# Tuttle Capital Management, LLC

> Tuttle Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2012, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated September 21, 2026.

- CRD: 164937
- Filed as: TUTTLE CAPITAL MANAGEMENT, LLC
- Also doing business as: TUTTLE CAPITAL
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: September 21, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/164937
- AdvisorCensus page: https://advisorcensus.com/firm/tuttle-capital-management-llc-164937

## Quick answers

**How is Tuttle Capital Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Tuttle Capital Management, LLC reports these compensation arrangements: a percentage of assets under its management; hourly charges; other.

**Is Tuttle Capital Management, LLC registered with the SEC or a state?**
Tuttle Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2012. Status as filed: Approved. CRD 164937.

**How much does Tuttle Capital Management, LLC manage?**
Tuttle Capital Management, LLC reports $5,501,580,000 in regulatory assets under management in its Form ADV filing dated September 21, 2026 (87% discretionary).

**How have Tuttle Capital Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Tuttle Capital Management, LLC: 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. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Tuttle Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: investment companies (78); pooled investment vehicles (other than investment companies and business development companies) (3).

**Does Tuttle Capital Management, LLC report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/164937

**What changed in Tuttle Capital Management, LLC's recent Form ADV filings?**
In the October 2026 filing data: 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).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Other

### Fees and minimums (Form ADV Part 2A brochure dated January 25, 2026)

- Minimum annual fee: None

> TCM does not impose a minimum account size for new or existing sub- advisory services clients. TCM also does not impose a minimum advisory fee dollar amount per annum.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Regulatory assets under management (Item 5.F)
- Total: $5,501,580,000
- Discretionary: $4,763,000,000
- Non-discretionary: $738,580,000

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 78 | $5,501,580,000 |
| Pooled investment vehicles (other than investment companies and business development companies) | 3 | $0 |

### Advisory services (Item 5.G)
- 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

### Firm details
- Registered since: 2012 (14 years)
- Employees: 21 total, 8 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CT, FL
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the October 2026 filing
- Clearwater, FL
- Palm Beach Gardens, FL

### Websites listed on Form ADV (Item 1.I)
- tuttle-capital-management.webflow.io
- tuttlecap.com
- Facebook facebook.com
- LinkedIn @tuttle-capital-management-llc
- X @tuttlecapital
- YouTube @TuttleCap

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $192,287,508 | 5 | March 23, 2021 |
| October 2022 | $205,181,792 | 4 | June 1, 2022 |
| October 2023 | $332,902,460 | 3 | March 27, 2023 |
| October 2024 | $680,855,217 | 4 | July 19, 2024 |
| October 2025 | $3,111,976,323 | 14 | March 27, 2025 |
| October 2026 | $5,501,580,000 | 21 | September 21, 2026 |

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.

## Changes in the filing (last 12 months)

### 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).

### 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).

### 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).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Tuttle Capital Management, LLC (CRD 164937): Form ADV filing data as of October 2026.
