Saluda Grade Asset Management LLC (“SGAM”), a Delaware limited liability company, was formed in June 2019 and is headquartered in New York, NY. SGAM and its relying adviser, Saluda Grade Ventures LLC (“SGV”) (a “Relying Adviser” as identified in Item 10 of this Brochure), provide discretionary investment advisory services to certain private funds in accordance with their investment objectives and strategies as broadly described in Item 8 of this Brochure. SGAM, SGV and affiliates are referred to throughout this Brochure as “Saluda Grade”, the “Firm”, “we”, “us” or “our”. Unless specifically noted otherwise, the responses to this Form ADV Part 2A combine information about SGAM and SGV. SGAM is a wholly owned subsidiary of Saluda Grade Holdings, LLC (“SGH”). The controlling members of SGAM and SGH are Ryan Joseph Craft, Timothy Edward Carr and Brian Edward Brennan. SGAM provides investment advisory services to Saluda Grade Opportunities Fund LP (“SGOF”), a Delaware limited partnership. SGAM also provides investment advisory services via a master- feeder structure, whereby Saluda Grade Tactical Credit Holdings Ltd., a Cayman Islands exempt company (“Feeder Fund”), is a feeder fund investing in Saluda Grade Tactical Credit Holdings LLC, a Delaware limited liability company (“Master Fund”). Unless otherwise specified, the Master Fund and Feeder Fund are collectively referred to as “SGTC” for purposes of this Brochure. SGV provides investment advisory services to Saluda Grade Alternative Lending & Fintech Growth Fund I LP (“ALF1”), a Delaware limited partnership, and Saluda Grade Alternative Lending & FinTech Growth Fund II LP (“ALF2”), a Delaware limited partnership. Unless otherwise specified, each of the private funds managed by Saluda Grade is generally referred to throughout this Brochure as a “Fund”, and they are collectively referred to as the “Funds”. SGAM and SGV manage the Funds pursuant to the investment guidelines set forth in the relevant governing and offering documents of the Funds, including any Limited Partnership Agreement, Limited Liability Company Operating Agreement, Investment Management Agreement, Investment Advisory Agreement, Private Placement Memorandum and/or Subscription Agreement (each an “Offering Document,” and collectively, the “Offering Documents”). The Offering Documents

contain more detailed information about the Funds, including a description of the investment objective and strategy or strategies employed by the Funds and related restrictions that serve as a limitation on the Firm’s advice or management. The Firm does not generally tailor its advisory services to the individual investors in the Funds (each an “Investor” and collectively the “Investors”) or provide Investors with the right to specify or restrict the Funds’ investment objectives or any investment decisions. Accordingly, an investment in the Funds does not create a client-adviser relationship between such Investors and the Firm. Each Investor is strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant Offering Documents and the additional details about SGAM’s investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and the Funds’ Offering Documents) in considering whether SGAM’s advisory services, or an investment in one of the Funds, is appropriate to the Investor’s own circumstances in light of all relevant factors including, but not limited to, the Investor’s own investment objectives, liquidity requirements, tax situation and risk tolerance before making an investment decision. Saluda Grade Opportunities Fund GP LLC, a Delaware limited liability company, serves as the general partner to SGOF and SGTC and has delegated the investment management and advisory responsibilities for SGOF and SGTC to SGAM. Saluda Grade Alternative Lending & Fintech Growth Fund I GP LLC, a Delaware limited liability company, serves as the general partner to ALF1 and ALF2 and has delegated the investment management and advisory responsibilities for ALF1 and ALF2 to SGV. The general partner has the ultimate responsibility for decisions relating to management and operations made on behalf of the Funds and has the ultimate responsibility for the investment decisions made on behalf of the Funds. Additional detailed information about Saluda Grade is provided below, including information about the Firm’s advisory services, investment approach, personnel, and affiliations. The Firm does not participate in wrap fee programs. As of December 31, 2022, the Firm managed $942,099,598 of discretionary regulatory assets under management.