Sprucegrove Investment Management Ltd

• A percentage of assets under your management
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated April 9, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$11,534,579,739 as of October 2026, filing dated April 9, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for investment companies (and business development companies)
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

1994 (32 years)

Employees

Total: 49. Performing investment advisory functions: 17.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

The Bank of New York MellonJPMorgan ChaseState Street Corporation

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

States registered or notice-filed

Not reported.

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $22,523,970,963 in the October 2021 data and $11,534,579,739 in the October 2026 data, down 49%.

Total employees: 52 in October 2021 and 49 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Employees performing advisory functions went from 18 to 17.
   • Regulatory assets under management went from $15,384,784,118 to $11,534,579,739 (-25%).
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.