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| Bengal Asset Management LLC
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| CRD # | 168688 |
| SEC # | 801-112905 |
| CIK # | |
| AUM | 197.6 M (2026-03-30) |
| Employees | 7 (43% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 310-237-6608 |
| Address | 2001 Wilshire Blvd Santa Monica, CA 90403 |
| Source | [IAPD] [Website] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (3/30/2026) [Brochure] |
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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] |
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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 |
| Serves | Institutional |
| Fund Types | Hedge Fund |
| LEI | 549300Y5EJN74LXY1Y78 |
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