Aspen Grove Capital, LLC (referred to as “we,” “our,” “us,” or “Aspen Grove”) was formed in March 2011. Our principal owner is Jeffrey C. Kirwood. Aspen Grove is a multi-family office that provides a trusted and holistic approach to investment management services across multiple asset classes. Generally, our client relationships are guided by an investment policy for each family. The investment policy is highly customized and aligned to each family’s risk appetite, lifestyle needs and long-term wealth creation and wealth transfer goals. Aspen Grove monitors and facilitates the subscription and redemption process and process of cash flows, such as capital gains or dividends, with regards to client assets invested in private funds advised by Aspen Grove and third-party managers. Clients pay fixed fees for this service as described in Item 5. If requested by the client, Aspen Grove also provides bill payment and the coordination of professional and other services (i.e., legal, insurance, home repair, public relations). In addition, Aspen Grove offers asset-based fee services for clients who do not utilize Aspen Grove’s bill paying, third party manager selection, and coordination of professional and other services. In these circumstances, Aspen Grove selects and manages exchange-traded securities and bonds. Clients may impose restrictions on the investments we make. IRA Rollover Recommendations: For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, Aspen Grove is providing the following acknowledgment to clients. When Aspen Grove provides investment advice to clients regarding retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Aspen Grove makes money creates some conflicts with client interests, so we operate under a special rule that requires Aspen Grove to act in clients’ best interest and not put our interest ahead of yours. Under this special rule’s provisions, Aspen Grove must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our

financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Aspen Grove is the investment advisor to private investment funds (“Private Funds”) and provides discretionary and non-discretionary investment advisory services to separately managed accounts. Aspen Grove provides clients with the opportunity to invest in one or more Private Funds that seek to achieve their objective by deploying assets among a select group of third-party investment managers that generally conduct their investment programs through unregistered, pooled investment vehicles (“Funds”). This allows clients to invest with investment managers whose Funds will be closed from time to time to new investors or that otherwise typically place stringent restrictions on the minimum investment requirements that these investment managers typically would impose. Private Funds advised by Aspen Grove are not offered or sold to the public. They are accessible only to our clients who are “Accredited Investors” as defined in Regulation D under the Securities Act of 1933 who receive an operating agreement issued by the Private Fund and who ultimately become parties to the agreement governing the operations of the Private Fund. The terms and conditions for participation in each Private Fund, including expenses, conflicts of interest and risk factors, are set forth in the respective Private Fund’s offering documents. As a registered investment advisor subject to Section 206 of the Advisers Act, Aspen Grove acts as a Fiduciary related to the conduct of its investment advisory services. As such Aspen Grove has an obligation to act in the best interest of its clients guided by the core fiduciary duties of loyalty and care. Assets under management As of 12/31/2023, we were actively managing $4,048,807,494 of clients’ assets on a discretionary basis and $1,190,707,997 on a non-discretionary basis. The total amount of regulatory assets under management were $5,239,515,491.