s investment advisory services to prospective investors derived from Navellier’s other marketing efforts. Mr. Perry’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 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 21  DISCLOSURE BROCHURE professionalism expected by all personnel in discharging their duties. This Code is a value-laden 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 15 of 21  DISCLOSURE BROCHURE 4. Bunched orders (See “Aggregating Trade Orders” below under Item 12, “Brokerage Practices”) may include employee accounts. In such cases, all client and employee accounts will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner. 5. 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 The Company typically recommends the custodial services of Charles Schwab & Company, Inc. (“Schwab”) and Interactive Brokers, LLC (“Interactive Brokers”), both of which are registered broker-dealers and members of FINRA and SIPC. Schwab and Interactive Brokers offer us services, which include custody of securities, trade execution, clearance and settlement of transactions. Our recommendation for you to custody your assets with Schwab or Interactive Brokers has no direct correlation to the services we receive from the Custodians 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 the Custodians that are typically not available to Schwab and Interactive Brokers retail clients. This creates an incentive for us to recommend Schwab and Interactive Brokers based on the economic benefits we receive rather than on your interest in receiving most favorable execution. These economic benefits include the following products and services provided without cost or at a discount:  Receipt of duplicate client statements and confirmations;  Research related products and 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, Schwab or Interactive Brokers. We have sole responsibility for investment advice rendered, and our advisory services are provided separately and independently from Schwab and Interactive Brokers. Direction of Transactions and Commission Rates (Best Execution) We have a fiduciary duty to put your interests before our own. The advisory support services we receive from these custodians creates an economic benefit to us and a potential conflict of interest to you; in that, our recommendation to custody your account(s) with Schwab or Interactive Brokers may have been influenced by these arrangements/services. This is not the case; we have selected Schwab and Interactive Brokers as our custodian of choice based on: 1. Their competitive transaction charges, trading platform, and on-line 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 Schwab and Interactive Brokers staff. 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 21  DISCLOSURE BROCHURE We do not generally permit you to direct us to use a particular broker-dealer outside of Schwab or Interactive to execute your account transactions. Since we do not recommend, suggest, or make available a selection of broker-dealers/custodians other than Schwab or Interactive Brokers, 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 broker-dealer. Selection of Third-Party Money Managers We may select various TPM’s to manage your portfolio accounts. We will assist you in determining which is most likely to provide the most effective financial growth based on your stated investment objectives and risk tolerance level. Where applicable, the brokerage practices of the TPM will be disclosed in their ADV Part 2A: Firm Brochure, which we will provide you prior to engaging the money manager to manage your account. As disclosed in Item 5, “Fees & Compensation”, your management fee will be shared between us and the TPM. Because our fee sharing arrangements vary with each TPM, this creates an incentive for us to recommend TPMs that provide us with a higher portion of your management fee. We mitigate this conflict of interest by fully disclosing to you the details of the fee-sharing arrangement and by selecting TPMs based on how well their investment strategies align with your investment objectives. In addition, prior to engagement and on a periodic basis, we review each TPM to ensure they are properly registered and have the reputation, experience, and credentials to provide investment management services. While we have exercised our best efforts in evaluating the investment performance and cost of services offered by these TPMs, we make no representation that the TPM to which you are referred has the best investment performance or the lowest portfolio management costs. The selection of TPMs will be limited to those with whom we have entered into service agreements. Therefore, it is possible that you could contract for similar services elsewhere or separately with higher performance at a lower cost. You are under no obligation to accept our recommendation to use a TPM to manage your portfolio. Aggregating Trade Orders Our objective in order execution is to act fairly, impartially, and to take all reasonable steps to obtain the best possible results (known as “best execution”) for our clients. Therefore, we typically bunch (aggregate) orders for a block trade when: (i) the bunching of orders is done for the purpose of achieving best execution; and, (ii) no client is systematically advantaged or disadvantaged by bunching the orders. Client accounts participating in the bunched order will receive an average share price, and transaction costs, if any, will be shared equally and on a pro rata basis. If a bunched trade is not completely filled, shares will be allocated in a fair and equitable manner. In consideration of these objectives, we will take into account the unique execution factors of the buy/sell order before bunching accounts for a block trade. A few of those factors are:  Security Trading Volume – Bunching orders in a block trade can secure price parity and continuity for our clients during heavy trading activity.  Number of Clients – The fewer the number of client accounts involved in the bunched order may not yield better pricing or order execution; it may be more advantageous to perform an individual market order for each client. In addition, preparing individual market orders, for the small number accounts involved, may be quicker to complete than preparing a bunch order.  Financial Instruments – The type of security involved as well as the complexity of order can affect our ability to achieve best execution. 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 21  DISCLOSURE BROCHURE I REVIEW OF ACCOUNTS T E M 1 3 Portfolio Management Reviews Your investment strategies and investments are monitored and reviewed on an ongoing basis by our Managing Member, Steven Fishman, and Portfolio Manager, Bryan Perry. The general economy, market conditions, and/or changes in tax law can trigger more frequent reviews. Cash needs will be adjusted as necessary. Material changes in your personal/financial situation and/or investment objectives will require additional review and evaluation for us to properly advise you on revisions to previous recommendations and/or services. However, it is your responsibility to communicate these changes for us to make the appropriate corrections to your management account(s). 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 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. Third-Party Money Manager Reviews If agreed to in writing, our Managing Member, Steven Fishman, will monitor and evaluate the performance of the TPM managing your account on a regular basis. We understand your goals and tolerance for risk may change over time; therefore, even though we may not be involved with the day-to-day management of your assets maintained with a TPM, we will supervise your portfolio and will make recommendations to you regarding the TPMs as market factors and your personal goals dictate. I CLIENT REFERRALS & OTHER COMPENSATION T E M 1 4 Referral Compensation Please see sub-section titled “Selection of Third-Party Money Managers” under Item 12, “Brokerage Practices”, for the conflicts of interest related to referral and fee sharing compensation arrangements with TPMs. 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 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 21  DISCLOSURE BROCHURE 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 Schwab and Interactive Brokers (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. 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 (Schwab or Interactive Brokers) 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. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 19 of 21  DISCLOSURE BROCHURE I INVESTMENT DISCRETION T E M 1 6 We provide investment management services on a discretionary basis. If you engage us for such services, you may place limitations, in writing, on our discretionary authority to the extent that the limitations do not adversely affect our ability to properly manage your account. Prior to us exercising discretionary authority in your account, you will be required to execute an investment advisory agreement or limited power of attorney, granting us full authority to supervise and direct the investments in your account. Although we have this authority, you retain all rights of ownership of the account and may revoke this authority at any time. I VOTING CLIENT SECURITIES T E M 1 7 Unless otherwise indicated in writing to you, we are responsible for voting your proxy solicitations, and shall do so in conjunction with the proxy voting administrative and due diligence services provided by ProxyEdge, an unaffiliated nationally recognized proxy voting service of Broadridge Financial Solutions, Inc. (“Broadridge”). We, in conjunction with the services provided by ProxyEdge, shall monitor corporate actions of individual issuers and investment companies consistent with our fiduciary duty to vote proxies in your best interest. With respect to individual issuers, we may be solicited to vote on matters including corporate governance, adoption or amendments to compensation plans (including stock options), and matters involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual funds), we may be solicited to vote on matters including the approval of advisory contracts, distribution plans, and mergers. We (in conjunction with the services provided by ProxyEdge) shall maintain records pertaining to proxy voting as required under the Advisers Act. Information pertaining to how we voted on any specific proxy issue is also available upon written request. If you have any questions regarding our proxy voting policy, you may contact our office. 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. We have identified an unaffiliated service provider (Broadridge) to assist you, for a fee (generally 20% of the recovery), with class-action matters. We will not receive any compensation from the service provider. You are under no obligation to use Broadridge for class-action matters. Please notify us in writing if you do not wish to use Broadridge for its class-action service. Please note: We do not participate in class-action proceedings on behalf of our clients. Thus, if you choose not to use Broadridge, you will be exclusively responsible to pursue and monitor all class-action claims. 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. Mint Asset Management, LLC Form ADV: Part 2A © 38 Compliance jointly with eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 20 of 21  DISCLOSURE BROCHURE 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 21 of 21  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 30 JULY 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 30 JULY 2026 © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com Page 1 of 1 

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. 30 JULY 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 This Disclosure Brochure has been reviewed and is current as of the date indicated on the cover. 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. 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 We do not vote client proxies for accounts managed under the SpaceMint Investment Portfolio strategy. You understand and agree that you retain the right to vote all proxies solicited for securities held in your managed accounts. Any proxy solicitations we inadvertently receive will be forwarded to you immediately for your evaluation and decision. However, if you have specific questions regarding an action being solicited by the proxy that you do not understand, or you 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 want clarification, you may contact us, and we will explain the particulars. Keep in mind that we will not advise you on how to vote; the final decision will be yours. 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 30 JULY 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 30 JULY 2026 © 38 Compliance jointly with eAdvisor Compliance, Inc. – Brochure Supplement Design Layout. www.38compliance.com Page 1 of 1