9AT: BROOKTREE CAPITAL MANAGEMENT INC.

other names

BROOKTREE CAPITAL MANAGEMENT INC.

Adviser Profile

As of Date	03/06/2026
Registration	SEC, Approved, 03/24/2020
Other registrations (2)	Texas, Terminated, 02/08/2021 Michigan, Terminated, 03/30/2020
ADV Location	GRAND RAPIDS, MI, United States
Contact Info	616 xxxxxxx
Websites

AUM^*	138,924,111 5%
of that, discretionary	138,924,111 5%
Private Fund GAV^*	25,714,746 -19%
Avg Account Size	971,497 -43%
% High Net Worth	41.89% 2%
SMA’s	Yes
Private Funds	1

Adviser Type

- Large advisory firm

Number of Employees 2

of those in investment advisory functions 2

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pooled investment vehicles
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management

SEC Fund Type	Count	GAV
Fund TypeOther Private Fund	Count1	GAV$25,714,746

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser AS AVARON ASSET MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM401.9m	#Funds-
Adviser THE L.T. FUNDS SA	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM55.4m	#Funds-
Adviser SYNTAX ADVISORS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM126.3m	#Funds-
Adviser LOTUSGROUP CAPITAL	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund54.9m	Total Private Fund GAV54.9m	AUM156.7m	#Funds4
Adviser SAVIOR WEALTH	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund50.4m	Total Private Fund GAV50.4m	AUM140.2m	#Funds14
Adviser STANCE CAPITAL LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM354.2m	#Funds-
Adviser LIVE OAK FAMILY OFFICES LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM158.4m	#Funds-
Adviser PRATTES WEALTH PARTNERS	Hedge Fund18.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund2.1m	Total Private Fund GAV20.3m	AUM243.6m	#Funds5
Adviser SQN VENTURE PARTNERS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM137.3m	#Funds1
Adviser WALL STREET INVESTMENT MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund18.1m	Total Private Fund GAV18.1m	AUM174.7m	#Funds1

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker45841N107	Stock NameINTERACTIVE BROKERS GROUP IN	$ Position$18,259,942	% Position14.00%	$ Change-29.00%	# Change-32.00%
Stck Ticker44891N208	Stock NameIAC INC	$ Position$12,587,353	% Position10.00%	$ Change0.00%	# Change-2.00%
Stck Ticker76674Q107	Stock NameRIMINI STR INC DEL	$ Position$12,984,487	% Position10.00%	$ Change-13.00%	# Change3.00%
Stck Ticker698884103	Stock NamePAR TECHNOLOGY CORP	$ Position$11,495,672	% Position9.00%	$ Change-19.00%	# Change121.00%
Stck Ticker084670702	Stock NameBERKSHIRE HATHAWAY INC DEL	$ Position$8,984,042	% Position7.00%	$ Change-18.00%	# Change-14.00%
Stck Ticker018581108	Stock NameBREAD FINANCIAL HOLDINGS INC	$ Position$7,379,211	% Position6.00%	$ Change-38.00%	# Change-39.00%
Stck Ticker747525103	Stock NameQUALCOMM INC	$ Position$6,766,616	% Position5.00%	$ Change-24.00%	# Change1.00%
Stck TickerM98068105	Stock NameWIX COM LTD	$ Position$4,337,771	% Position3.00%	$ Change1956.00%	# Change2271.00%
Stck Ticker252131107	Stock NameDEXCOM INC	$ Position$3,157,458	% Position3.00%	$ Change7.00%	# Change13.00%
Stck Ticker337738108	Stock NameFISERV INC	$ Position$3,741,836	% Position3.00%	$ Change39.00%	# Change67.00%

Brochure Summary

Overview

Our firm is an investment adviser registered with the United States Securities and Exchange Commission and was established in October 1996, by Brian R. Ellis. Effective January 1, 2020, Hunter E. Lewis, CFA purchased a 50% interest in the firm. Mr. Ellis and Mr. Lewis co-own and co-manage the firm in all aspects and as described later in this brochure. Mr. Ellis and Mr. Lewis have substantial business experience involving financial and investment matters, as well as managing investment portfolios. Investment Advisory and Management Services Our firm offers investment advisory services and we manage investment portfolios comprised of various types of securities such as stocks, bonds, mutual funds, exchange-traded funds, and municipal securities. As of March 3, 2023, we manage client accounts valued at approximately $137,401,131 on a discretionary basis. While we manage most of our client’s accounts based on similar investment strategies suitable for similar investment objectives, we will take your personal financial circumstances into account in formulating our advice and investment decisions for your account. Based upon the information you provide, we will consider many factors such as your income and expenses, assets and other financial resources, financial or special needs, investment goals, anticipated investment time horizon, and other personal financial circumstances.

If you have investments held in other accounts not under our management, we will take those investments into consideration if you tell us about them. In managing your account, we will take income tax planning into consideration if you provide us with your historical, current, and anticipated tax- related information. If you desire, we will coordinate our investment decision-making with your tax accountant or preparer. We rely upon you to keep us up to date about changes in your personal circumstances. Brooktree Capital Management, Inc. 2 Firm Brochure Our investment management agreement contains your authorization for us to manage your account on a discretionary basis. It also contains important terms and conditions governing our services, our fees, and our obligations to you. Binding Arbitration We sincerely hope that no dispute will ever arise between us over our advisory services. If you ever have a concern, please talk with us as soon as possible so that your concern can be promptly addressed. In the unlikely event that a dispute cannot be amicably resolved, our investment management agreement provides that all disputes, claims, or controversies, and any related issues, which may arise at any time will be resolved by binding arbitration, rather than by a lawsuit in a court. We believe arbitration is more expeditious and cost-effective than litigation.

BROOKTREE CAPITAL MANAGEMENT INC.

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Private Funds Structure

Similar advisers

Top Holdings

Brochure Summary

Overview