CLP ASSET MANAGEMENT, LLC

Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page CLP Asset Management, LLC 8901 Firetower Road Ooltewah, TN 37363 Tel: (630) 272-6321 March 20, 2025 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of CLP Asset Management, LLC. If you have any questions about the contents of this brochure, please contact us at (630) 272-6321. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about CLP Asset Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CLP Asset Management, LLC is 305962. CLP Asset Management, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Form ADV, Part 2A, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (630) 272-6321. Material Changes since the Last Update CLP Asset Management, LLC was established as a Registered Investment Advisor in August 2021 with the Securities and Exchange Commission (“SEC”), under the rules and regulations of the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). There have been the following material changes since the Firm’s last Annual Update Filing on March 19, 2024: • Fee range was amended to reflect a maximum asset based fee rate of 1.50% per annum. 2  Form ADV, Part 2A, Item 3 Table of Contents Item 1 - Cover Page……………………………………………………………………………1 Item 2 - Material Changes…………………………………………………………………….2 Item 3 - Table of Contents……………………………………………………………………3 Item 4 - Advisory Business…………………………………………………………… ......... 4 Item 5 - Fees and Compensation…………………………………………………….. ........ 5 Item 6 - Performance-Based Fees and Side-By-Side Management……………. ........ 6 Item 7 - Types of Clients………………………………………………………………. ......... 7 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss……… ........ 7 Item 9 - Disciplinary Information…………………………………………………….. ......... 9 Item 10 - Other Financial Industry Activities and Affiliations……………………. ....... 9 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading……………………………………………………………… …………………10 Item 12 - Brokerage Practices………………………………………………………….. .... 11 Item 13 - Review of Accounts………………………………………………………….. .... 12 Item 14 - Client Referrals and Other Compensation……………………………….. .... 12 Item 15 - Custody………………………………………………………………………… ..... 12 Item 16 - Investment Discretion……………………………………………………….. ..... 13 Item 17 - Voting Client Securities……………………………………………………… .... 13 Item 18 - Financial Information………………………………………………………… .... 14 Item 19 - Requirements for State-Registered Advisers…………………………… ..... 14 ADV Part 2B…………………………………………………………………………………………………………………….14 3  Form ADV Part 2A, Item 4 Advisory Business CLP Asset Management, LLC (hereinafter called “CLP”) is an investment adviser based in Ooltewah, Tennessee, and incorporated under the laws of the State of Delaware. CLP is owned by Joshua Luff, Jonathan Thiel, and Richard Losiniecki. CLP is registered with the U.S. Securities and Exchange Commission (“SEC”) and is subject to the rules and regulations of the U.S. Advisers Act. Founded in October 2019, CLP provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. CLP provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with CLP. Managed Accounts are available to individuals. CLP provides discretionary and non-discretionary investment advisory services to some of its clients through various managed account programs. CLP will assist clients in determining the suitability of the Managed Account Programs for the client. The IAR is compensated through a comprehensive single fee and the account may be assessed other charges associated with conducting a brokerage business. CLP and its IAR, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections • Providing Firm Brochure (this document) As of February 6, 2025, the firm has $127,700,000 discretionary assets under management and $0 non-discretionary assets under management. 4  Form ADV, Part 2A, Item 5 Fees and Compensation One or both of the following types of fees will be assessed: Wealth Management – Fees are charged in advance and are based primarily on asset size and the level of complexity of the services provided. In individual cases, CLP has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the market value of the assets on the last business day of the previous quarter. Annual fees are negotiable but will not exceed 1.50% – See chart below. Fee Schedule for Asset Management: Total Account Value Maximum Annual Advisory Fee All assets 1.50% As authorized in the client agreement, the account custodian withdraws CLP Asset Management, LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodial statement includes the amount of any fees paid to CLP for advisory services. You should carefully review the statement from your custodian/broker- dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not verify the accuracy of fee calculations. In addition to asset-based fees, certain clients may pay fixed fees which are on a negotiated basis between the firm and the client. Just as with the asset- based fee clients, those paying fixed fees will have the terms associated with that arrangement described in the client agreement. While all advisory fees, including asset-based fees, are negotiable, at no point would the asset-based fee exceed 1.50% per annum. No changes to client fees will take place without clients’ written authorization. Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the quarter. Clients may terminate investment advisory services obtained from CLP, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with CLP. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by CLP. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of CLP’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. 5  Financial Planning / Consultation – For clients choosing to be billed based on a flat fee basis, those fixed fees may range from $10,000 to $500,000 and may be assessed on an ongoing basis for ongoing services. These fees are negotiated between CLP and the Client. Additional Fees and Expenses In addition to advisory fees paid to CLP as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask CLP for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. CLP does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with CLP and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of CLP or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive CLP’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. Please refer to Item 12 “Brokerage Practices” of this brochure for additional information. Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management CLP Asset Management, LLC does not charge performance-based fees or participate in side-by- side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and 6  Compensation section above, and are not charged on the basis of performance of your advisory account. Form ADV, Part 2A, Item 7 Types of Clients CLP offers investment advisory services to individuals. There is a $5,000,000 minimum account size to open and maintain an advisory account. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss CLP’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. CLP is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there 7  can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. CLP’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. CLP’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e., individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. CLP’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments 8  that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. CLP has no control over the risks taken by the underlying funds. Form ADV, Part 2A, Item 9 Disciplinary Information CLP Asset Management, LLC or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations Joshua Luff, part owner and sole IAR of CLP, is not currently registered with any broker dealer. Neither CLP nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Joshua Luff, Partner of CLP, is also an indirect minority owner of WatersEdge Management, LLC (“WatersEdge”), a Family Office of one of the other owners. WatersEdge serves as General Partner to two private Funds. Joshua Luff is the CEO of WatersEdge Management however he does not receive any compensation directly from WatersEdge. WatersEdge pays CLP Asset Management for services rendered in offering investment and wealth management advice for the 9  Family Office. WatersEdge funds are not publicly available, but rather are only offered to members of a specific Family Office. Joshua Luff is a partial owner of CLP Investments, LLC (CLPLLC). CLPLLC may be recommend an investment in certain Funds to its clients. The relationship between CLP and CLPLLC may create a conflict of interest because CLP may be incentivized to recommend an investment in the Fund to generate revenue for itself. This conflict is mitigated by the fact that CLPLLC does not charge ongoing management fees to its investors, and CLP does not charge for the management of funds that its clients invest in CLPLLC. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CLP’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of CLP’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with CLP Asset Management, LLC are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. CLP and its employees may buy or sell securities that are also held by clients. It is the expressed policy of the advisor that no person employed by our firm purchase or sell any security prior to the transaction being implemented for an advisory account; therefore, preventing such employees from benefiting from transactions placed on behalf of the advisory clients. The advisor does not have, nor plans to have, an interest or position in a security which is then also recommended to the client. As these situations may present a conflict of interest, the advisor has established the following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise: 1. A director, officer or employee of the advisor shall not buy or sell a security for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of CLP shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. The advisor requires that all employees must act in accordance with all applicable Federal and State regulations governing registered investment advisors. 4. The advisor may block personal trades with those of clients but will ensure that clients are not at a disadvantage. CLP’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Joshua Luff at (630) 272-6321. 10  Form ADV, Part 2A, Item 12 Brokerage Practices In order for CLP to provide asset management services, we request you utilize the brokerage and custodial services of Charles Schwab & Co., Inc. (“Schwab”), for which we have an existing relationship. CLP and Schwab are not affiliated companies. In considering which independent qualified custodian will be the best fit for CLP’s business model, we are evaluating the following factors, which is not an all-inclusive list:  Financial strength  Reputation  Reporting capabilities  Execution capabilities  Pricing, and  Types and quality of research While you are free to choose any broker-dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker-dealers, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions for your account. If you do so, you are responsible for negotiating the terms and arrangements for the account with that broker-dealer. We may not be able to negotiate commissions, obtain volume discounts, or best execution. In addition, under these circumstances a difference in commission charges may exist between the commissions charged to clients who direct us to use a particular broker or dealer and other clients who do not direct us to use a particular broker or dealer. CLP does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. When CLP buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions. No client is favored over any other client. If an order is not completely filled, it is allocated pro-rata based on an allocation statement prepared by CLP prior to placing the order. Because of an order’s aggregation, some clients may pay higher 11  transaction costs, or greater spreads, or receive less favorable net prices on transactions than would otherwise be the case if the order had not been aggregated. Form ADV, Part 2A, Item 13 Review of Accounts Client accounts are reviewed at least quarterly by Joshua Luff, Principal Executive Officer of the firm. Joshua Luff reviews clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at CLP are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Joshua Luff, Principal Executive Officer of the firm. There is only one level of review and that is the total review conducted to create the financial plan. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. Form ADV, Part 2A, Item 14 Client Referrals and Other Compensation CLP does not compensate any individual or firm for client referrals. In addition, CLP does not receive compensation for referring clients to other professional service providers. Form ADV, Part 2A, Item 15 Custody CLP does not have physical custody of any client funds and/or securities, and client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, CLP is technically considered to have custody of certain assets, as Joshua Luff, Principal Executive Officer, also works for a family office that grants him the authority to sign for and transfer funds, for those clients. As a result, the firm is required to have an annual surprise examination. Clients will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will 12  indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. Standing Letters of Authorization Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Form ADV, Part 2A, Item 16 Investment Discretion Before CLP can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. 13  Form ADV, Part 2A, Item 18 Financial Information CLP is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. Form ADV, Part 2A, Item 19 Requirements for State-Registered Advisers This section is not applicable as the firm is SEC registered. 14  Form ADV, Part 2B, Item 1 Cover Page Joshua Luff 8901 Firetower Road Ooltewah, TN 37363 Phone: (630) 272-6321 March 12, 2025 FORM ADV PART 2 BROCHURE SUPPLEMENT This brochure supplement provides information about Joshua Luff that supplements the CLP Asset Management, LLC brochure. You should have received a copy of that brochure. Please contact Joshua Luff if you did not receive a CLP Asset Management, LLC’s brochure or if you have questions about this supplement. Mr. Luff’s CRD number is 5899228. Additional information about Joshua Luff is also available on the SEC’s website at www.adviserinfo.sec.gov. 15  Form ADV, Part 2B, Item 2 Educational Background and Business Experience Joshua Luff CLP Asset Management, LLC Year of Birth: 1981 Business Background: CLP Asset Management, LLC, Owner/CCO, October 2019 – Present Wayne Hummer Investments LLC, Senior Portfolio Manager, June 2014 – August 2019 Educational Background: Indiana University, Bachelor of Science in Finance, Graduated: 2003 DePaul University, Master of Business Administration, Graduated: 2008 Relevant Designations CHARTERED FINANCIAL ANALAYST® (CFA®) A Chartered Financial Analyst (CFA) is a professional designation given by the CFA Institute, formerly AIMR, that measures the competence and integrity of financial analysts. Candidates are required to pass three levels of exams covering areas such as accounting, economics, ethics, money management and security analysis. Before you can become a CFA charter holder, you must have four years of investment/financial career experience and hold a bachelor's degree. Successful candidates take an average of four years to earn their CFA charter. The program covers a broad range of topics relating to investment management, financial analysis, stocks, bonds and derivatives, and provides a generalist knowledge of other areas of finance. The CFA charter is one of the most respected designations in finance, considered by many to be a gold standard in the field of investment analysis. Form ADV, Part 2B, Item 3 Disciplinary Information Mr. Luff does not have any reportable disciplinary disclosures. 1  Form ADV, Part 2B, Item 4 Other Business Activities WatersEdge funds are not publicly available, but rather are only offered to members of a specific Family Office. As noted previously in Item 10, Joshua Luff does not receive any compensation directly from WatersEdge. However, Joshua Luff does receive indirect compensation since WatersEdge pays CLP Asset Management for services rendered in offering investment and wealth management advice for the Family Office. This indirect compensation does create a conflict; however, Joshua Luff commits to the fiduciary standard in his dealings with advisory clients and puts their interests first. WatersEdge is not available to the public, and only to direct family members of the Family Office. Joshua Luff is a partial owner of CLP Investments, LLC (CLPI), a “fund of funds.” CLPI may recommend an investment in certain Funds to its clients. The relationship between CLP and CLPLLC may create a conflict of interest because CLP may be incentivized to recommend an investment in the Fund to generate revenue for itself. This conflict is mitigated by the fact that CLPLLC does not charge ongoing management fees to its investors, and CLP does not charge for the management of funds that its clients invest in CLPLLC. Form ADV, Part 2B, Item 5 Additional Compensation Joshua Luff does not receive any economic benefit from anyone, who is not a client, for providing advisory services. Form ADV, Part 2B, Item 6 Supervision CLP Asset Management, LLC has written supervisory procedures in place that are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations of the Securities and Exchange Commission and the U.S. Advisers Act. Mr. Luff is CLP Asset Management, LLC’s Chief Compliance Officer and the sole Investment Advisory Representative (“IAR”) of the firm, therefore he is responsible for all of the activities that occur on behalf of CLP Asset Management, LLC and its clients. Mr. Luff can be reached at (630) 272-6321. Form ADV, Part 2B, Item 7 Requirements for State-Registered Advisers This section is not applicable as the firm is SEC registered. 2