Bengal Asset Management LLC

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Bengal Asset Management LLC
CRD #168688
SEC #801-112905
CIK #
AUM 197.6 M (2026-03-30)
Employees 7 (43% Investors, 0% Brokers)
Fees
Minimum
Phone310-237-6608
Address2001 Wilshire Blvd
Santa Monica, CA 90403
Source [IAPD] [Website]
Total AUM ($M)
3002401801206002010201520212027
Fees and Compensation — Form ADV Part 2A (3/30/2026) [Brochure]
ITEM 5: FEES AND COMPENSATION

The description below is intended to provide a brief summary of typical fee, compensation, and expense
structures shared by certain types of Clients, and is not intended to depict every scenario where such
structures may differ. All investors should review the Governing Documents of each Client in
conjunction with this Brochure for more complete information.

A. Compensation for Advisory Services

Funds

Bengal receives a management fee from each Feeder Fund for its advisory services to the Funds. The
management fee for each Feeder Fund is payable, in arrears, on the last business day of each fiscal
quarter, out of the assets of the Feeder Fund. Specifically, each investor in the Feeder Funds will be
charged a pro rata share of the management fee charged on the last day of each month generally equal
to (1/12) of 2.0 % (per annum) of the Feeder Fund’s net assets. No management fee is charged to the
Master Fund.

Bengal has the potential to earn a performance-based fee from the Feeder Funds. The performance fee
is equal to, in the aggregate, 20% of the appreciation on the net asset value of the respective Feeder
Fund. Performance fees are calculated on a cumulative basis and are not payable by an investor in a
Feeder Fund until all prior net losses with respect to such investor’s account are recouped. No
performance fee is charged by the Master Fund.

From time-to-time Bengal may, in its sole discretion, afford certain investors, including its employees,
more favorable economic terms, including waiver or reduction of management and performance fees.

Managed Accounts

For Managed Accounts, Bengal generally receives management fees and performance fees that are
subject to negotiation and may vary from those paid by the Funds.

B. Deduction of Fees

Management fees payable by the Feeder Funds to Bengal are calculated monthly, accrued, and collected
directly from the Feeder Funds quarterly in arrears. The performance fee for the Feeder Funds is payable
annually, on the last business day of each fiscal year and upon full or partial redemption of an interest
by an investor in a Feeder Fund. Generally, Bengal will typically issue an invoice to the Managed
Accounts for fees incurred.

Other Fees and Expenses

Bengal bears its operating and overhead expenses, including expenses related to its facilities, salaries,
and fees and expenses to retain an affiliate to perform certain ancillary operational services (e.g.,
confirmation and settlement, reconciliation, data management, etc.).

Subject to the Governing Documents, each Fund generally pays all organization and operating expenses
attributable to the Fund. Operating expenses are all expenses incurred in operating the Fund, including,
but not limited to, brokerage commissions and other charges for transactions in securities and other
instruments, marketing costs, certain due diligence expenses, including but not limited to, travel

expenses and fees and expenses of consultants and experts, insurance costs, administration fees and
expenses, custodial fees and expenses, reporting expenses, data feeds and databases, news wires and
quotation services, periodical subscription fees, legal, tax and accounting fees and expenses (including,
without limitation, the allocable share of the costs, fees and expenses relating to internal accounting and
tax preparation functions, inclusive of salaries of the personnel of Bengal performing such functions,
should Bengal determine to use such personnel in addition to, or instead of, third party providers for
such services), audit fees, administrator fees, including, but not limited to, risk reporting services
provided by the Fund’s administrator, consulting and recording fees and expenses, servicing fees and
other similar expenses. The Funds bear their own portion of all extraordinary expenses including,
without limitation, litigation fees and expenses.

C. Pre-Paid Fees

Not applicable. Bengal’s fees are earned when services are provided and are paid in arrears thereafter.

D. Compensation for Sale of Securities

Not applicable. Neither Bengal nor any of Bengal’s employees accepts compensation for the sale of
securities or other investment products, including asset-based sales charges or service fees from the
sale of mutual funds.
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2026) [Brochure]
ITEM 7: TYPES OF CLIENTS

Bengal currently only provides investment advice to pooled investment vehicles as described in Item4.B.
above.

Each Fund is exempt from registration as an investment company in reliance upon the exemptions
available under Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act of 1940, as amended
(the “Company Act”). Admission to the Funds is not open to the general public, and each investor must
meet the eligibility provisions and minimum contribution amounts described in each Fund’s offering
documents. The Funds are offered exclusively to parties who are “accredited investors” as defined in
Regulation D under the Securities Act of 1933, as amended (the “Securities Act”), and “qualified
purchasers” as defined under the Company Act.

Generally, the initial subscription minimums are JPY10,000,000 for the Offshore Fund and $100,000
for the Onshore Fund as more fully disclosed in the Offering Documents for each Fund. Initial and
additional subscription minimums may be waived by Bengal or the directors of the Funds, in their sole
discretion.

Account minimums for Managed Accounts are negotiable and generally subject to a significant
minimum amount.
Type Form D Funds Date Sold AUM
HF Persistent Asset Global Select Fund SPC - Persistent Asset X Segregated Portfolio 2026-03-30 20.1 M
HF Bengal 2 Fund [2018-03-21] 20.6 M 177.5 M
Filed 2018-02-07 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 4 197.6
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 4 197.6
By Discretionary
Discretionary 4 197.6
Non-Discretionary 0 0.0
Total 4 197.6
By Non-United States Persons
Non-United States Persons 148.2
United States Persons 49.4
Total 4 197.6
Form D Directors Role # Filings # Firms 2011 - 2026
Robert Santos Executive Officer 8 2
Firm Profile (Form ADV)
Discretionary AUM$0.2B
ServesInstitutional
Fund TypesHedge Fund
LEI549300Y5EJN74LXY1Y78
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