Tuttle Capital Management LLC

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Tuttle Capital Management LLC
CRD #164937
SEC #801-76982
CIK #0001581641
AUM 3,909.2 M (2026-01-28)
Employees 14 (64% Investors, 0% Brokers)
Fees
Minimum
Phone888-723-2821
Address
Source [IAPD] [EDGAR] [Website] [LinkedIn] [Facebook]
Total AUM ($B)
4.03.22.41.60.80.02010201520212027
In the News
Thu, 28 May 2026 Tuttle Capital Management CEO Matthew Tuttle on what's fueling Dow's record — qz.com
Mon, 06 Apr 2026 REX Shares, LLC & Tuttle Capital Management, LLC Announce a Reverse Share Split of T-REX 2X Long EOSE Daily Target ETF — Newswire.com
Fees and Compensation — Form ADV Part 2A (1/25/2026) [Brochure]
Item 5 – Fees and Compensation

The fees and compensation payable to TCM vary among the investment products or
institutional separately managed accounts (collectively, the “Clients”) it furnishes advisory
services or sub-advisory services.

Portfolio Management Services

TCM, as the primary investment adviser or sub-adviser to registered investment companies
(“RIC”), which include sponsored and co-sponsored exchange traded fund (“ETF”) offerings,
TCM (either independently or in collaboration with a Sub-Adviser)performs portfolio
management services for these ETFs in exchange for compensation that is owed to the Firm
(and Sub-Adviser, as applicable) as set forth in the fee table of the prospectus. The ETFs for
which TCM provides advisory services are administered through the Trust Sponsors. Each of
the Trust Sponsors has had filed a registration statement the Securities Act of 1933
(“Securities Act”) and Investment Company Act of 1940 (“Company Act”). The Board of
Trustees for those Trust Sponsors in which TCM serves as ETF adviser or sub-adviser provide
governance as does the Trust Chief Compliance Officer (“Trust CCO”). The Trust CCO is
appointed by each respective Trust’s Board of Trustees. ETFs are subject to applicable
requirements set forth in the Securities Act and Company Act, and therefore, TCM has policies
and procedures designed to comply with these regulations. For ETFs which TCM manages the
custodian deducts applicable management fees and pays TCM. TCM or the Trust Sponsor
generally shall provide a portion of the investment management fee to sub-advisors that
render services to TCM sponsored ETFs.

Tuttle Capital Strategies

   •   The SPAC and New Issue ETF
   •   Brendan Wood TopGun ETF
   •   The National Security Emerging Markets Index ETF
   •   Tuttle Capital 2X Inverse Regional Banks ETF
   •   Select STOXX® Europe Aerospace & Defense ETF
   •   Tuttle Capital IBIT 0DTE Covered Call ETF
   •   Tuttle Capital MSTR 0DTE Covered Call ETF
   •   Tuttle Capital Magnificent 7 Income Blast ETF
   •   Tuttle Capital Meme Stock Income Blast ETF

T-REX Strategies

   •   T-REX 2X Inverse MSTR Daily Target ETF
   •   T-REX 2X Long MSTR Daily Target ETF
   •   T-REX 2X Long Microsoft Daily Target ETF
   •   T-REX 2X Long Alphabet Daily Target ETF
   •   T-REX 2X Long Apple Daily Target ETF
   •   T-REX 2X Long NFLX Daily Target ETF

Tuttle Capital Management, LLC 2A Disclosure Brochure                                  Page 8

   •   T-REX 2X Inverse NVIDIA Daily Target ETF
   •   T-REX 2X Long NVIDIA Daily Target ETF
   •   T-REX 2X Inverse TESLA Daily Target ETF
   •   T-REX 2X Long TESLA Daily Target ETF
   •   T-REX 2X Inverse Bitcoin Daily Target ETF
   •   T-REX 2X Long Bitcoin Daily Target ETF
   •   T-REX 2X Long Ether Daily Target Index ETF
   •   T-REX 2X Inverse Ether Daily Target Index ETF
   •   T-Rex 2X Long HOOD Daily Target ETF
   •   T-REX 2X Long RBLX Daily Target ETF
   •   T-REX 2X Long DJT Daily Target ETF
   •   T-REX 2X Long ARM Daily Target ETF
   •   T-REX 2X Long GLXY Daily Target ETF
   •   T-REX 2X Long GME Daily Target ETF
   •   T-REX 2X Long SNOW Daily Target ETF
   •   T-REX 2X Long CRWV Daily Target ETF
   •   T-REX 2X Long SMR Daily Target ETF
   •   T-REX 2X Long DKNG Daily Target ETF
   •   T-REX 2X Long BULL Daily Target ETF
   •   T-REX 2X Long CRCL Daily Target ETF
   •   T-REX 2X Long AXON Daily Target ETF
   •   T-REX 2X Long AFRM Daily Target ETF
   •   T-REX 2X Long KTOS Daily Target ETF
   •   T-REX 2X Long BKNG Daily Target ETF
   •   T-REX 2X Long UPXI Daily Target ETF
   •   T-REX 2X Long TTDU Daily Target ETF
   •   T-REX 2X Inverse CRWV Daily Target ETF
   •   T-REX 2X Inverse CRCL Daily Target ETF
   •   T-REX 2X Long BMNR Daily Target ETF
   •   T-REX 2X Long SBET Daily Target ETF
   •   T-REX 2X Long CIFR Daily Target ETF
   •   T-REX 2X Long SOL Daily Target ETF
   •   T-REX 2X Long XRP Daily Target ETF
   •   T-REX 2X Long EOSE Daily Target ETF
   •   The Laddered T-Bill ETF

Other Strategies

   •   Tapp Alpha SPY Growth & Daily Income ETF
   •   Rareview 2X Bull Cryptocurrency & Precious Metals ETF
   •   Opportunistic Trader ETF
   •   TappAlpha Innovation 100 Growth & Daily Income ETF
   •   Founder-Led ETF
   •   Truth Social American Red State REITs ETF
   •   Truth Social American Energy Security ETF
   •   Truth Social American Security & Defense ETF
   •   Truth Social American Next Frontiers ETF
   •   Truth Social American Icons ETF
   •   TDAQ LIFT ETF

Tuttle Capital Management, LLC 2A Disclosure Brochure          Page 9

    •   TSPY LIFT ETF

For more information on TCM-sponsored/co-sponsored or sub-advised ETFs, including fees,
costs, and expenses, please visit our website at https://tuttlecap.com.

Separately Managed Accounts

In certain situations. TCM may be engaged as either a primary investment adviser or sub-
adviser to a Separately Managed Account or WRAP Program Account (i.e. advisory programs
in which the advisory fees and other expenses including transaction and/or custodial fees are
bundled into a pre-determined fee percentage) for Institutional Investor Clients sponsored
by an independent and unaffiliated registered investment adviser (“RIA”). In these
circumstances, the RIA, and not the underlying investor, is the client of TCM. As such, when
TCM does not maintain the underlying investor’s financial information, investment objectives
or risk tolerance as that detailed review is to be performed by the RIA. Accordingly, the RIA
maintains the fiduciary obligation to the underlying investor whereas TCM acts in the
capacity of an “Independent Manager” and provides advisory services to the institutional
SMA or institutional WRAP Program Account according to the portfolio model strategy
determined by the RIA. In our relationship as Independent Manager,

TCM does not deduct any investment management fees directly but will receive
...
Account Minimums and Types of Clients — Form ADV Part 2A (1/25/2026) [Brochure]
Item 7 – Types of Clients

TCM provides investment management services through advisory or sub­advisory
arrangement and on either a discretionary or non-discretionary basis to investment advisers
registered with the SEC or state jurisdictions, registered investment companies and
commodity pools. TCM also provides customized investment advice through separately
managed accounts on either a discretionary or non-discretionary basis to institutional
investors inclusive of charitable organizations, corporations and other types of business
entities.

TCM may also provide OCIO services, Outsourced Trading services and/or sub­advisory
services to SEC and/or state­registered investment advisers (“together “RIAs”), financial
planning firms, broker­dealers, banks and other financial institutions that maintain ongoing
relationships with clients. TCM also furnishes White Label ETFs to RIAs and/or other
financial institutions for which our Firm maintains business relationships.

Tuttle Capital Management, LLC 2A Disclosure Brochure                                      Page 12

Engaging the Services of TCM

All financial institutions, including SEC and state­registered investment advisers, must first
execute a sub­advisory agreement that provides TCM with the authority to invest all or some
of the sub­advisory client’s assets in one or more of the Adviser’s strategy programs.
Sector Form 13F Holdings Value ($M)
Nvidia Corp 3.1
Facebook Inc 2.8
Tesla Motors Inc 2.3
Palantir Technologies Inc 2.2
Oracle Corp 1.3
FPL Group Inc 1.1
Costco Wholesale Corp /NEW 1.0
Progressive Waste Solutions Ltd 0.9
Home Depot Inc 0.9
Chevron Corp 0.9
View All
Holdings by Sector ($M)
60048036024012002013201720222027
AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 57 3.9
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 57 3.9
By Discretionary
Discretionary 47 3.6
Non-Discretionary 10 0.3
Total 57 3.9
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 3.9
Total 57 3.9
EDGAR Form CIK 2011 - 2026
13F-HR [0001581641]
Firm Profile (Form ADV)
Discretionary AUM$0.2B
Clients1 (1 non-US)
ServesInstitutional
LEI9845000D509661HOF540
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