Compass Group LLC

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Compass Group LLC
CRD #108772
SEC #801-58080
CIK #0001317627, 0001563190, 0001964835, 0001666910
AUM 1,654.6 M (2026-03-31)
Employees 19 (53% Investors, 11% Brokers)
Fees
Minimum
Phone212-355-7630
Address590 Madison Ave
New York, NY 10022
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
5.04.03.02.01.00.01999200820172027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
Item 5. Fees and Compensation

Pooled Investment Vehicles:

The fees for Clients that are pooled investment vehicles (“the Funds”) consist of fixed fees, of up to 2.0%
per annum, depending on the strategy of the Fund and the size of the investment. The fixed fees are payable
monthly or quarterly in arrears. In addition, with respect to one or more of the Funds, Compass at times
will also receive an incentive fee payable annually equal to either 10% or 20% of net profits. This fee may
vary by class or type of investment and be subject to a “hurdle rate.” Incentive fees are generally subject to
a loss carry forward provision. In the case a Client utilizes the services of an affiliated sub-adviser, any fees
payable to such affiliated sub-advisers are paid out of the fixed and incentive fees received by the Adviser
from the Funds.

Separately Managed Accounts:

For its separate account management services, the Adviser charges a maximum annual fee of 2.0% of the
assets under management, payable monthly or quarterly in arrears. In addition, the Adviser may charge a
quarterly or annual incentive fee equal to 10% to 20% of the account’s quarterly or yearly return. This fee
may vary by class or type of investment and be subject to a “hurdle rate” which is negotiated separately
with respect to each Client. In the case a Client utilizes the services of an affiliated sub-adviser, any fees
payable to such affiliated sub-advisers is paid out of the fixed and incentive fees received by the Adviser
from the Funds.

Investment management fees are charged each month or quarter in arrears based on the total market value
of the assets in the Client account (including net unrealized appreciation or depreciation of investments and
cash, cash equivalents and accrued interest) on the last day of the month or quarter. If a new Client account
is established during a month or quarter or a Client makes an addition to its account during a month or
quarter, the investment management fee will be prorated for the number of days remaining in the month or
quarter. If a Client’s investment management agreement is terminated or a withdrawal is made from a Client
account during a month or quarter, the fee payable to the Adviser will be calculated based on the value of
the assets on the termination date or withdrawal date and prorated for the number of days during the month

or quarter in which the investment management arrangement was in effect or such amount was in the
account.

Performance Based Compensation:

The Adviser at times will also be paid a performance-based fee, which is compensation that is based on a
share of capital gains on or capital appreciation of the assets of a Client. This compensation will be paid to
the Adviser and range from 10% to 20%. Under certain circumstances, receipt of performance-based
compensation will be subject to a hurdle rate.

Payment of Fees:

The Adviser does not deduct the investment management fee from Client accounts. Rather, the Adviser
invoices Clients. The Adviser may, within its discretion, waive any portion of any of its fees or negotiate a
lower fee.

Other Fees and Expenses:

In addition to paying investment management fees and, if applicable, performance-based fees or other
compensation, Client accounts will also be subject to other investment expenses such as custodial charges,
brokerage fees, commissions and related costs; interest expenses; taxes, duties and other governmental
charges; transfer and registration fees or similar expenses; costs associated with foreign exchange
transactions; other portfolio expenses; and costs, expenses and fees (including, investment advisory and
other fees charged by investment advisers with, or funds in, which the Client’s account invests) associated
with products or services that may be necessary or incidental to such investments or accounts. Client assets
may be invested in pooled investment vehicles. In these cases, Clients will bear their pro rata share of the
underlying fund’s operating and other expenses including, in addition to those listed above: sales expenses,
legal expenses; internal and external accounting, audit and tax preparation expenses; and organizational
expenses. Client assets may be invested in money market mutual funds, ETFs or other registered investment
companies. In these cases, the Client will bear its pro rata share of the investment management fee and
other fees of the fund, which are in addition to the investment management fee paid to the Adviser. Client
assets may be invested in a master-feeder structure. Feeder funds bear a pro rata share of the expenses
associated with the related master fund. In addition, Clients will incur brokerage and other transaction costs.
Please refer to Item 12 of this Firm Brochure for a discussion of the Adviser’s brokerage practices.

Prepayment of Fees:

Certain Clients may, as agreed to with the Adviser, authorize the Adviser to collect its management fees up
to one quarter in advance. In these cases, management fees will be based on the fair market value of the
account’s assets valued as of the last business day of the previous calendar quarter.

In the event of the termination of the advisory mandate, or if a full or partial withdrawal of assets from the
account occurs, the Adviser shall refund to the Client promptly a pro rata portion of the prepaid management
fees which are attributable to the amount withdrawn from the Adviser’s management.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
Item 7. Types of Clients

Description:

The Adviser’s Clients consist of pooled investment vehicles, other investment advisers, endowments,
sovereign wealth funds, and other institutional Clients.

Account Minimums:

The Adviser typically requires that a Client invests a minimum of $10,000,000 to open an account and to
maintain a minimum account size of $10,000,000 for separate accounts. The Adviser reserves the right to
waive the minimum investment or minimum account size for certain Clients.

With respect to any Client that is a pooled investment vehicle, any initial and additional subscription
minimums are disclosed in the offering memorandum for the pooled investment vehicle.
Sector Form 13F Holdings Value ($M)
iShares Comex Gold Trust 3.7
 
 
 
 
 
 
 
 
 
 
Holdings by Sector ($M)
100080060040020002014201820222027
Type Form D Funds Date Sold AUM
PE CG Funds SPC - Compass Latin American Corporate Debt Fixed Maturity III 2026-03-31 44.2 M
PE Vinci Compass SICAV -Vinci Compass Brazil Equity Fund 2026-03-31 6.9 M
PE Vinci Compass SICAV - Vinci Compass Latin America Equity Fund 2026-03-31 2.0 M
Other CG Funds SPC-Compass Fixed Maturity Bonds II SP 2025-03-31 40.8 M
Other CG Funds SPC - Compass Latin American Corporate Debt Fixed Maturity SP 2024-03-28 35.0 M
PE Compass Group Alternative Fund SCA SICAV-RAIF - Compass Latin American High Yield Fund 2022-03-30 86.9 M
HF Compass Group Alternative Fund SCA SICAV-RAIF - Compass Latin American Private Credit Opportunities Lapco Sub-Fund 2022-03-30 24.9 M
AUM Breakdown Accounts AUM ($B)
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 7 0.2
(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 1.4
(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 10 1.7
By Discretionary
Discretionary 10 1.7
Non-Discretionary 0 0.0
Total 10 1.7
By Non-United States Persons
Non-United States Persons 1.7
United States Persons 0.0
Total 10 1.7
EDGAR Form CIK 2011 - 2026
13F-HR [0001317627]
SC 13G [0001317627]
10-K [0001563190]
10-Q [0001563190]
3 [0001563190]
4 [0001563190]
8-K [0001563190]
D [0001563190]
SC 13G [0001563190]
13F-HR [0001666910]
13F-HR [0001964835]
Form 13D/13G Filer Form 13D/13G Subject Filed
Vanguard Portfolio Management LLC Compass Inc [2026-04-29]
FMR LLC Compass Inc [2024-11-12]
BlackRock Inc Compass Inc [2024-11-08]
BlackRock Inc Compass Inc [2024-10-24]
Reffkin Robert L Compass Inc [2023-02-13]
Vanguard Group Inc Compass Inc [2023-02-09]
SB Investment Advisers UK Ltd Compass Inc [2022-02-14]
Discovery Capital Management LLC / CT Compass Inc [2022-02-14]
Reffkin Robert L Compass Inc [2022-02-14]
Compass Group LLC Vasta Platform Ltd [2021-02-01]
View All
Firm Profile (Form ADV)
Discretionary AUM$1.3B
ServesInstitutional
Fund TypesHedge Fund, Private Equity
LEI254900QDNHFT26JCYA95
Form 3/4/5 Subject 2011 - 2026
Compass Inc
Reffkin Robert L
Gustavson Timothy B
Glass Ethan Charles
Wahlers Scott R
McCarter Josh N
Thomas-Graham Pamela
Williams Dawanna
Martell Frank
Leinwand Allan
View All
Insider Transaction (Form 3/4/5) Date Action Shares Price Value ($)
Compass Inc COMP
Class A Common Stock
2026-03-23 Tax withheld 18,103 $7.77 140,660
Compass Inc COMP
Performance Stock Unit (PSU) · derivative
2026-03-23 Option exercise 35,460 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 11,898 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 15,750 $0.00
Compass Inc COMP
Performance Stock Unit (PSU) · derivative
2026-03-23 Grant 70,921 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 64,696 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 156,959 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 18,431 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-23 Option exercise 35,460 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 196,199 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-23 Grant 36,787 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-16 Option exercise 36,895 $0.00
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-16 Option exercise 63,583 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-16 Tax withheld 50,970 $8.28 422,032
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-16 Option exercise 19,795 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-16 Tax withheld 28,941 $8.28 239,631
Compass Inc COMP
Restricted Stock Unit (RSU) · derivative
2026-03-16 Option exercise 38,150 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-16 Option exercise 56,690 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-16 Option exercise 101,733 $0.00
Compass Inc COMP
Class A Common Stock
2026-03-03 Gift 30,296 $0.00
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