Firm Description Empirical Asset Management, LLC (“EAM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is located in the Commonwealth of Massachusetts and is organized as a limited liability company (“LLC”) under the laws of the State of Delaware. EAM was founded in July of 2010 and began accepting client accounts on January 1, 2011. Mark H. Fiskio is the founder, Managing Partner and Principal Owner of EAM. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by EAM. Types of Advisory Services EAM offers investment management services to individuals, high net worth individuals, trusts, estates, pooled investment vehicles, charitable organizations, businesses, institutions, retirement plans, and other investment advisors (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. EAM’s fiduciary commitment is further described in the Advisor 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 EAM provides investment management services to Clients, which is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. EAM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a strategy. EAM will construct a customized investment portfolio, consisting of low-cost, diversified exchange-traded funds (“ETFs”) and/or mutual funds, individual stocks, bonds or alternative investment vehicles to meet the needs of its Clients. Additionally, the Advisor may utilize Rules Based Investing® (“RBI”) methodology and in such instances, will place Client assets into one of EAM’s proprietary models. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. EAM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client, due to market conditions or to comply with the trading policies of an EAM investment strategy. EAM 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 Advisor. EAM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. EAM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. EAM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. EAM 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. 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 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 – When deemed to be in the Client’s best interest, EAM will recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes the appropriate disclosures).

All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the Client investment advisory agreement, please see Item 12 – Brokerage Practices. Private Fund Advisor Services EAM also serves as the investment manager to the Empirical Long Short Fund, LP (the “Fund”). The general partner to the Fund is Empirical Fiscal Partners, LLC (“EFP”), an affiliated entity under common control an ownership with the Advisor. The services to the Fund are detailed in the offering documents for the Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor manages the Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in the Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Fund are not permitted to impose restrictions or limitations. However, the Advisor may enter into side letter agreements with one or more investors that may alter, modify, or change the terms of interest held by investors. Certain types of side letters create a conflict of interest between the Advisor and the investors in the Fund, and/or between investors themselves. The Advisor will recommend that certain Clients invest in the Fund. The recommendation to invest in the Fund poses a conflict between the interests of the Advisor and the interests of the Client, as the Advisor is incentivized to increase the amount of assets in the Fund in order to increase the revenue generated to EAM. This conflict is mitigated as Clients will pay fees in accordance with the offering documents and will not pay any investment advisory fees to the Advisor on assets invested in the Fund. Clients of the Advisor are under no obligation to invest in the Fund. For more detailed information on investment objectives, policies and guidelines, please refer to the Fund’s Offering Documents. Retirement Plan Advisory Services EAM provides advisory services to retirement plans (each a “Plan”) and the company sponsor (the “Plan Sponsor”). The Advisor’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 may include:
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendations and Assistance
• Benchmarking Services Certain of these services are provided by EAM serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of EAMs fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Institution Consulting Services EAM provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with EAM. Client Account Management Prior to engaging EAM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – EAM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – EAM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – EAM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – EAM will provide investment management and ongoing oversight of the Client’s investment portfolio. Wrap Fee Program In certain instances, EAM may include securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the EAM Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. For a copy of the Advisors Wrap Fee Program Brochure please contact the Advisor by phone at 781-431-2223 or by email at mfiskio@empiricalam.com. Assets Under Management As of December 31, 2023, EAM manages $328,685,091 in Client assets, $316,771,385 of which are managed on a discretionary basis and $11,913,706 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. In addition, as of December 31, 2023, the Advisor also has $16,235,441 in assets under advisement (“AUA”), attestable to ongoing consulting services provided to Clients of the Advisor. Clients may request more current information at any time by contacting the Advisor.