Tuttle Capital Management, LLC

• A percentage of assets under your management
• Hourly charges
• Other

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

Minimum annual fee: None

As stated in the firm's Form ADV Part 2A brochure dated January 25, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$5,501,580,000 as of October 2026, filing dated September 21, 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.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• 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
• Selection of other advisers (including private fund managers)
• Other

Also doing business as

TUTTLE CAPITAL

Registration

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

Registered since

2012 (14 years)

Employees

Total: 21. Performing investment advisory functions: 8.

Wrap fee program participation

No.

Other offices (Schedule D, Section 1.F)

2 other offices, as of the October 2026 filing

Clearwater, FLPalm Beach Gardens, FL

States registered or notice-filed

2 states or jurisdictions

CTFL

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: $192,287,508 in the October 2021 data and $5,501,580,000 in the October 2026 data, up 2761%.

Total employees: 5 in October 2021 and 21 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. October 2026
   • Employees performing advisory functions went from 10 to 8.
   • Regulatory assets under management went from $3,909,230,378 to $5,501,580,000 (+41%).
   • Added an office in Clearwater, FL.
   • Added an office in Palm Beach Gardens, FL.
   • Updated its list of owners and control persons (Schedule A).
2. September 2026
   • Employees performing advisory functions went from 9 to 10.
   • Registered or notice-filed in FL.
   • Updated its list of owners and control persons (Schedule A).
3. February 2026
   • Added the business name Tuttle Capital.
   • Employees performing advisory functions went from 7 to 9.
   • Regulatory assets under management went from $3,111,976,323 to $3,909,230,378 (+26%).
   • 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.