9AT: BOULDER ASSET MANAGEMENT

Adviser Profile

As of Date	03/28/2025
Registration	SEC, Approved, 06/21/1991
ADV Location	ENGLEWOOD, CO, United States
Contact Info	303 xxxxxxx

AUM^*	426,099,643 0%
of that, discretionary	426,099,643 15%
Number of Employees	4
of those in investment advisory functions	1 -50%
Private Fund GAV^*	0
Avg Account Size	2,393,818 47%
% High Net Worth	100.00%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- High net worth individuals

Advisory Activities

- Portfolio management for individuals and/or small businesses

Compensation Arrangments

- A percentage of assets under your management
- Fixed fees (other than subscription fees)

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser ESSEX RIDGE CAPITAL GROUP, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM146.3m	#Funds-
Adviser WESTPORT ASSET MANAGEMENT INC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM396.8m	#Funds-
Adviser ST. NICHOLAS PRIVATE ASSET MANAGEMENT, INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM151.0m	#Funds-
Adviser RM PRIVATE WEALTH MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM340.9m	#Funds-
Adviser TAIKO	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM5.1b	#Funds-
Adviser NAMTAF ADVISORS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM159.3m	#Funds-
Adviser ENVISION CAPITAL MANAGEMENT INC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM334.1m	#Funds-
Adviser SUSTAINABLE LEADERS INVESTMENT MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM79.9m	#Funds-
Adviser DUBEAU CAPITAL USA INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM47.9m	#Funds-
Adviser RETURN ADVISORS INC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM49.7m	#Funds-

Brochure Summary

Overview

Stark Asset Management, Inc. is an S Corporation doing business as Boulder Asset Management. We offer investment advice to a limited number of qualified investors. Our goal is to tailor each portfolio to preserve wealth through growth of capital and income and to teach investors more about their own investments. Stark Asset Management, Inc. (“Stark Asset Management”) was founded in 1984 by Richard J. Stark, CFA, and was first registered with the SEC in 1991. Mr. Stark continues to manage the company, which he owns with Linda J. Stark. As of December 31, 2023, Stark Asset Management had $424,664,108 of discretionary client assets under management. We are not currently providing services on a non-discretionary basis. We believe preserving and continuing to build wealth requires the selection and retention of long-term investments. This strategy avoids the high cost of excessive transactions and taxes created by market timing. The percentage that we allocate to each asset class (stocks, fixed income and cash reserves) reflects client income needs and tolerance for portfolio volatility. Our investment philosophy for equity securities is to concentrate selection in a limited number of investment themes whose time horizon

can vary in length. Individual issues are purchased with the intent of creating a portfolio with a five-year time horizon. Some of our investment themes are top-down-driven by economic factors. However, most themes evolve on a bottom-up basis as a number of attractive stocks actually define economic segment or industry. For example, themes can be based on demographics, new product cycles, the direction of interest rates, commodity cycles, capitalization cycles, beta, dividend yield, etc. We invest in fixed income securities with a focus on the income and stability needs of the individual client. Cash reserves are used to provide liquidity. Our focus at Stark Asset Management is on client service with an emphasis on education. On a quarterly basis, clients are updated on their portfolio’s performance and structure, Stark Asset Management’s economic and investment outlook, and are provided custom-tailored reports showing the clients investment positions, actual income to date, and a value-added analysis. In addition, we contact clients on a regular basis, generally quarterly, to monitor client objectives, discuss the current portfolio, and increase the client’s understanding of the investment holdings. 5 |

BOULDER ASSET MANAGEMENT

BOULDER ASSET MANAGEMENT

STARK RICHARD JOSEPH

STARK ASSET MANAGEMENT

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

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BOULDER ASSET MANAGEMENT BOULDER ASSET MANAGEMENT STARK RICHARD JOSEPH STARK ASSET MANAGEMENT

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

BOULDER ASSET MANAGEMENT

BOULDER ASSET MANAGEMENT

STARK RICHARD JOSEPH

STARK ASSET MANAGEMENT