A. Firm Information Aspire Capital Advisors LLC (“Aspire Capital” or the “Adviser”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The Adviser is organized as a Limited Liability Company (“LLC”) under the laws of the State of Washington. Aspire Capital was founded in August 2018 and became a registered investment adviser in October 2018. The Advisor conducts business under the practice names (“doing business as” or “dba” name), Kirkland Financial Advisers, AFG Financial, and Sound Financial Investments, Inc. Aspire Capital is owned and operated by John A. Flavin (Managing Principal and Chief Compliance Officer) and Shannon Crotty Flavin (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Aspire Capital. B. Advisory Services Offered Aspire Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Adviser serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Aspire Capital’s fiduciary commitment is further described in the Adviser’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Aspire Capital provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Aspire Capital works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to develop an investment strategy for the Client’s investment portfolio[s]. Aspire Capital typically constructs portfolios utilizing low-cost, diversified mutual funds and exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Adviser may also utilize individual stocks, individual bonds or other types of investments, as appropriate, to meet the needs of the Client. The Adviser may retain certain types of investments based on a Client’s legacy portfolio construction to avoid tax implications or unnecessary trading costs. Aspire Capital’s investment approach is primarily long-term focused, but the Adviser may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Aspire Capital will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Adviser. Aspire Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Aspire Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Aspire Capital may recommend specific positions to increase sector or asset class weightings. Aspire Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Aspire Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Page 5 Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers Aspire Capital will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure

the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services Aspire Capital will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Aspire Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Adviser will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Adviser may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Adviser and the interests of the Client. For example, the Adviser has an incentive to recommend that Clients engage the Adviser for investment management services or to increase the level of investment assets with the Adviser, as it would increase the amount of advisory fees paid to the Adviser. Clients are not obligated to implement any recommendations made by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects to act on any of the recommendations made by the Adviser, the Client is under no obligation to implement the transaction through the Adviser. Retirement Plan Advisory Services Aspire Capital provides advisory services on behalf of company retirement plans (each a “Plan”) and the company’s sponsor (the “Plan Sponsor”). The Adviser’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Page 6
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Ongoing Investment Recommendation and Assistance These services are provided by Aspire Capital serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The Adviser serves as a fiduciary to Clients, as defined under the Securities Act of Washington and other applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate conflicts of interest. While the Adviser may have specific responsibilities under ERISA to disclose the Adviser’s fiduciary separately from its non-fiduciary services, this disclosure does not limit the Adviser’s fiduciary responsibility to Clients. Further, in accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Aspire Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Adviser reasonably expects under the engagement. C. Client Account Management Prior to engaging Aspire Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities of the Adviser and the Client. These services may include:
• Establishing an Investment Strategy – Aspire Capital, in connection with the Client, will develop an investment strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Aspire Capital will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – Aspire Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Aspire Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Aspire Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Aspire Capital. E. Assets Under Management As of December 31, 2023 Aspire Capital manages $817,666,295 in Client assets, $817,531,123 of which are managed on a discretionary basis and $135,172 are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Adviser.