Asio Capital LLC (“Asio Capital”, “we”, “our”, “us”) is an SEC-registered investment adviser with its principal place of business located in Kentucky. Asio Capital began conducting business in 2018. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• John Carroll Cheshire III, Member
• Ryan Tracy Osborne, Member Asio Capital’s Chief Compliance Officer (“CCO”) is Jared Calvert. Asio Capital offers the following advisory services to our clients: PORTFOLIO MANAGEMENT Our firm provides asset management for client accounts based on the individual needs of the client. Through personal discussions in which a client’s goals and objectives are established, we develop the client's personal investment policy. We create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client's prior investment history, as well as family composition and background. Our services will typically include, to the extent specifically requested by the client, a review of each client's financial situation, including tax planning, education planning, retirement planning, and estate planning. These services are part of our portfolio management services and are not offered on a stand-alone basis. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and we may provide advice regarding any type of securities. However, generally we use the following securities in creating client’s portfolios:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Municipal securities
• Mutual fund shares
• Exchange-traded funds (ETFs)
• United States governmental securities While we will offer advice on any investment held by a client, recommendations for new investments are typically limited to those listed above. Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Part 2A of Form ADV 5 Asio Capital, LLC RETIREMENT PLAN SERVICES We offer retirement plan sponsors with discretionary management of defined benefit and defined contribution plans, and we provide services to the client as we would under our Portfolio Management offering. Where we agree to provide discretionary Portfolio Management services to a plan covered by ERISA, we acknowledge that we are a “fiduciary” and “investment manager” within the meaning of Sections 3(21) and 3(38) of ERISA, respectively. We also may serve as consultants to participant-directed retirement plan sponsors in assisting them with their selection of other service providers for their plans. In such engagements, we will generally consult with the plan sponsor and refer the plan to service providers for the provision of recordkeeping, administrative, investment option selection, and other plan services, while remaining available to the plan for ongoing consultative services. PARTICIPANT ACCOUNT SERVICES Asio Capital uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of a client’s funds since we do not have direct access to the client’s log-in credentials to affect trades. We are not affiliated with the platform and receive no compensation from them for using their platform. A link is provided to the client, allowing them to connect an account(s) to the platform. Once a client’s account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance.

Assets Under Management: As of 12/31/2023, we managed approximately $499,551,795 of client assets on a discretionary basis and $0 of client assets on a non-discretionary basis. MISCELLANEOUS DISCLOSURES Limitations of Financial Consulting. To the extent requested by a client, we may provide financial consulting services regarding investment and non-investment related matters, such as estate planning, tax planning, retirement planning, insurance, etc. We do not serve as a law firm, accounting firm, or insurance agency, and no portion of our services should be construed as legal, accounting, or insurance implementation services. Accordingly, we do not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by us or our representatives. Please Note: If the client engages any professional, recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s) shall be responsible for the quality and competency of the services provided. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted; (iii) roll over to an Individual Retirement Account (“IRA”); or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement plan assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn a new (or increase our current) advisory fee as a result of the rollover. No client is under any obligation to roll over Part 2A of Form ADV 6 Asio Capital, LLC retirement plan assets to an account managed by us. Portfolio Activity. We have a fiduciary duty to provide services consistent with the client’s best interest. As part of our investment advisory services, we will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when we determine that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Positions. We may maintain cash and cash equivalent positions (such as money market funds) for defensive and liquidity purposes. Unless otherwise agreed in writing, all cash and cash equivalent positions will be included as part of assets under management for purposes of calculating our investment advisory fee. Client Obligations. In performing our services, we shall not be required to verify any information received from the client or from the client’s other designated professionals, and we are expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and/or services. Disclosure Statement. A copy of our written disclosure statement as set forth on Part 2 of Form ADV shall be provided to each client before or at the time they enter an Investment Management Agreement with Asio Capital.