Security, Compliance & Regulatory Disclosures

Eshel Spring LLC is an SEC-registered investment adviser and provides discretionary investment advisory services through Eshel Bot, an AI-powered platform.

• We operate in accordance with applicable SEC regulations, including Regulation S-P.
• Statements regarding cybersecurity, monitoring, and supervision are based on commercially reasonable efforts; no guarantees are implied.
• References to FINRA or broker-dealer supervisory standards are informational and not indicative of regulatory oversight over Eshel Spring LLC.
• This document is supplemental to and subordinate to Form ADV Part 2A and the Client Advisory Agreement. In the event of conflict, the Client Advisory Agreement governs trade execution, data use, and risk disclosures.

• Eshel Spring LLC does not take custody of client funds or securities.
• Client assets remain with third-party brokers selected by clients.
• Advisory subscription fees are collected separately from client brokerage accounts and are not deducted automatically.
• Clients are responsible for all broker-related fees, including Alpaca API fees, commissions, margin interest, and regulatory charges.
• This arrangement is consistent with SEC Custody Rule (Rule 206(4)-2).

Eshel Bot executes trades under discretionary authority, and all automated activity is subject to human oversight:

During beta testing:

• Features may be unstable, modified, or withdrawn.
• Trades executed by beta features occur only with client consent as part of the advisory agreement.
• Beta features are non-essential and supplemental; clients may opt out at any time.
• Limitation of Liability: Eshel Spring LLC is not liable for losses resulting from beta feature use, except as required by law.

• Clients select and maintain their own brokerage accounts.
• Brokers, including Alpaca, may charge commissions, fees, margin interest, or regulatory charges. Eshel Spring LLC does not collect, control, or offset these fees.
• Best Execution: While the firm uses commercially reasonable efforts to achieve best execution, clients retain discretion over broker selection.
• Conflicts of Interest: Disclosures regarding potential conflicts are included in Form ADV Part 2A.
• All trades are executed through brokers selected by the client.

Eshel Spring LLC follows commercially reasonable cybersecurity practices to safeguard Nonpublic Personal Information (NPI):

Security practices are implemented with commercially reasonable efforts and do not guarantee absolute protection against all threats.

This section describes the firm's approach to regulatory compliance, security, discretionary trading oversight, AI and beta feature limitations, broker transparency, and client privacy. All statements are supplemental to Form ADV Part 2A and the Client Advisory Agreement, ensuring SEC alignment while maintaining transparency for clients and examiners.