Sabre Asset Management LLC

FORM ADV PART 2A (FIRM BROCHURE) Sabre Asset Management LLC 29525 Chagrin Blvd., Suite 302 Pepper Pike, OH 44122 Telephone: 216-245-6622 Fax Number: 216-245-6627 Website: https://sabreasset.com September 2, 2026 Item 1: Cover Page This brochure provides information about the qualifications and business practices of Sabre Asset Management LLC. If you have any questions about the contents of this brochure, please contact us at 216-245-6622. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Sabre Asset Management LLC is available on the SEC's website at www.adviserinfo.sec.gov. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Sabre Asset Management LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2: Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Generally, Sabre Asset Management LLC will notify clients of material changes on an annual basis. However, where we determine that an interim notification is either meaningful or required, we will notify our clients promptly. In either case, we will notify our clients in a separate document. This Brochure, dated June 29, 2026, is an other-than-annual update to the last annual brochure dated March 15, 2026. • The firm has transitioned to registration with the United States Securities and Exchange Commission from its current registration at the state level. This Brochure replaces the previous version dated June 29, 2026. Full Brochure Availability The Firm Brochure for Sabre Asset Management LLC is available by contacting us at 216-245-6622. In 2026, all new clients are being provided a full copy of our brochure. 2  Item 3: Table of Contents Subject Item # 1 2 3 4 5 6 7 8 9 10 11 Page # 1 2 3 4 4 6 6 6 8 8 9 12 13 14 15 16 17 18 19 Cover Page Material Changes Table of Contents Advisory Business Fees and Compensation Performance-Based Fees and Side-By-Side Management Types of Clients Methods of Analysis, Investment Strategies and Risk of Loss Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Brokerage Practices Review of Accounts Client Referrals and Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Requirements for State-Registered Advisers Brochure Supplement for Michael Whalen 9 10 11 11 12 13 13 13 14 3  Item 4: Advisory Business Firm Description Sabre Asset Management LLC (“SAM”) is a registered investment adviser primarily based in Pepper Pike, Ohio. We are organized as a limited liability company under the laws of the State of Ohio. We have been providing investment advisory services since 2017. Principal Owner Michael Whalen is the principal owner. Types of Advisory Services Sabre Asset Management provides investment management services to individuals, Trusts, and retirement plans. Our strategy predominately uses individual equities, no-load mutual funds, exchange traded funds (ETF’s) and closed end mutual funds but may include investments in corporate debt, municipal securities, United States government obligations and option contacts on securities. SAM will act as an investment advisor and will supervise and direct the investments and make all investment decisions for the client based on the client’s risk aversion. Tailored Relationships We will work with our clients that have specific needs to tailor portfolios to meet their investment parameters, time horizon, risk tolerance, and return objectives. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in SAMs sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Wrap Fee Programs Sabre Asset Management does not offer a wrap fee program. Assets Under Management Sabre Asset Management has $127,339,006 in assets under management (AUM) as of June 2026. All of these assets were managed on a discretionary basis. Item 5: Fees and Compensation Description & Fee Billing Investment management services are provided based on written agreement. The agreement includes fee schedules, and advisory fees are generally payable quarterly in advance based upon the net value of the account on the last business day of the previous quarter. For accounts opened during the quarter, the net value of assets contributed to the account serves as the basis for the fees for that quarter which is calculated on a prorated basis. As part of the written agreement, Client authorizes the custodian to deduct SAM’s fee directly from the account upon presentation of an appropriate invoice showing the calculation of the fee. Fees are based solely upon a percentage of assets under management. 4  The fee schedule is: 1.5% of the first $500,000 1.0% of the next $1.5 million .75% of the next $1 million .50% of the amount above $3 million For example, if your account is $2.5 million in value, the quarterly fee is calculated by multiplying $500,000 by .015 plus multiplying $1.5 million by .010 plus multiplying $500,000 by .0075, then take the total sum and divide by 4 to arrive at the total due. All of your accounts are grouped when determining fee. The Agreement may be cancelled by either party in accordance with the provisions of the Agreement. If the Agreement is canceled prior to the end of the calendar quarter, the unearned portion of the fee will be returned to the Client. Clients may also terminate the Agreement without incurring any fees within five days of signing. The foregoing describes SAM’s basic fee schedule, however, fees may be negotiable in certain limited circumstances and arrangements. Your death will not terminate the Investment Management Agreement or authority granted to SAM Capital until we have received actual written notification of your death. Other Fees and Expenses Our management fees are separate from charges assessed by third parties such as broker dealers, custodians and mutual fund companies. Brokerage and other transaction costs charged by broker dealers executing transactions and custodians maintaining your assets are in addition to the management fees and are not negotiable. Investment advisor clients that hold mutual funds in their portfolio(s) will also pay investment management fees and/or administrative fees. These fees are paid to the managers of the fund for their role in managing the fund(s) on a daily basis. Mutual funds, variable annuities and or other platforms may assess other fees and expenses such as 12B-1 fees or commissions in connection with the placement of your funds. To fully understand the total cost you will incur, you should review the prospectus for all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this brochure. Fees Paid In Advance Management fees are charged quarterly (1/4 of annual fee) in advance based upon the quarter end value of your account and the type of account. Clients may terminate their advisory contract with the firm in writing, signed receipt required, at any time, and fees will be refunded on a pro-rated basis through the end of the calendar quarter. We may terminate relationships with clients, in writing, upon 30 days notice and will refund fees on a pro-rated basis through the end of the calendar quarter. Your death will not terminate the Investment Management Agreement or authority granted to our firm to charge for management fees until we have received actual written notification of your death. Additional Compensation for the Sale of Securities or Other Investment Products Persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because 5  persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. In an effort to mitigate this conflict of interest, SAM makes every effort to fully understand your needs, and will recommend the purchase of insurance products only to the extent that we feel such a purchase meets those needs. Any commissions that will be paid to a SAM associate in conjunction with such purchases will be disclosed to you in advance of the purchase of an insurance product. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. At our discretion, we may offset our advisory fees to the extent persons associated with our firm earn commissions in their separate capacities as insurance agents. Item 6: Performance-Based Fees and Side-By-Side Management Sharing of Capital Gains or Appreciation We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation from a qualified client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Our fees are calculated as described in the Fees and Compensation section above. Item 7: Types of Clients Description We offer investment advisory services to individuals, including high net worth individuals; pension and profit sharing plans; and corporations. Account Minimums SAM’s minimum opening balance for new individually managed accounts is $100,000. An individual’s personal account, joint account with spouse, spouse’s account, retirement account and spouse’s retirement account can be aggregated for purposes of meeting the minimum opening balance requirement. Smaller accounts may be accepted by SAM, at its discretion, if related to other accounts under management by SAM, or in other unusual circumstances. SAM reserves the right to accept or reject accounts at its sole discretion. We reserve the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to effectively manage. For your benefit, we will also household related accounts; i.e., combining account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum for breakpoints in the sale of investment company shares (mutual fund and exchange traded funds ("ETFs")) which reduce your purchasing costs of such securities. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We may use one or more methods of analysis or investment strategies when providing investment advice to you. We will primarily use Fundamental Analysis. Listed below is information related to the risk(s) related to these methods of analysis. 6  Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. • Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance Investment Strategies Sabre Asset Management, LLC will explore and consider investments in various securities such as mutual funds, exchange traded funds, closed end funds, common stocks, preferred stocks, and corporate, municipal and government issued fixed income securities. Exposure to foreign companies and economies may be employed to take advantage of growth opportunities in other regions of the world. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. • Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Equity Investments When equities are a prudent choice, we attempt to identify the best funds or companies that can be acquired at reasonable prices. When evaluating mutual funds and exchange traded funds a variety of factors will be considered including the underlying portfolio holdings of the fund, the track record and history of the fund manager, and fund expenses. Once a client’s risk profile has been determined and an allocation to equity investments has been decided, SAM will construct a portfolio using a variety of equity securities to adequately diversify the equity portion of the client’s portfolio. Options When markets are volatile, we may use “covered calls” and “protective puts” to protect portfolio profits and enhance portfolio returns. Fixed Income Investments SAM generally uses mutual funds, exchange traded funds and closed end funds to invest in the fixed income markets. In certain cases SAM will consider individual issues of corporate, municipal and government issued debt for client portfolios. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. 7  Risk of Loss SAM’s investment activities may involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by SAM. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of SAM to realize profits. As a result of the nature of SAM’s investing activities, it is possible that the financial performance may fluctuate over time and from period to period. Market or Interest Rate Risk The price of most fixed income securities move in the opposite direction of interest rates. For example, as interest rates rise, the prices of fixed income securities fall. Changes in interest rates will affect the values of fixed income securities Item 9: Disciplinary Information Legal and Disciplinary Registered Investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SAM and the integrity of our management of your assets. We have no information that applies to this item. Criminal or Civil Action Registered Investment advisors are required to disclose all material facts regarding any criminal or civil action events that would be material to your evaluation of SAM and the integrity of our management of your assets. We have no information that applies to this item. Administrative Proceeding Registered Investment advisors are required to disclose all material facts regarding any administrative proceeding that would be material to your evaluation of SAM and the integrity of our management of your assets. We have no information that applies to this item. Self-Regulatory Proceeding Registered Investment advisors are required to disclose all material facts regarding any Self- Regulatory Organization proceedings that would be material to your evaluation of SAM and the integrity of our management of your assets. We have no information that applies to this item. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Registered Representative Registrations The investment advisor representatives of SAM are not registered representatives of a broker dealer. SAM is not affiliated with a broker dealer. Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser or Associated Person SAM and our staff are not affiliated with a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser. Material Relationships or Arrangements with Financial Industry SAM has no other material relationships or arrangements with the financial industry not disclosed elsewhere in this document. 8  Recommend or Select Other Investment Advisers SAM does not recommend or select other investment advisors for our clients. Insurance Affiliations Michael Whalen is licensed as independent an insurance agent. SAM is not an affiliate of any insurance companies. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Recommend Securities with Material Financial Interest SAM and its investment advisor representatives do not have any material financial interest in any public companies. Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Invest in Same Securities Recommended to Clients A SAM staff member may invest in the same securities as recommended to clients under the firm personal trading policy listed below. Personal Trading Practices Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for staff member accounts. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12: Brokerage Practices SAM recommends brokers or dealers to effect portfolio transactions. In doing so, consideration is given to the proven integrity and financial responsibility of the various firms as well as to their demonstrated execution experience and capability generally and in regard to particular markets or securities and to the competitiveness of the commission rates they charge. If a client requests to custody the account at another brokerage firm, SAM will execute transactions through that broker- 9  dealer. You may pay higher commissions and/or trading costs than those that may be available elsewhere. Research and Other Soft Dollar Benefits SAM does not receive non-cash compensation from investment companies, custodians, and third party vendors. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage We routinely recommend that you direct our firm to execute transactions through Charles Schwab. As such, we may be unable to achieve the most favorable execution of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. You may utilize the broker-dealer of your choice and have no obligation to purchase or sell securities through such broker as, we recommend. In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Order Aggregation or Block Trades We do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (the practice of combining multiple orders for shares of the same securities is commonly referred to as "block trading") unless you have given us discretionary authority. Accordingly, you may pay different prices for the same securities transactions than other clients pay. Furthermore, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than other clients. Item 13: Review of Accounts Periodic Reviews Michael Whalen of Sabre Asset Management LLC will monitor your accounts on an ongoing basis and will conduct formal account reviews at least annually or upon your request. The reviews are designed to ensure the advisory services provided to you, and the portfolio mix, are consistent with your stated investment needs and objectives. Review Triggers Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, 10  • market moving events, • security specific events, and/or, • changes in your risk/return objectives. Account Reports You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). You should carefully review those statements promptly when you receive them. Item 14: Client Referrals and Other Compensation Economic Benefits SAM does not receive any compensation other than the compensation discussed in Item 5. There currently are no other arrangements, oral or in writing where it directly or indirectly receives compensation for client referrals. Third Party Solicitors SAM may use, employ, or compensate non-employee (outside) consultants, individuals, and/or entities (Solicitors) for client referrals. If your investment advisor relationship is obtained through a Solicitor, you will receive a Solicitor Disclosure Form that will describe the solicitor relationship and the compensation earned by the Solicitor. Your fee will not increase because of the Solicitor relationship. This form will require you to sign the form acknowledging this relationship. Beyond the disclosures provided in this Brochure, we do not receive any compensation from any third party in connection with providing investment advice to you. Item 15: Custody Sabre Asset Management LLC does not take custody of your funds and securities. Your broker dealer custodian maintains actual custody of your assets. As a result, our firm does not accept securities or forward securities to your brokerage firm or custodian. The only checks accepted as payable to Sabre Asset Management LLC are those submitted for payment of advisory fees. SAM’s Agreement and/or the separate agreement with your Financial Institution may authorize us through such Financial Institutions to debit your account for the amount of our fee and to directly remit that management fee to our firm in accordance with applicable custody rules. Under government regulations, we are deemed to have custody of your assets due to our ability to deduct management fees in accordance with the advisory agreement, but we do not otherwise have any access to client assets. In February 2017, the SEC issued a no-action letter clarifying that standing authority (also known as a standing letter of authorization or “SLOA”) to move money from a client’s account to a third party account is “custody” within the meaning of Investment Advisers Act Rule 206(4)-4 (the “Custody Rule”). The SEC also stated that any accounts that meet the following seven conditions (the SEC refers to them as “representations”) will not be subject to the “independent verification” requirement under Rule 206(4)-2(a)(4), also known as the annual surprise accountant’s examination. As such, our firm has adopted the following seven safeguards in conjunction with our custodian, Charles Schwab: The client provides an instruction to the qualified custodian, in writing, that includes the 1. client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s 11  form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s qualified 4. custodian. The investment adviser has no authority or ability to designate or change the identity of the 5. third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party 6. of the investment adviser or located at the same address as the investment adviser. The client’s qualified custodian sends the client, in writing, an initial notice confirming the 7. instruction and an annual notice reconfirming the instruction. Account Statements The Financial Institutions recommended by our firm have agreed to send a statement to you the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to our firm. In addition, as discussed in Item 13, our firm also sends periodic supplemental reports to clients. You will receive account statements directly from your broker dealer custodian at least quarterly. They will be sent to the email or postal mailing address you provided to your broker dealer. You should carefully review those statements promptly when you receive them. Item 16: Investment Discretion Discretionary Authority for Trading Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement and the appropriate trading authorization form(s). This gives us discretion over the selection of securities, timing when transactions are made and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the Advisory Business section in this brochure for more information on our discretionary management services. Non-Discretionary Agreements - If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Limited Power of Attorney Our firm does not have any limited power attorney accounts. We do not use limited power of attorney to make investments in your account(s). 12  Item 17: Voting Client Securities Proxy Voting Without exception, we will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. You will receive proxy materials directly from the account custodian. Item 18: Financial Information Prepayment of Fees Management fees are charged quarterly (1/4 of annual fee) in advance based upon the quarter end value of your account and the type of account. Additional information is contained in Item 5, “Fees Paid in Advance”. Financial Condition We are not required to provide a balance sheet or other financial information to our clients because we do not require the prepayment of fees in excess of $1,200 and six months or more in advance; we do not take custody of client funds or securities; and, we do not have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. Bankruptcy Moreover, we have never been the subject of a bankruptcy petition. 13  Brochure Supplement (Form ADV, Part 2B) Michael J. Whalen Sabre Asset Management LLC 29525 Chagrin Blvd., Suite 302 Pepper Pike, OH 44122 Telephone Number: (216) 245-6622 Fax Number: (216) 245-6627 Website: https://sabreasset.com June 29, 2026 Item 1: Cover Page information about Michael Whalen is available on the SEC's website at This brochure supplement provides information about Michael Whalen that supplements the Sabre Asset Management LLC. Brochure (Form ADV Part 2A). You should have received a copy of that brochure. Please contact us at (216) 245-6622 if you did not receive the Sabre Asset Management LLC Brochure or if you have any questions about the contents of this supplement. Additional www.adviserinfo.sec.gov. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Sabre Asset Management LLC. is a Registered Investment Adviser. Registration as a "Registered Investment Adviser" does not imply a certain level of skill or training. 14  Item 2: Educational Background & Business Experience Name, Age (Year of Birth) Michael J. Whalen, 57 (1968) Formal Education • John Carroll University, University Heights, OH , BS – Business Administration, 1993 Business Background • Sabre Asset Management LLC – President, 2017 - Present • Raymond James Financial Services, Financial Advisor, 2008 - 2017 • Raymond James & Associates, Financial Advisor, 2005 - 2008 • Morgan Stanley, Financial Advisor, 1996 – 2005 Item 3: Disciplinary Information Legal or Disciplinary Events No information is applicable for this item for Mr. Whalen. Criminal or Civil Action There is no material information that is applicable for this item for Mr. Whalen. Administrative Proceeding No information is applicable for this item for Mr. Whalen. Self-Regulatory Organization Proceeding No information is applicable for this item for Mr. Whalen. Other Proceeding No information is applicable for this item for Mr. Whalen. Item 4: Other Business Activities Investment-related Activities Mr. Whalen is an insurance agent and may be licensed with various insurance companies. In his capacity as a licensed insurance agent, he may offer insurance to the Company’s advisory Clients. If the Client elects to purchase insurance products through Mr. Whalen as an independent insurance agent, he may earn commissions from the sale of insurance. This may be a potential conflict of interest because the he could receive fees for the advice and also receive commissions as an insurance agent for implementing insurance transactions. The Client is not obligated to implement the advice provided by Mr. Whalen to implement transactions in his separate capacity as an insurance agent. The firm does not offer insurance products as part of its activities as a Registered Investment Adviser. Other Business or Occupation for Compensation Mr. Whalen has no other business or occupation for compensation. 15  Item 5: Additional Compensation Economic Benefit Mr. Whalen does not receive any additional compensation from non-clients for providing investment services. Item 6: Supervision Describe Supervision For activities of Sabre Asset Management LLC., Mr. Whalen is the senior officer and is not directly supervised by anyone and is responsible for his own supervision. Mr. Whalen monitors his advice in an effort to ensure investments are suitable for his individual clients and consistent with their individual needs, goals, investment objectives and risk tolerance, as well as any restrictions requested by a SAM client. Name, Title and Telephone Number of Supervisor Not Applicable for Mr. Whalen. 16