A. Firm Information
Birch Run Investments, LLC (“Birch Run” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. Birch Run was founded in September 2016 and became a registered investment advisor in December 2016. Birch Run is owned and operated by David Killian (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Birch Run.
B. Advisory Services Offered
Birch Run offers investment management and related advisory services to institutional investors, high net worth individuals, pension plans, and other types of investors (each referred to as a “Client”). Birch Run specializes in fixed income investing in separately managed accounts for its Clients. The Advisor offers several fixed income strategies, including Core Fixed Income, Intermediate Fixed Income, Tax Exempt Total Return and Short-Term Fixed Income. Birch Run’s fixed income investment strategies are actively managed strategies that invest in all major asset classes within the investment grade fixed income marketplace. In providing investment advisory services to a Client, Birch Run maintains flexible strategies designed to conform with each Client’s individual investment objectives, whether such objectives are total return, current income or tax-exempt income. Birch Run provides these services on a discretionary basis and customizes the portfolio strategy to meet the needs of each Client. The Client may request to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. The Advisor also manages equity-based and diversified portfolios for certain of its Clients.

Birch Run typically constructs fixed income portfolios utilizing domestic investment-grade corporate bonds, U.S. government and agency securities, and short-term fixed income instruments. The Advisor may also utilize high- yield corporate bonds, asset-backed securities and other fixed income securities. In certain instances, the Advisor may also utilize exchange-traded funds (“ETFs”) or mutual funds to represent a particular asset class or sector. Equity and diversified portfolios are customized based on the needs of each Client and also include domestic equity securities, ETFs, mutual funds and other types of investments, as appropriate for the Client. In constructing the Client’s portfolio, the portfolio manager considers, among other factors, the security and credit quality composition of the relevant benchmark and the composition of similar portfolios in a competitive peer group. Clients may impose investment restrictions on their account[s] as to which securities may be purchased including types of asset, security quality and allocation amounts. Such investment restrictions are established by a mutually agreed upon written investment policy statement or agreement.

Birch Run’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client, liquidity needs and/or due to market conditions. Birch Run will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Birch Run evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Birch Run may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Birch Run may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Birch Run accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client investment management agreement. Please see Item 12.
Page 5
C. Client Account Management
Prior to engaging Birch Run to provide investment management services, each Client is required to enter into an investment management agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:

 Establishing an Investment Strategy – Birch Run, in connection with the Client, will design and implement an investment strategy that seeks to achieve the unique goals of the Client, which may be described in an Investment Policy Statement (“IPS”) and other communications.  Portfolio Construction – Birch Run will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – Birch Run will provide investment management and ongoing oversight of the Client’s relationship’s investment portfolio.
D. Wrap Fee Programs
Birch Run does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Birch Run.
E. Assets Under Management
As of February 29, 2020, Birch Run manages $220,904,231 in assets. Clients may request more current information at any time by contacting the Advisor. please register to get more info

The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor.
A. Fees for Advisory Services
Investment management fees are paid quarterly, either on a calendar quarter end or mid quarter basis dependent upon the agreed upon terms in the investment management agreement with the client, pursuant to the terms of the investment management agreement. Investment management fees are based on the average of the ending market values of each month in the quarter or on the value determined by the custodian on last calendar day of the billing period, again, dependent upon the agreed terms of the investment management agreement. Investment management fees are typically based on the schedules below.
Institutional Assets Under
Management ($)
Core Fixed
Income
Intermediate
Fixed Income
Tax Exempt
Total Return
Short-Term
Fixed Income
Short Term
Fixed Income
Plus
Up to $25,000,000 0.35% 0.30% 0.35% 0.25% 0.35% $25,000,001 to $50,000,000 0.30% 0.25% 0.30% 0.20% 0.30% Over $50,000,000 Negotiable Negotiable Negotiable Negotiable Negotiable

Non-Institutional Assets
Under Management ($)
Core Fixed
Income
Intermediate
Fixed Income
Tax Exempt
Total Return
Short-Term
Fixed Income
Short Term
Fixed Income
Plus
Up to $5,000,000 0.50% 0.50% 0.50% 0.50% 0.50% $5,000,001 to $15,000,000 0.45% 0.45% 0.45% 0.45% 0.45% $15,000,001 to $20,000,000 0.40% 0.40% 0.40% 0.40% 0.40% $20,000,001 to $25,000,000 0.35% 0.30% 0.35% 0.25% 0.35%
Page 6
Minimum portfolio size for Core and Intermediate Fixed Income is $5,000,000. Minimum portfolio size for Short Term Fixed, Short Term Fixed Plus and Tax Exempt Total Return is $500,000. All of the above strategies are subject to a minimum annual fee of $5,000. Clients with equity-based portfolios may be charged a higher blended or fixed investment management fee up to 0.50% annually. Investment management fees in the first quarter of service are prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at sole the discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Birch Run. All securities held in accounts managed by Birch Run will be independently valued by the designated Custodian. Birch Run will not have the authority or responsibility to value portfolio securities.

The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs.
B. Fee Billing
Investment management fees are calculated by the Advisor or its delegate and may be invoiced directly to the Client or deducted from the Client’s account[s] at the Custodian, pursuant to the terms of the investment management agreement. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. The fees can be calculated by applying the quarterly rate (annual rate divided by 4) to an average of the ending market values of each month in the quarter or upon the ending quarter value as described previously in Section A. Unless otherwise noted in the investment management agreement, Birch Run will calculate fees exclusive of any accrued income. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment management fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting Birch Run to be paid directly from their account[s] held by the Custodian as part of the investment management agreement and separate account forms provided by the Custodian.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Birch Run, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the custodian and executing broker-dealer. The investment management fee charged by Birch Run is separate and distinct from these custody and execution fees.

In addition, all fees paid to Birch Run for investment management services are separate and distinct from the expenses charged by mutual funds and ETS to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. The Client should review both the fees charged by the fund[s] and the fees charged by Birch Run to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Birch Run is typically compensated for its services at the end of the quarter, after investment management services are rendered. Dependent on the agreed upon terms in the investment management agreement with the client, Birch Run will accept compensation in advance. In such limited instances, Birch Run will not accept advance compensation for a management period exceeding ninety (90) days. Either party may terminate the investment management agreement, at any time, by providing advance written notice to the other party. Upon termination of a standard in arears fee arrangement, the Client shall be responsible for investment management fees up to and including the effective date of termination. Upon termination of an advance fee arrangement, Birch Run shall be responsible for refunding investment management fees from the effective date of termination up to the end of the management period. The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior approval.
Page 7
E. Compensation for Sales of Securities
Birch Run does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment management fees noted above. please register to get more info

Birch Run is typically compensated on the basis of fees calculated as a percentage of a client’s assets under management. In certain limited instances, however, Institutional Separate Accounts clients may negotiate a performance based fee with Birch Run. Such fee arrangements will comply with the requirements of SEC Rule 205-3 under the Investment Advisers Act of 1940. The performance fee, if earned, will be calculated as follows: A hurdle rate (gross of fees) must be achieved to become eligible for an inventive fee payment for the relevant calendar year. If the outperformance exceeds the hurdle rate versus the benchmark for the full calendar year, the incentive fee will equal 10% of the excess return above the hurdle rate, up to a maximum of 10 basis points total incentive fee for any given calendar year. In the event that Birch Run’s net of fee performance lags that of the benchmark for the relevant calendar year, the performance hurdle will be revised upward by the amount of underperformance (in basis points). To the extent that Birch Run receives a performance fee for a particular client account, Birch Run may be perceived to have an incentive to maximize gains in that account (and, therefore, maximize Birch Run’s performance fee) by making investments for that account that are riskier or more speculative than would be the case in the absence of a performance fee. Birch Run may also be perceived to have an incentive to favor accounts for which it charges a performance fee over other types of client accounts, by allocating more profitable investments to performance fee accounts or by devoting more resources toward the management of those accounts. Birch Run seeks to mitigate the conflicts which may arise from managing accounts that bear a performance fee by monitoring and enforcing its investment allocation procedures which requires the firm to allocate investment opportunities (if they are suitable), in an effort to avoid favoritism among our clients, regardless of whether the client is charged a performance based fee. please register to get more info

Birch Run offers investment management and related management services to institutional investors, high net worth individuals, pension plans, and other types of investors. The amount of assets attributable to each type of Client is available on Birch Run’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Birch Run generally does not impose a minimum account size for establishing a relationship. please register to get more info

A. Methods of Analysis
Birch Run primarily employs various analysis methods in developing investment strategies for its Clients. Research and analysis from Birch Run is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others.

Birch Run’s methods of security analysis include fundamental, technical and cyclical analysis. Sources of information used by Birch Run include, sell-side research, financial newspapers and magazines; inspections of corporate activities; corporate rating services; annual reports, prospectuses, and filings with the SEC; and company press releases. In managing fixed income portfolios for our Clients, Birch Run employs a conservative investment approach which seeks to outperform a designated benchmark over a full market cycle. Our investment process is centered upon three key portfolio construction decisions where we believe opportunities exist to add value to Client portfolios. These three areas of focus are Relative Portfolio Duration, Security Selection/Sector Allocation and Yield Curve Positioning.
Page 8
Relative Portfolio Duration Our belief is that the bond market is efficient with respect to interest rates and as a result our fixed income strategies adhere to a relatively neutral interest rate stance (+/- 5%) versus the stated benchmark at the total portfolio level. Within this context however, we do believe that opportunities can arise where value can be added to client portfolios by actively monitoring and adjusting relative portfolio duration at the sector level. These sectors would typically include U.S. Treasury and Investment Grade Corporate Bonds. By implementing sector based duration decisions while at the same time adhering to an overall neutral portfolio stance Birch Run can further enhance or limit the anticipated return of the U.S. Treasury and Investment Grade Corporate Bond sectors.

Security Selection and Sector Allocation Security selection and sector allocation are key areas of focus in our investment process and are the primary areas in which Birch Run seeks to add value to Client portfolios. Our belief is that over a full market cycle portfolio income is the primary driver of portfolio results. Therefore, our tendency is to invest more heavily in the higher yielding segments of the investment grade fixed income marketplace. The tools we utilize in this regard include: sell-side research; financial newspapers and magazines; inspections of corporate activities; corporate rating services; annual reports, prospectuses; filings with the SEC; and/or company press releases. Birch Run’s credit research process is built upon a combination of both a top-down review of macro-economic conditions and a bottom-up fundamental review of specific companies being evaluated for inclusion in Client portfolios.

Top-down considerations would typically include: a review of the current stance of monetary policy, domestic and global growth outlook, inflation outlook and geopolitical conditions. Birch Run’s top-down review of market conditions is a dynamic process that helps determine the sector allocation within Client portfolios.

Bottom-up review of specific investment opportunities seeks to identify those companies that have a strong and stable credit profile relative to the overall universe as well as a relevant peer group. Within this research process, Birch Run evaluates many different aspects of a company’s financial profile including: balance sheet leverage, interest coverage, debt distribution, free cash flow and profitability. Birch Run’s credit research process also seeks to be opportunistic in identifying securities with above average total return potential. These situations may include companies whose credit profile may have been weakened by macro-economic conditions but where Birch Run believes an improvement is forthcoming. While these opportunities provide the potential for outsized returns they also carry greater downside risk and therefore exposure to this type of security would be limited. Yield Curve Positioning The third element of our investment process is yield curve positioning. Depending upon our outlook for interest rates we may utilize ‘bullet’, ‘barbell’, and ‘ladder’ maturity structures to capture relative changes in the yield curve. These strategies provide the opportunity to enhance portfolio returns in declining interest rate environments and limit losses at times when interest rates are expected to increase. In most market conditions, Birch Run’s yield curve strategy will be relatively neutral when compared to the overall market. However, at significant inflection points in monetary policy, Birch Run may employ either a bullet or barbell portfolio structure to further benefit Client results. More information about these strategies is available upon request.
Page 9
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Birch Run will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”.

Each Client engagement will entail a review of the Client's investment goals, liquidity needs, risk parameters and other factors to develop an appropriate strategy for managing a Client's account[s]. The Advisor shall rely on the information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in goals or other factors that may affect the management of the Client’s account[s].

The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Past performance is not a guarantee of future returns. Investing in securities and
other investments involve a risk of loss that each Client should understand and be willing to bear.
Clients are reminded to discuss these risks with the Advisor. please register to get more info

There are no legal, regulatory or disciplinary events involving Birch Run or any of its affiliated persons. Birch Run values the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by our firm name or our CRD# 285285. please register to get more info

The sole business of Birch Run and Mr. Killian is to provide investment management services to its Clients. Neither Birch Run nor its associated persons are involved in other business endeavors. please register to get more info

A. Code of Ethics
Birch Run has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. Birch Run and its affiliated persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Birch Run’s CCO, Mr. Killian to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (610) 321-3453.
B. Personal Trading with Material Interest
Birch Run allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Birch Run does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Birch Run does not have a material interest in any securities traded in Client accounts.
Page 10
C. Personal Trading in Same Securities as Clients
Birch Run allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Mr. Killian may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information.
D. Personal Trading at Same Time as Client
While Birch Run allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Birch Run or its affiliated persons, transact in any security to the detriment of any Client. please register to get more info

A. Recommendation of Custodian[s]
Birch Run does not have discretionary authority to select the Custodian for safekeeping of Client funds and securities. The Client will select the Custodian to safeguard Client assets and authorize Birch Run to direct trades to this Custodian as agreed in the investment management agreement.

Birch Run, at its discretion, may execute trades directly with the designated Custodian or other broker-dealers, unless otherwise agreed by the Client. Birch Run seeks to trade with broker-dealers that will enable the Advisor to achieve best execution as defined by a combination of price, execution quality and liquidity.

Where Birch Run does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for execution and/or custody services. Clients are not obligated to use the recommended Custodian. Birch Run may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and/or the reputation of the Custodian.

Following are additional details regarding the brokerage practices of the Advisor:

1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers whereby an advisor enters into an agreement to place security trades with the broker in exchange for research and other services that provide assistance in the investment decision making process. Consistent with obtaining best execution on executed trades, Birch Run clients may pay commissions in excess of what other broker-dealers might have charged for certain portfolio transactions in recognition of brokerage and/or investment research services. Section 28(e) of the U.S. Securities Exchange Act of 1934 permits investment advisors to cause an account to pay a higher commission to a broker-dealer that provides certain brokerage and/or investment research services to the advisors, if the advisors make a good faith determination that such commissions are reasonable in relation to the value of the services provided to the advisors in terms of that particular transaction or the advisors’ overall responsibility to their clients. Research and other services obtained via soft dollar commissions may be used to benefit clients other than those whose trades generated the commissions. However, over time, all clients receive the benefits of services purchased using soft dollar commissions. 2. Brokerage Referrals - Birch Run does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. 3. Directed Brokerage – Clients may direct the Advisor, under certain circumstances, to trade with a particular broker-dealer. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Directing brokerage may result in less favorable execution.
Page 11
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. Birch Run will execute its transactions through an unaffiliated broker-dealer selected by the Client. Birch Run may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre- allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. please register to get more info

A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Killian, Chief Compliance Officer of Birch Run. Formal reviews are generally conducted at least annually or more or less frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify Birch Run if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the trustee or Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. please register to get more info

A. Compensation Received by Birch Run Participation in Institutional Advisor Platform
Birch Run has established various institutional relationships to assist the Advisor in managing Client account[s]. Access to institutional custody and brokerage platforms are provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at these platforms. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first.
B. Client Referrals from Solicitors
If a client is introduced to Birch Run by either an unaffiliated or an affiliated solicitor, Birch Run may pay that solicitor a referral fee in accordance with the requirements of Rule 201(4)-3 of the Investment Advisors Act of 1940, and any corresponding state securities law requirements. Unaffiliated or affiliated solicitors will be licensed in accordance with applicable state laws. Any such referral fee shall be paid solely from Birch Run’s investment management fee, and shall not result in any additional charge to the client. If the client is introduced to Birch Run by an unaffiliated solicitor, the solicitor, at the time of solicitation, shall disclose the nature of the solicitor relationship, and shall provide each prospective client with a copy of Birch Run’s ADV and a copy of the written disclosure statement from the solicitor to the client disclosing the terms of the solicitation agreement between Birch Run and the solicitor, including the compensation to be received by the solicitor from Birch Run.
Page 12 please register to get more info

Birch Run does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to designate the Custodian to retain their funds and securities and direct Birch Run to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Birch Run to ensure accuracy, as the custodian does not perform this review. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices”. please register to get more info

Birch Run generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Birch Run. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment management agreement containing all applicable limitations to such authority. All discretionary trades made by Birch Run will be in accordance with each Client's investment objectives and goals. please register to get more info

Birch Run does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. please register to get more info

Neither Birch Run, nor its management, have any adverse financial situations that would reasonably impair the ability of Birch Run to meet all obligations to its Clients. Neither Birch Run, nor any of its associated persons, has been subject to a bankruptcy or financial compromise. Birch Run is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance.
Page 13

Form ADV Part 2B – Brochure Supplement
for


David M. Killian
President and Chief Compliance Officer
Effective: March 25, 2020


This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David M. Killian (CRD# 5599953) in addition to the information contained in the Birch Run Investments, LLC (“Birch Run” or the “Advisor”, CRD# 285285) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Birch Run Disclosure Brochure or this Brochure Supplement, please contact us at (610) 321-3453.

Additional information about Mr. Killian is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5599953.
Page 14
Item 2 – Educational Background and Business Experience
David M. Killian, born in 1970, is dedicated to advising Clients of Birch Run as its President and Chief Compliance Officer. Mr. Killian earned his Bachelor of Science in Business Administration from Villanova University in 1996. Additional information regarding Mr. Killian’s employment history is included below.
Employment History:
President and Chief Compliance Officer, Birch Run Investments, LLC 12/2016 to Present Senior Vice President, BB&T Securities, LLC 03/2016 to 12/2016 Senior Portfolio Manager, Valley Forge Asset Management Corp. 12/2011 to 03/2016 Principal, Sterling Asset Management 07/2008 to 12/2011 Portfolio Manager, Stone Ridge Investment Partners 10/1999 to 07/2008

Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Killian. Mr. Killian has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Killian. However, we do encourage you to independently view the background of Mr. Killian on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5599953.
Item 4 – Other Business Activities
Mr. Killian is dedicated to the investment management activities of Birch Run’s Clients. Mr. Killian does not have any other business activities.
Item 5 – Additional Compensation
Mr. Killian is dedicated to the investment management activities of Birch Run’s Clients. Mr. Killian does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Killian serves as the President and Chief Compliance Officer of Birch Run. Mr. Killian can be reached at (610) 321-3453.

Birch Run has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Birch Run. Further, Birch Run is subject to regulatory oversight by various agencies. These agencies require registration by Birch Run and its Supervised Persons. As a registered entity, Birch Run is subject to examinations by regulators, which may be announced or unannounced. Birch Run is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Page 15

Form ADV Part 2B – Brochure Supplement
for


Glenn E. Becker
Managing Director
Effective: March 25, 2020


This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Glenn E. Becker in addition to the information contained in the Birch Run Investments, LLC (“Birch Run” or the “Advisor”, CRD# 285285) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Birch Run Disclosure Brochure or this Brochure Supplement, please contact us at (610) 321-3453.
Page 16
Item 2 – Educational Background and Business Experience
Glenn E. Becker, born in 1948, is dedicated to advising Clients of Birch Run as its Managing Director. Mr. Becker earned his Bachelor of Science in Business Administration from Drexel University in 1971 and his Master of Business Administration from Drexel University in 1973. Additional information regarding Mr. Becker’s employment history is included below.
Employment History:
Managing Director, Birch Run Investments, LLC 08/2019 to Present President, The Swarthmore Group 04/2006 - 12/2018 Managing Director, Morgan Stanley Investment Management, INC 01/1996 - 12/2002 Director of Client Service, Miller Anderson & Sherrerd 08/1988 - 12/1995 Director of Marketing and Client Services, Provident Capital Management 01/1975 - 07/1988

Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Becker. Mr. Becker has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Becker.
Item 4 – Other Business Activities
Mr. Becker is presently a member of the board of the Pennsylvania State Employees’ Retirement System (SERS), where he serves as Chairman of the Investment Committee.
Item 5 – Additional Compensation
Mr. Becker is dedicated to the investment management activities of Birch Run’s Clients. Mr. Becker does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Becker serves as Managing Director under the supervision of the President and Chief Compliance Officer of Birch Run, Mr. David Killian. Mr. Killian can be reached at (610) 321-3453.

Birch Run has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Birch Run. Further, Birch Run is subject to regulatory oversight by various agencies. These agencies require registration by Birch Run and its Supervised Persons. As a registered entity, Birch Run is subject to examinations by regulators, which may be announced or unannounced. Birch Run is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Page 17


Form ADV Part 2B
– Brochure Supplement
for


Joseph Shacklock
Portfolio Manager
Effective: March 25, 2020


This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Joseph Shacklock (CRD# 6240082) in addition to the information contained in the Birch Run Investments, LLC (“Birch Run” or the “Advisor”, CRD# 285285) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Birch Run Disclosure Brochure or this Brochure Supplement, please contact us at (610) 321-3453.

Additional information about Mr. Shacklock is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6240082.
Page 18
Item 2 – Educational Background and Business Experience
Joseph Shacklock, born in 1989, is dedicated to advising Clients of Birch Run as Portfolio Manager. Mr. Shacklock earned his Bachelor of Science in Finance from West Chester University of Pennsylvania in 2013. Additional information regarding Mr. Shacklock’s employment history is included below.
Employment History:
Portfolio Manager, Birch Run Investments, LLC 12/2018 to Present Head Trader, BB&T Securities, LLC 03/2016 to 12/2018 Trader, Valley Forge Asset Management Corp. 08/2013 to 03/2016

Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Shacklock. Mr. Shacklock has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Shacklock. However, we do encourage you to independently view the background of Mr. Shacklock on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6240082.
Item 4 – Other Business Activities
Mr. Shacklock is dedicated to the investment management activities of Birch Run’s Clients. Mr. Shacklock does not have any other business activities.
Item 5 – Additional Compensation
Mr. Shacklock is dedicated to the investment management activities of Birch Run’s Clients. Mr. Shacklock does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Shacklock serves as Portfolio Manager under the supervision of the President and Chief Compliance Officer of Birch Run, Mr. David Killian. Mr. Killian can be reached at (610) 321-3453.

Birch Run has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Birch Run. Further, Birch Run is subject to regulatory oversight by various agencies. These agencies require registration by Birch Run and its Supervised Persons. As a registered entity, Birch Run is subject to examinations by regulators, which may be announced or unannounced. Birch Run is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Page 19
Privacy Policy
Effective: February 6, 2017
Our Commitment to You
Birch Run Investments, LLC (“Birch Run” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Birch Run (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Birch Run does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?

Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number(s) Income and expenses E-mail address(es) Investment activity Account information (including other institutions) Investment experience and goals

What Information do we collect from other sources?

Custody, brokerage and management agreements Account applications and forms Other management agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account

How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us.
Page 20
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.
Basis For Sharing Do we share? Can you limit?
Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.

Yes

No
Marketing Purposes
Birch Run does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Birch Run or the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
No

Not Shared
Authorized Users
Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).

Yes

Yes
Information About Former Clients
Birch Run does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

No

Not Shared
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (610) 321-3453. please register to get more info