The Firm: Aspiration was founded on October 31, 2013, and is headquartered in Marina del
Rey, California. It is a privately held limited liability company and a wholly owned subsidiary of
Aspiration Partners, Inc. Timothy Newell assumed the role of Chief Executive Officer in October
of 2023 but is not a significant owner of Aspiration.
Aspiration serves as the investment adviser to the Aspiration Redwood Fund (the “Fund”), a
registered open-end investment company or mutual fund. We have delegated certain advisory
duties to UBS Asset Management (Americas) Inc. (“UBS” or the “Sub-Adviser”) pursuant to a
sub-advisory agreement entered into on behalf of the Fund. UBS, a Delaware corporation, is a
member of the UBS Asset Management business division of UBS Group AG, a publicly traded
Swiss bank (NYSE: UBS). UBS Asset Management (Americas) Inc. is an indirect wholly owned
subsidiary of UBS Group AG and is registered as an investment adviser pursuant to the
Investment Advisers Act of 1940, as amended (“Advisers Act”). UBS and Aspiration are not
affiliated entities.
The Sub-Adviser has been selected based on an evaluation of its skills and investment results in
managing assets for the Fund’s specific asset class, investment style, and strategies. Although
Aspiration has delegated responsibility for day-to-day portfolio management (including authority
over security-level decisions) to the Sub-Adviser, Aspiration regularly monitors the Sub-
Adviser’s performance with respect to its management of client assets and retains the authority to
engage or terminate the Sub-Adviser. Any decision to engage or terminate the Sub-Adviser will
be based upon continued suitability and performance of the Sub-Adviser in relation to its
management of client assets.
Information regarding the services and strategies provided by the Sub-Adviser is set forth below.
A more detailed description of the specific services available from the Sub-Adviser can be found
in the Sub-Adviser’s current Form ADV Part 2A, available at
https://adviserinfo.sec.gov/.Clients
are encouraged to carefully review the Sub-Adviser’s Form ADV Part 2A disclosure brochure
for service level, fee, conflict and professional background information applicable to the Sub-
Adviser.
Aspiration Partners, Inc., the parent company to Aspiration Fund Adviser, LLC, is the sole
member of the Aspiration Impact Foundation, LLC, a 501c(3) organization. As discussed in
more detail below, the Aspiration Impact Foundation serves as the organizational umbrella for
the Aspiration’s charitable activities and allows the contributors to the Aspiration Impact
Foundation (
i.e., Aspiration’s clients) to deduct their charitable donations from their taxable
income.
Our Advisory Services: We serve as investment adviser to the Fund. The Fund is a series of
Aspiration Funds, a Delaware statutory trust (the “Trust”). Item 8 of this brochure provides more
information about the Fund’s investment
strategy.
Unlike traditional registered investment companies, the Fund does not charge an investment
advisory fee at the Fund level. Instead, in order to be consistent with the current regulatory
framework, investors who want to invest in a Fund must become an advisory client of Aspiration
and choose the amount of advisory fees, if any, that they will pay us under our “Pay What is
Fair” fee model. Currently, the Adviser is not collecting advisory fees while they await
shareholder approval on the Interim Advisory Contract with the Redwood Fund.
Our advice to individual clients is limited to general advice as to the advisability of investing in
shares of the Fund. We do not make specific recommendations to invest a certain amount in the
Fund at any certain point in time, provide discretionary advice to individual clients who seek to
invest in the Fund, or create or recommend investment portfolios for individual clients. The
advice provided to individual clients is not personalized or otherwise based on any information
or knowledge of the individual clients and therefore is not designed to meet the objectives or
needs of individual clients. In addition, we do not provide ongoing monitoring of individual
client accounts.
We provide non-advisory, administrative services in support of the individual client accounts
established with us, such as placing orders for the purchase and sale of Fund shares, as well as
providing a software interface and technical support; access to statements, trade confirmations
and tax forms online; information and reports issued by the Fund; education; customer service;
and facilitation of charitable giving through Aspiration Impact Foundation, Inc. an affiliated
501(c)(3) organization.
Tailoring Our Services: Our advice to the Fund is tailored to meet the investment objectives and
restrictions of the Fund, which are described in detail in the Fund’s registration statement. In
addition, we have delegated certain advisory duties to the Sub-Adviser. We actively oversee the
Sub-Adviser’s investment performance, operations and compliance through regular due diligence
reviews and policies and procedures.
As discussed in above in “Our Advisory Services,” because our advice to individuals is limited
to general advice as to the advisability of investing in shares of the Fund and does not take the
form of specific recommendations to invest a certain amount in the Fund at a certain point in
time, individual clients may not impose restrictions relating to investing in securities or certain
types of securities.
Wrap Fee Programs: We do not participate in wrap fee programs.
Assets Under Management: As of December 31, 2023, Aspiration had $147,009,436 of
discretionary assets under management. While we will retain discretionary responsibility for the
management of the assets of the Fund, we have delegated such responsibility to the Sub-Adviser.
Aspiration does not manage any assets on a non-discretionary basis.