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Adviser Profile

As of Date 09/06/2024
Adviser Type - Large advisory firm
- An investment adviser (or subadviser) to an investment company
Number of Employees 143 45.92%
of those in investment advisory functions 106 178.95%
Registration SEC, Approved, 4/6/2016
AUM* 1,218,995,681 1.70%
of that, discretionary 1,218,995,681 1.70%
Private Fund GAV* 698,061,923 0.22%
Avg Account Size 5,975,469 -9.77%
SMA’s No
Private Funds 96 3
Contact Info 844 xxxxxxx
Websites

Client Types

- Investment companies
- Pooled investment vehicles

Advisory Activities

- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles

Compensation Arrangments

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

Recent News

Reported AUM

Discretionary
Non-discretionary
1B 1B 856M 685M 514M 342M 171M
2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypePrivate Equity Fund Count31 GAV$262,434,923
Fund TypeReal Estate Fund Count12 GAV$109,567,351
Fund TypeOther Private Fund Count53 GAV$326,059,649

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Brochure Summary

Overview

Advisory Business A. General Description of Advisory Firm YieldStreet Management, LLC (the “Adviser”, “we”, “us”, and similar terms) is a Delaware limited liability company that was formed and commenced operations on March 25, 2015, with principal offices located in New York, New York. The Adviser also has offices in Miami, Florida and Athens, Greece. The Adviser is a wholly owned subsidiary of YieldStreet Inc. (the “Website Operator”), a Delaware corporation founded in August 2014. The sole owner of the Adviser is the Website Operator. As of January 22, 2024, the Website Operator is the indirect owner of RealCadre LLC, a Delaware limited liability company (“RealCadre”) and CCV, LLC, a Delaware limited liability company (“CCV”). B. Description of Advisory Services The Website Operator operates and manages the Yieldstreet.com online platform, including mobile applications and any related URLs (the “Website”). The Website allows individuals and select entities to become investors in historically difficult to access alternative investment opportunities. Through the use of the Website, prospective investors can browse and screen alternative investment opportunities, view details of a prospective investment and then complete the investment process online. Website users that decide to invest in one or more Yieldstreet Funds (as defined below) can complete their subscription and fund their investment via the Website. Website users may elect to receive limited, non-discretionary investment recommendations from the Adviser for guidance in their selection of investments from the alternative and private markets investment opportunities on the Website. Such services are referred to herein as “Digital Advice” and “Non-Digital Advice”, as more fully described below. Additionally, Website users may elect to receive the Adviser’s discretionary investment advisory services – referred to herein as “Managed Portfolios” – which are managed investment portfolios offered online through our proprietary automated advisory service. The investment options available within these advisory services are limited to certain Yieldstreet Funds and/or certain other investment products managed, sponsored or issued by third parties (“Third-Party Products” and, together with Yieldstreet Funds, “Funds”). Website users enrolled in any of these advisory services are referred to herein as “advisory clients.” Advisory clients and Yieldstreet Funds are referred to herein collectively as “clients”. This Brochure may also from time to time refer to investors within the Yieldstreet Funds as “Fund Investors”. In its capacity as the manager or investment adviser to a Yieldstreet Fund, the Adviser provides management services and/or investment advice, as applicable, solely to the Yieldstreet Funds, and not to individual Fund Investors. The descriptions set forth in this Brochure of specific advisory services that we offer to our clients, and investment strategies pursued, and investments made by us on behalf of our clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, and, in the case of Yieldstreet Funds, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Yieldstreet Fund’s investment objectives and guidelines. We do not provide investment advisory services to any client except pursuant to a written advisory agreement. The investment strategies we pursue are speculative and entail substantial risks. Yieldstreet Funds The several varieties of investment vehicles managed by the Adviser are: ● Investment vehicles (operated as standalone, parallel or master-feeder-type structures) that offer exposure to alternative investment opportunities through issuing limited liability membership interests (each, an “Equity Issuer Fund”), including: o investment(s)-specific special purpose vehicles (each, an “SPV”), o a real estate investment trust (“REIT”), which offers securities under Regulation A of the Securities Act of 1933, as amended (the “REIT Fund”), o investment vehicles that act, directly or indirectly, as access funds to investment vehicles advised by third-party investment advisers (each, an “Access Fund”), and o investment vehicles that hold assets other than securities (except for up to 40% of the assets of such investment vehicle) for which the Adviser acts solely as a manager (each, a “Company”); ● Investment vehicles that offer exposure to alternative investment opportunities through issuing notes (each, a “Note Issuer Fund”); and ● A closed-end registered investment company (the “Closed-End Fund” and collectively with the Equity Issuer Funds and the Note Issuer Funds, the “Yieldstreet Funds”). Each Yieldstreet Fund has an operating agreement or other organizational documents, a subscription agreement, the listing on the Website and disclosure documents, including investment memoranda or private placement memoranda, which are referred to hereafter as “Offering Documents”. The Adviser serves as the investment adviser to each Yieldstreet Fund (except for any Yieldstreet Fund that is a Company). i. Equity Issuer Funds An Equity Issuer Fund is generally a limited liability company formed by the Adviser to serve as an investment vehicle that will fund, acquire or originate one or more investments, in accordance with its investment guidelines, either directly or through separate investment structures or vehicles that provide the Equity Issuer Fund with exposure to such investments. Equity Issuer Funds include the REIT Fund, SPVs, Access Funds and Companies. Through the Website, prospective investors meeting the required criteria (e.g., accredited investor, qualified client and/or qualified purchaser), if any, may purchase membership interests in the applicable Equity Issuer Fund to participate in the investment opportunities. Certain Equity Issuer Funds, such as SPVs, are formed specifically to make one or more particular investments, and such SPV’s investment guidelines limit the Fund to making only those investments. The assets and liabilities of each SPV are kept separate and distinct from each other SPV and there is no commingling of funds among SPVs. The advisory services performed by the Adviser with respect to the applicable Equity Issuer Fund include: identifying and acquiring the Equity Issuer Fund’s investments, which is generally accomplished through the Adviser’s network of loan, financial asset and/or other investment originators, asset managers, sponsors and specialty finance companies, (each, an “Originator”) who provide access to potentially attractive investment opportunities (or selecting a sub-adviser to provide advice thereon); monitoring and managing each Equity Issuer Fund’s investments; and coordinating distribution of proceeds and the ultimate liquidation of each Equity Issuer Fund. Ultimately, each Fund Investor in an Equity Issuer Fund chooses to invest therein, including the amount of such investment, and the Adviser has no discretion or authority with respect to such Fund Investor’s decisions. ii. Note Issuer Funds We currently manage the following categories of Note Issuer Funds: ● Delaware limited liability companies that offer multiple series of privately-placed borrower payment dependent notes (the “ALTNOTE Funds”); ● A Delaware limited liability company that offers multiple series of privately-placed promissory notes with terms between 30 and 270 days (the “ST NOTE Fund”); and ● A Delaware limited liability company that offers multiple series of privately-placed obligor payment dependent notes with terms of no more than 270 days (the “ST STRUCTURED NOTE Fund”). The Adviser implements the ALTNOTE Funds’ investment objectives by creating wholly-owned special purpose investment vehicles, each of which (a) corresponds to a series of notes and (b) funds, acquires or originates one or more investments. Payments on each series of notes will be dependent on payments each corresponding special purpose investment vehicle receives (and therefore, in turn, the relevant ALTNOTE Fund receives) on one or more specific investments. The ST NOTE Fund similarly invests in Yieldstreet Funds. No note or series of notes issued by the ST NOTE Fund, however, is directly associated with any particular investment, unless specifically stated otherwise in the ST NOTE Fund’s Offering Documents. Instead, the notes are debt obligations that are secured by all of the assets of the ST NOTE Fund. The Adviser implements the ST STRUCTURED NOTE Fund’s investment objectives by creating wholly-owned special purpose investment vehicles, each of which (a) corresponds to a series of notes and (b) acquires one or more investments in the form of structured notes. Payments on each series of notes will be dependent on payments each corresponding special purpose investment vehicle receives (and therefore, in turn, the ST STRUCTURED NOTE Fund receives) on one or more specific structured notes. The Adviser manages Note Issuer Funds and, in the case of the ALTNOTE Funds, the ST STRUCTURED NOTE Fund, their underlying special purpose investment vehicles, and is responsible for making their investment decisions on a discretionary basis. Ultimately, each note purchaser chooses to invest therein, including the amount of such investment, and the Adviser has no discretion or authority with respect to such note purchaser’s decisions. iii. The Closed-End Fund The Closed-End Fund is a non-diversified, closed-end management investment company that has registered as an investment company under the Investment Company Act of 1940 (the “1940 Act”). The Closed-End Fund makes investments either directly or through separate investment structures or vehicles that provide the Closed-End Fund with exposure to such investments. Subject to oversight and monitoring by the Closed-End Fund’s board of directors, the Adviser has investment discretion over the Closed-End Fund. Ultimately, each Fund Investor in the Closed-End Fund chooses to invest therein, including the amount of such investment, and the Adviser has no discretion or authority with respect to such Fund Investor’s decisions. The Closed-End Fund’s shares are not currently listed on an exchange for public trading, and we do not expect a secondary market in the shares to develop in the foreseeable future, if ever. To the extent permitted by the 1940 Act and staff interpretations, the Adviser has, and in the future anticipates seeking to have, the Closed-End Fund and one or more other investment accounts managed by the Adviser or any of its affiliates participate in investment opportunities. On November 10, 2020, the Closed-End Fund received exemptive relief from the SEC to engage in co-investment transactions with the Adviser and/or its affiliates, including current and future investment vehicles on the Website, subject to certain conditions. These co-investment transactions may give rise to conflicts of interest or perceived conflicts of interest among the Closed- End Fund and the other participating accounts. To mitigate these conflicts, the Adviser and its affiliates will seek to allocate investment opportunities for all of the participating investment accounts, including the Closed-End Fund, pursuant to an allocation policy, taking into account relevant factors, such as the relative amounts of capital available for new investments, the applicable investment programs and portfolio positions, regulatory constraints, the clients for which participation is appropriate and any other factors deemed appropriate. Certain Yieldstreet Funds invest in debt securities and other credit instruments across multiple sectors, either directly or indirectly, including in direct loans to borrowers or in participation interests or other investments in income producing assets (such as individual or pools of loans or receivables) held by a third party (collectively, “Credit Investments”). Such Credit Investments include, without limitation, the following: corporate and commercial loans, consumer loans, leases, working capital loans, asset- based financing, merchant cash advances, short-term loans, litigation financing, law firm financing, supply chain financing, purchase order financing, retail point of sale financing, marine finance, professional athlete loans, small business loans and other asset-based financing or other instruments which are typically secured by interests in, without limitation: real or personal property, equipment, vehicles and other goods and merchandise, aircraft, receivables, pre-settlement and post-settlement cases; law firm receivables, purchase orders, cash flow, oil or gas, artwork, and residential and commercial mortgages. Certain Yieldstreet Funds acquire equity or similar ownership interests in securities and other assets including, without limitation, real estate, litigation cases, securitizations or structured investments, merchant cash advances secured by cash flow or future earnings, aircraft, artworks, collective investment funds, common or preferred stock in private operating companies, and limited partnership or similar interests in investment vehicles managed by third-party investment advisers whose portfolio companies include, without limitation, private equity, venture capital, private credit and real estate (“Equity Investments”). Certain Yieldstreet Funds invest in both Credit Investments and Equity Investments. The Closed-End Fund may make Equity Investments, including common stocks, preferred stocks, convertible securities, warrants, depositary receipts, ETFs, equity interests in real estate investment trusts and master limited partnerships, and may enter into certain types of derivative transactions for hedging purposes or to enhance total return. In accordance with the foregoing strategies, we will generally seek to acquire Credit Investments that (i) are believed to be sufficiently backed by collateral to preserve capital, and (ii) will generate income in accordance with our desired investment characteristics. Given the nature and risks associated with special-situation investing, we will generally seek to focus first on the collateral available for each Credit Investment in order to protect principal, and then second on obtaining an appropriate return given the term, risk and liquidity associated with each specific Credit Investment. We will generally apply similar criteria for any Equity Investment we may acquire, with a focus on our expected risk adjusted return on such Equity Investments. The Closed-End Fund is sub-advised by Prytania Investment Advisors LLP, a United Kingdom limited liability partnership (“Prytania”) pursuant to a Sub-Advisory Investment Management Agreement (the “Sub-Advisory Agreement”). Pursuant to the Sub- Advisory Agreement, our Adviser pays Prytania a Sub-Advisory Management Fee. Prytania is registered as an investment adviser with the SEC under the Advisers Act and is a quantitatively focused investment management firm specializing in structured finance, managing and advising on portfolios that consist primarily of assets originated in the United Kingdom, Europe and the United States. Advisory Services The Adviser provides limited, non-discretionary advisory services and/or discretionary advisory services directly to certain individuals and entities in their selection of investments from the alternative and private markets investments offered on the Website. These advisory services are only appropriate for those investors who have independently determined that they are considering making an investment in alternative and private markets through the Website and elect to receive guidance solely on selecting Funds. The Adviser provides (1) Digital Advice, which generates recommendations through a proprietary automated advisory service, (2) Non-Digital Advice, which provides recommendations developed by a representative of the Adviser’s client advisory team or (3) Managed Portfolios, which generates discretionary investment advice for investing portfolios offered online through a proprietary automated advisory service. Due to the non-discretionary nature of Digital Advice and Non-Digital Advice, after recommendations are provided, it is the Digital Advice advisory client’s and Non-Digital Advice advisory client’s responsibility to decide whether to invest in any of the recommended Funds at all and to determine the amount to invest in each Fund (subject to applicable investment minimums and increments), in consideration of their own overall financial goals and needs. Further, the Digital Advice advisory client and Non-Digital Advice advisory client is responsible for effecting the desired transactions; the Adviser does not arrange or effect the recommended investment. The Adviser does not provide overall financial, retirement, estate, or tax planning to any advisory client. i. Digital Advice Through Digital Advice (referred to as “Yieldstreet Recommendations” or similar phrases on the Website), a prospective advisory client may elect to receive tailored Fund investment recommendations generated by the Adviser’s proprietary automated advisory service based on their responses to a questionnaire regarding their alternative and private markets investment preferences. Digital Advice is an automated and digital investment advice experience. A Website user should not participate in the Digital Advice program if they do not wish to or are unable to interact digitally and to receive program-related communications and/or documents electronically. Regular Internet access is required to enroll in Digital Advice and to access all related program
documents. Prospective advisory clients complete the questionnaire to indicate, in the context of their alternative and private markets investment preferences, their risk tolerance, preferred investment horizon, investment style preference and eligibility status (e.g., if such prospective client is a qualified purchaser, qualified client and/or an accredited investor) (“Digital Advice Preferences”) and the range for the amount to be invested, before entering into an advisory relationship directly with the Adviser. The questionnaire will also, for data-collection purposes only, request information from a prospective client regarding annual income, net worth and other items. The questionnaire allows the Adviser to obtain information directly from the advisory client. Based solely upon the prospective advisory client’s Digital Advice Preferences (notwithstanding the additional questions included in the questionnaire), the Adviser’s automated advisory service generates a tailored investment recommendation of one or more Funds. The Adviser’s investment recommendations will consist solely of Funds that are available for investment on the Website at the time recommendations are given. The Digital Advice program is limited to recommendations of investments in one or more such Funds. The Adviser does not provide advice as to the aggregate size of the advisory client’s Fund portfolio, amount to be invested in each Fund, or overall financial, retirement, estate, or tax planning. Each Fund is recommended as an individual investment recommendation; the Fund recommendations are not provided as a recommended portfolio of Funds. Each time Digital Advice is requested, if more than five Funds fit the Digital Advice Preferences, five Funds will be randomly selected as recommendations to the prospective advisory client. If fewer than five Funds fit the Digital Advice Preferences, additional Funds that meet some but not all of the Digital Advice Preferences will be selected as recommendations to the prospective client, for a total of up to five recommended Funds for each request for Digital Advice. The prospective advisory client will be required to review and confirm their selection of Fund(s) and investment amount(s). The prospective advisory client may choose to accept one or more of the recommendations from the Adviser and determine the amount(s) to invest. If (and only if) a prospective advisory client decides to proceed, they will agree to a written investment advisory agreement and be directed to read and sign the relevant Fund Offering Documents and contribute the full amount(s) to be invested in the selected Fund(s) to complete the investment transaction. Such prospective advisory client will then become an advisory client of the Adviser, as well as a Fund Investor and/or an investor in a Third-Party Product. ii. Non-Digital Advice Certain existing and prospective advisory clients may be eligible, at the Adviser’s discretion, for Non-Digital Advice. Through Non-Digital Advice, such prospective advisory clients may elect to receive personalized Fund investment ideas, Fund allocation ideas and/or Fund portfolio reviews from the Adviser based on their discussions with an Adviser representative about their alternative and private markets investment preferences. While a Non-Digital Advice advisory client receives guidance from an Adviser representative, the advisory client must use the Website to complete the Fund investment process and access their online account portal. A Website user should not participate in the Non- Digital Advice program if they do not wish to or are unable to interact digitally and to receive program-related communications and/or documents electronically. Regular Internet access is required to enroll in Non-Digital Advice and to access all related program documents. Subsequent to conversations with an Adviser representative, prospective advisory clients eligible for Non-Digital Advice can enter into an advisory relationship with the Adviser by agreeing to a written investment advisory agreement. Based on the advisory client’s responses to the questionnaire or a substantially similar survey or discussion (written or verbal) with the advisory client, a representative from the Adviser’s advisory team develops Fund recommendations and/or sample Fund portfolios with allocations and/or conducts Fund portfolio reviews, depending on the scope of the services which are agreed upon between the Adviser and the advisory client. Unless otherwise agreed in writing, the Adviser does not consider the advisory client’s pre-existing portfolio of Fund investments or any other investments. The Adviser’s investment recommendations will consist solely of Funds that are available or may soon become available for investment on the Website at the time recommendations are given. The Non-Digital Advice program is limited to recommendations of investments in one or more such Funds. Upon receiving Fund recommendations and/or allocation recommendations, the advisory client will be required to review and confirm their selected Fund(s) and investment amount(s). The advisory client will then be directed to read and sign the relevant Fund Offering Documents and contribute the full amount(s) to be invested in the selected Fund(s) to complete the investment transaction through the Website. iii. Managed Portfolios An advisory client enrolled in a Managed Portfolio will receive discretionary investment advice generated by the Adviser’s proprietary automated advisory service with respect to a designated account funded by the advisory client (the “Managed Portfolio Account”). Discretionary trading authority permits the Adviser to select which securities to buy and sell and when to place orders for the execution of securities in Managed Portfolio Accounts on the advisory client’s behalf. A Managed Portfolio is an automated and digital investment advice experience. A Website user should not participate in the Managed Portfolios program if they do not wish to or are unable to interact digitally and to receive program-related communications and/or documents electronically. Regular Internet access is required to enroll in Managed Portfolios and to access all related program documents. Following completion of the eligibility and suitability questionnaires (the “Suitability Questionnaire”), the Adviser will recommend an investment strategy to the prospective advisory client with respect to the Managed Portfolio Account based on their responses to the Suitability Questionnaire, and the prospective advisory client may select the investment strategy to be applied to the account. The prospective advisory client completes the enrollment process by entering into an advisory relationship directly with the Adviser and confirming via the Suitability Questionnaire that it meets the basic requirements of a prospective advisory client, opening the required brokerage and custodial accounts, and funding the Managed Portfolio Account. An advisory client acknowledges that it will be unable to adjust its selections or withdraw any amounts from its Managed Portfolio Account for a period of one year following the date of its enrollment into Managed Portfolios. Once an advisory client is enrolled in Managed Portfolios, an advisory client will not have the ability to directly buy or sell investments in its Managed Portfolio Account, or to direct the Adviser to buy or sell investments in its Managed Portfolio Account. The investment advice generated is based on investment guidelines selected for the Managed Portfolio Account. The investment products available through the Managed Portfolio program are limited to certain Funds selected by the Adviser as part of each investment strategy offered and such Funds may be supplemented with additional Funds or adjusted in the sole discretion of the Adviser. The Adviser does not provide advice as to the overall investment portfolio of advisory clients (including, but not limited to, the appropriate aggregate size of the advisory client’s Managed Portfolio or the appropriate composition of the investments in advisory client’s Managed Portfolio when combined with the investments of the advisory client held outside of the Managed Portfolio), or overall financial, retirement, estate, or tax planning. Adviser will provide discretionary advisory services only with respect to the enrolled Managed Portfolio Account and will not otherwise provide any services with respect to an advisory client’s assets not included in such account. Digital Advice, Non-Digital Advice and Managed Portfolios are distinct and separate services offered by the Adviser. If an advisory client elects to receive more than one type of service, information outside of the questionnaire provided under one type of service will not be considered in the provision of another type of service. Each type of advisory service employs a different questionnaire. For example, the investment recommendations received by an advisory client pursuant to the Digital Advice program relies solely on the Digital Advice Preferences from the questionnaire and does not take into account such advisory client’s prior Fund investments made through the Website directly or through previously received Digital Advice, Non-Digital Advice or Managed Portfolio advice. Non-Digital Advice may or may not, in the Adviser’s discretion, take into consideration responses to the questionnaire as well as various discussions and other communications between Adviser representatives and the advisory client. Recommendations made to an advisory client pursuant to one type of service may differ because the investment preferences used for one type of service may differ from the investment preferences provided by the advisory client to the Adviser or Adviser representative for another type of service, and because of the differences in the information used and differences in how that information is used and analyzed in formulating the recommendations. Use of any other interactive tools on the Website or submissions of any other questionnaire or survey on the Website or otherwise to the Adviser or its affiliates will not update an advisory client’s questionnaire responses or other account profiles used by the Adviser in providing any of these advisory client services. C. Availability of Tailored Services for Individual Yieldstreet Funds and Advisory Clients i. Yieldstreet Funds Our investment decisions and advice with respect to each Yieldstreet Fund will be subject to each Yieldstreet Fund’s investment objectives and guidelines, as set forth in its respective Offering Documents. Fund Investors and prospective Fund Investors should refer to the Offering Documents for the applicable Fund for complete information regarding the investment restrictions and other information with respect to a Fund. ii. Advisory Clients For Digital Advice, investment recommendations for advisory clients are generated by the Adviser’s software-based automated advisory service, which excludes and selects Funds based upon the advisory client’s Digital Advice Preferences from the questionnaire. The Digital Advice program builds upon the due diligence process run by the Adviser’s team of investment professionals for each investment opportunity. During the due diligence process, the Adviser analyzes the characteristics for each Fund that are relevant to the Digital Advice Preferences such as investment style, investment time horizon, and risk rating. Each Fund is assigned a risk rating (i.e., Conservative, Moderate, Aggressive or Aggressive Plus) and investment style by the Adviser. For purposes of the Digital Advice programs, any Conservative risk rating assigned to a Fund will be regarded as a Moderate risk rating. The Digital Advice service is developed and managed by the Adviser’s product team in collaboration with the investment teams and the portfolio risk management team. For Non-Digital Advice, investment recommendations are generally based on the advisory client’s responses to the questionnaire or a substantially similar survey or discussions with the advisory client. The Adviser’s representatives will also utilize the risk ratings and other characteristics referenced above with respect to Digital Advice. For Managed Portfolios, tailored investment advice is generated by the Adviser’s software-based automated advisory service, which selects and allocates among Funds based on the advisory client’s selected investment strategy and guidelines as agreed between the Adviser and the advisory client. When an advisory client agrees to the allocation recommended by the Adviser’s software-based automated advisory service, such client will open a Managed Portfolio Account and accept and electronically sign the Yieldstreet Client Advisory Agreement (“Advisory Agreement”). The Adviser’s software-based automated advisory service will guide an advisory client through the account opening process. By electronically signing the Advisory Agreement, an advisory client grants discretion over the Managed Portfolio Account to the Adviser and it authorizes the Adviser to invest and reinvest the assets in the Managed Portfolio Account in accordance with the allocation model agreed to by the advisory client. The scope of any investment advisory relationship the Adviser has with an advisory client is defined in the Advisory Agreement. When an advisory client is enrolled in Managed Portfolios, the Adviser acts as such advisory client’s investment adviser only for its Managed Portfolio Account and not for any other assets or accounts, unless otherwise separately agreed to by the Adviser in writing. The Adviser’s advisory relationship with an advisory client begins when the Adviser enters into an Advisory Agreement with the advisory client. Preliminary discussions or recommendations before the Adviser enters into an Advisory Agreement with an advisory client are not intended as investment advice under the Advisers Act and should not be relied on as such. D. Other Website Operator Services i. The Yieldstreet Wallet The Website Operator, an affiliate of the Adviser, has entered into an arrangement (through a third-party banking services provider) with Evolve Bank, an unaffiliated FDIC insured bank, whereby Website users establish an account at Evolve Bank – entitled the Yieldstreet Wallet – to deposit funds and/or purchase investments on the Website. The Website Operator may in the future enter into similar arrangements with other third-party banking services providers and banks and in its sole discretion, pursuant to any applicable agreements, conclude its relationship with Evolve Bank or any similar provider. Investors deposit funds in their Yieldstreet Wallet, and such money is available to be used to efficiently process investment subscriptions on the Website. The Website Operator also uses the Yieldstreet Wallet to process distributions from investments, as well as cash rewards earned by a Website user from referral programs, incentive programs and other reward opportunities. The Website Operator is a non- advisory affiliate of the Adviser, and the Yieldstreet Wallet is a service offered by the Website Operator, rather than the Adviser, in order to improve the usability of the Website. In the future, the Website Operator may offer additional services relating to the Yieldstreet Wallet, including credit card and debit card services. Please see Item 10 for further information relating to the Yieldstreet Wallet. As used herein, the term “Yieldstreet Wallet” includes such other wallets, as the context permits. ii. Individual Retirement Arrangements The Website Operator, an affiliate of the Adviser, provides a service - entitled the Yieldstreet IRA - to assist investors in creating Individual Retirement Arrangements (“IRAs”) with IRA custodians that are unaffiliated with either the Website Operator or the Adviser. Funds are transferred from investors’ other IRAs or rolled over from qualified plans into the IRAs to be available to invest. Funds are transferred directly into the Yieldstreet Wallet described in Item 4, Section D, in the name of a revocable trust distinctly owned by each individual IRA. The Website Operator charges a facilitation fee for the Yieldstreet IRA in the form of an annual fee for the service. This fee generally ranges between $299 and $399, depending on the value of the IRA at the end of each calendar year. Annual fees may be waived for certain promotions. Further, the Website Operator has partnered with a certain unaffiliated IRA custodian (and may in the future partner with other unaffiliated IRA custodians) to provide a service so that the holders of self-directed individual retirement accounts with that unaffiliated IRA custodian are able to direct investments in investment opportunities on the Website without a Yieldstreet Wallet or Yieldstreet IRA. Accounts held at such unaffiliated IRA custodian are subject to the fees, expenses and terms determined by the custodian or as arranged between the Website Operator and the custodian. E. Wrap Fee Programs The Adviser does not participate in wrap fee programs. F. Assets Under Management The Adviser managed approximately $1,218,995,681 in regulatory assets under management on a fully discretionary basis, determined as of December 31, 2023. Pursuant to the instructions for the Form ADV, portfolios that are excluded from the definition of “securities portfolios” or accounts with respect to which we do not provide continuous and regular supervisory or management services are not included in the Adviser’s regulatory assets under management.