Stewart Asset Management, LLC

Stewart Asset Management, LLC (SAM) is a New York-based firm established in November 2013, specializing in investment advisory services. SAM was acquired by Spouting Rock Asset Management, LLC in December 2022. The firm offers portfolio management services tailored to individual client goals, with a focus on fiduciary duties and avoiding conflicts of interest. SAM primarily advises on U.S. securities but may diversify portfolios as needed. As of December 31, 2022, SAM manages approximately $19,000,000 in assets on a fully discretionary basis. The firm charges a management fee based on a tiered structure. Clients are responsible for third-party fees. SAM's investment strategies include fundamental and quantitative analysis, with a long-term trading approach. The firm discloses various risks associated with investments, such as market volatility, inflation risk, and emerging market investments. SAM has a Code of Ethics to manage conflicts of interest and ensure compliance. The firm does not engage in principal transactions and has discretion over client accounts. SAM does not receive compensation for client referrals from broker-dealers and does not take custody of client assets. Clients receive quarterly account reports. The firm does not have any disciplinary history or financial conditions impacting client commitments.