Bramshill Investments, LLC

Bramshill Investments, LLC is a federally registered investment adviser specializing in asset management since May 2012. The firm is wholly owned by Ironmen Holdings, LLC, with principal owners Arthur DeGaetano and Stephen Selver. Bramshill manages separate managed accounts and pooled investment vehicles on a discretionary basis, allocating assets among various securities. The firm offers advisory advice on a non-discretionary basis as well. As of December 31, 2024, Bramshill had $6,923,745,332 in assets under management. The firm's fee structure includes negotiated annual management fees up to 100 basis points for managed accounts and sub-advisory relationships. Bramshill also receives performance allocations based on investment gains. The firm acts as a fiduciary, providing investment discretion to clients and voting client securities. Bramshill's investment strategies include fixed income, tactical fixed income, structured products, quantitative income, and all-weather income strategies. The firm's code of ethics ensures compliance with securities laws and prevents the unlawful use of material non-public information. Bramshill may receive soft dollar benefits and referral fees, and it exercises best execution practices in brokerage practices. Clients receive regular account reviews and statements, and the firm votes proxies on their behalf. Bramshill does not require prepayment of fees exceeding $1,200 in advance and has a sound financial condition.