SpringTide is registered as an investment adviser and is a limited liability company (LLC) formed under the laws of the State of Illinois.
• Aaron D. Dirlam is the Managing Member and 39% owner of SpringTide. Full details of the education and business background of Aaron D. Dirlam are provided at Item 19 of this Disclosure Brochure.
• Paul S. Courtney is the Director of Research and 47% owner of SpringTide. Full details of the education and business background of Paul S. Courtney are provided at Item 19 of this Disclosure Brochure.
• Dennis & Eileen Dirlam are 8% owners of SpringTide.
• Joshua Dirlam is 6% owner of SpringTide.
• SpringTide has been registered as an investment adviser since June 2017. Introduction The investment advisory services of SpringTide are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of SpringTide (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of SpringTide. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and SpringTide before we can provide you the services described below. Investment Research – SpringTide provides investment research services to other investment advisory firms, institutional investors, corporations, trusts and individual clients. Our Research Services include:
• Investment Due Diligence
• Strategic & Tactical Asset Allocation
• Portfolio Design, Review & Risk Management
• Market Commentary, Asset Class Reviews, and White Papers
• Ad Hoc Analysis Support
• Special Projects as Requested In certain situations, our research services may be utilized by the managers of investments (Mutual Funds, Hedge Funds, Public or Private Partnerships, etc.) that are also held within our managed account portfolios. This presents the appearance of a conflict of interest since SpringTide would have an incentive to favor investments that contract with us for our research services. SpringTide addresses this conflict by only considering investment options based upon the investment objectives of the managed portfolio and SpringTide Partners, LLC Page 5 Form ADV Part 2A Disclosure Brochure the fee structure, performance history and investment objective of the particular investment under consideration. Asset Management Services – SpringTide offers comprehensive investment management solutions for a select group of private individuals. Our process covers the spectrum of understanding your risk tolerance, designing an investment program to meet your needs, implementing the asset allocation and manager/fund selection. As a part of our Asset Management Services SpringTide assist in the preparation of an Investment Policy Statement for each client. Once the Investment Policy Statement is created and the asset management services are implemented, we provide ongoing monitoring, risk management and performance reporting. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss

any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. SpringTide Partners, LLC Page 6 Form ADV Part 2A Disclosure Brochure Newsletters and White Paper Publications - SpringTide prepares general, research oriented educational and informational newsletters and white papers. Newsletters and white papers are always offered on an impersonal basis and do not focus on the needs of a specific individual. Limits Advice to Certain Types of Investments SpringTide provides investment advice on the following types of investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Separate Account Managers
• Options Contracts on Securities
• Interests in Partnerships Investing in Real Estate
• Interests in Partnerships Investing in Energy and Natural Resources
• Interests in Partnerships Investing in Venture Capital, Distressed Securities, Buyout, Secondaries
• Hedge Funds Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients SpringTide’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our services are always provided based on your individual needs. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by SpringTide The amount of client assets managed by us totaled $42,092,336 as of December 31, 2023; with $42,092,336 managed on a discretionary basis and $0 managed on a non-discretionary basis. SpringTide Partners, LLC Page 7 Form ADV Part 2A Disclosure Brochure