Legal Notices & Disclosures

Effective Date: July 1, 2026 · Last Updated: July 1, 2026

1. General Notice

The information on this website (the "Site") is published by AspireFunds, LLC and its affiliates and managed fund vehicles (collectively, "AspireFunds") for general informational purposes only. It is not intended as, and should not be relied upon as, investment, legal, tax, or accounting advice. Prospective investors and borrowers should consult their own advisors before making any decision based on Site content.

2. No Offer of Securities

The interests in AspireFunds fund vehicles have not been and will not be registered under the Securities Act or the securities laws of any state, and none of the funds is registered as an investment company under the Investment Company Act of 1940, as amended, in reliance on Section 3(c)(7) or another applicable exclusion. Neither the U.S. Securities and Exchange Commission ("SEC") nor any state securities regulator has approved or disapproved these interests or passed upon the accuracy or adequacy of any Offering Document.

3. Accredited & Qualified Investors Only

Interests in AspireFunds funds are offered only to persons who qualify as "accredited investors" as defined in Rule 501(a) of Regulation D and, where applicable, "qualified purchasers" as defined in Section 2(a)(51) of the Investment Company Act. Prospective investors will be required to make certain representations and provide supporting documentation before subscribing. AspireFunds reserves the right to reject any subscription in its sole discretion.

4. Investment Risk Disclosures

An investment in an AspireFunds fund involves a high degree of risk, including the risk of loss of the entire investment. Risks include, without limitation:

• Illiquidity: interests are subject to substantial transfer restrictions; there is no public market for the interests and none is expected to develop.
• Credit risk: borrower default, prepayment, or workout outcomes may materially affect fund performance.
• Real estate risk: value of collateral is subject to market, economic, environmental, geographic, and interest-rate conditions.
• Leverage risk: use of leverage or warehouse facilities may amplify losses.
• Interest-rate risk: changes in interest rates may adversely affect fund cash flows, net interest margin, and asset valuations.
• Concentration risk: fund portfolios may become concentrated by geography, sponsor, asset type, or loan program.
• Regulatory risk: changes in federal or state banking, securities, consumer-lending, or tax law may materially affect operations and returns.
• Reliance on key personnel: the loss of Alexandra Pohl or other key personnel could adversely affect the funds.

A complete description of risk factors will be set forth in the applicable Offering Documents, which prospective investors should read in full before investing.

5. Performance and Target Returns

Any performance information presented on the Site, including target returns, projected internal rates of return, target preferred returns, and hypothetical results, is provided for illustrative purposes only. Targets and projections reflect assumptions and estimates by AspireFunds that are inherently subject to significant business, economic, competitive, and market uncertainties and contingencies, many of which are beyond our control. Actual results may vary materially from projections. Past performance is not indicative of future results.

6. Forward-Looking Statements

The Site contains "forward-looking statements" within the meaning of Section 27A of the Securities Act and Section 21E of the Securities Exchange Act of 1934, including statements about AspireFunds' investment strategy, capital deployment plans, target returns, projected fund size, and anticipated growth. Words such as "expects," "believes," "anticipates," "intends," "plans," "targets," "projects," and similar expressions identify forward-looking statements. These statements are not guarantees of future performance and involve risks and uncertainties. AspireFunds undertakes no obligation to update any forward-looking statement, except as required by law.

7. Lending & Consumer Notices

AspireFunds' managed fund vehicles engage primarily in commercial real estate lending and specialty finance for business purposes. Most loans are business-purpose loans and are not subject to the federal Truth in Lending Act (15 U.S.C. § 1601 et seq.), Real Estate Settlement Procedures Act ("RESPA"), or comparable consumer-finance protections. Where a loan is consumer purpose or otherwise regulated at the state level, AspireFunds and its servicers comply with applicable licensing, disclosure, and servicing requirements, including any applicable state mortgage-lending, small-business truth-in-lending, and fair-lending laws.

Equal Credit Opportunity. AspireFunds does not discriminate on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to contract), receipt of public assistance income, or the good-faith exercise of any right under the Consumer Credit Protection Act, in any aspect of a credit transaction, consistent with the Equal Credit Opportunity Act (15 U.S.C. § 1691) and its implementing regulation (Regulation B, 12 C.F.R. Part 1002).

8. Investment Adviser Status

Certain AspireFunds affiliates may be, or may become, registered as investment advisers with the SEC or with one or more state securities regulators. If and when AspireFunds Capital Management, LLC (or another affiliate) is required to register, its Form ADV Part 1, Part 2A (brochure), Part 2B (brochure supplement), and Part 3 (Form CRS) will be available through the SEC's Investment Adviser Public Disclosure system at adviserinfo.sec.gov and upon request from AspireFunds. Registration does not imply a certain level of skill or training.

9. AML, KYC, Sanctions, and Beneficial Ownership

AspireFunds and its fund administrators conduct customer identification, know-your-customer, source-of-funds, and sanctions-screening procedures consistent with the Bank Secrecy Act, USA PATRIOT Act, OFAC-administered sanctions, and the Corporate Transparency Act. Subscription may be delayed or rejected pending satisfactory diligence. Certain beneficial-ownership information may be reported to FinCEN as required by law.

10. Conflicts of Interest

AspireFunds, its affiliates, and its personnel may have relationships or engage in activities that give rise to actual or potential conflicts of interest, including allocation of investment opportunities among funds and accounts, cross-fund transactions, related-party service providers, and personal investments by principals. Material conflicts and mitigation practices are disclosed in the applicable Offering Documents and, where applicable, in Form ADV Part 2A.

11. Tax Matters

Nothing on the Site is intended or written to be used, and cannot be used, by any person for the purpose of avoiding U.S. federal, state, or local tax penalties. Prospective investors should consult their own tax advisors regarding the tax consequences of an investment in an AspireFunds fund based on their particular circumstances.

12. Trademarks & Copyright

"AspireFunds," "AspireFundsBank," the AspireFunds logo, and related marks are trademarks of AspireFunds, LLC. All content on the Site is © 2026 AspireFunds, LLC, all rights reserved, except as otherwise noted. Unauthorized use is prohibited.

13. Contact for Compliance Matters

AspireFunds — Compliance
1910 Pacific Ave, Suite 2000
Dallas, TX 75201
[email protected]
972.945.5050