Creighton Capital Management LLC

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Creighton Capital Management LLC
CRD #307737
SEC #801-126239
CIK #
AUM
Employees 13 (38% Investors, 0% Brokers)
Fees
Minimum
Phone415-823-7840
Address2602 Ellerhorst Avenue
El Cerrito, CA 94530
Source [IAPD] [Website] [LinkedIn]
Total AUM ($M)
3502802101407002009201420192025
Fees and Compensation — Form ADV Part 2A (4/1/2024) [Brochure]
Item 5 - Fees and Compensation

   Creighton AI’s Clients generally compensate Creighton AI and its affiliates through a management fee
   and an incentive allocation. Please see the applicable offering documents and investment
   management agreements for the Fund and each Sub-Advisory Clients which include a complete
   discussion of applicable fees paid by investors related to such relationships.

   Management Fee – The Fund will pay Creighton AI a monthly management fee, calculated at an
   annual rate of 1.5% (0.125% per month) calculated and paid monthly in arrears, based on the net
   asset value of each applicable share class as of the last day of the calendar month. Creighton AI may
   in its discretion, reduce, waive or calculate differently the management fee with respect to any
   investor. Creighton AI offers the Fund in USD, AUD, and GBP. The management fee will be charged
   for USD shares in U.S. Dollars. The management fee for GBP shares and AUD shares will be charged in
   British Pounds or Australian Dollars, as applicable, and converted to U.S. dollars at the month end
   exchange rate for payment to Creighton AI and its affiliates. Shares purchased of any class at any time
   other than at the beginning of the calendar month, a pro rata portion of the management fee will be
   paid to Creighton AI. Creighton AI’s management fee is inclusive of the Sub-Adviser’s fees which shall
   be borne and paid to the sub-advisor directly by Creighton AI.

   Performance Allocation The Master Fund makes a Performance Allocation (the “Performance
   Allocation”) to the Investment Manager, in its capacity as general partner of the Master Fund, as of
   January 1, April 1, July 1, and October 1 of each calendar year, and as of any date on which the Fund
   makes a withdrawal from the Master Fund (for the purpose of satisfying a Participating Share
   redemption request from a Shareholder) or receives a distribution from the Master Fund. The
   Performance Allocation is equal to 20% of the net new profit in each capital account held by a limited
   partner in the Master Fund, as provided in the Master Fund’s Confidential Private Placement
   Memorandum, which is available from the Investment Manager upon request. The Performance
   Allocation is calculated and allocated to the Investment Manager, in its capacity as general partner of
   the Master Fund, at the Master Fund level through the use of separate capital sub-accounts within
   the Fund’s capital account in the Master Fund. Such capital sub-accounts correspond to each Series
   of a Class of Participating Shares in the Fund. Creighton AI may in its discretion, reduce, waive or
   calculate differently the performance allocation with respect to any investor.

   Performance Allocations are subject to a “high water mark” provision under which the Investment
   Manager, in its capacity as general partner of the Master Fund, receives a Performance Allocation
   from a limited partner of the Master Fund only to the extent that net assets allocated to that limited
   partner’s capital account exceeds any net losses previously allocated to it since the last date a
   Performance Allocation was assessed (or the original date of contribution if no Performance

Creighton Capital Management: Part 2A                                                             Page 6

   Allocation has previously been assessed). With respect to the Fund, the Investment Manager, in its
   capacity as general partner of the Master Fund, will be eligible to receive a Performance Allocation as
   to a Series as of a quarter end (or earlier date, if the allocation is being paid as a result of an intra-
   quarter redemption) only if the appreciation in the net asset value per Share of that Series for the
   calendar quarter (or portion thereof) exceeds any depreciation in that net asset value for that Series
   that has not been recouped.

   Creighton AI appoints Exchange Traded Concepts, LLC (CRD #: 151197) to act as a sub-adviser to the
   Creighton AI Fund LP. Creighton AI is responsible for paying the sub-adviser a management fee which
   is separately negotiated between Creighton AI and Exchange Traded Concepts, LLC. The Fund shall
   bear full responsibility for its costs and expenses related to its investments and operations as
   described in the Offering Memorandums and, to the extent such expenses are paid initially by
   Exchange Traded Concepts, LLC, shall reimburse Exchange Traded Concepts, LLC for the same.

   For each Sub-Advisory Client Creighton AI typically negotiates a management fee that is individually
   negotiated between Creighton AI and each Sub-Advisory Client.

   Investors in the Creighton AI Fund typically pay Management fees monthly in arrears. Performance
   Allocations are assessed quarterly. In addition to management fees, the Fund bears its own expenses
   which include, but are not limited to, general investment expenses, all administrative, Fund level
   accounting, auditing, record-keeping, tax form preparation, regulatory, compliance, and consulting
   costs and expenses including, without limitation, costs and fees associated with compliance
   requirements of Her Majesty’s Revenue and Customs department and any applicable regulations of
   the United Kingdom (including as extended to the Cayman Islands); all fees, costs and expenses
   related to middle office operations which may include daily reconciliation of cash, cost, positions, and
   valuations; fees, costs, and expenses of third-party service providers that provide such services; costs
   and expenses associated with preparing investor communications, printing, and mailing costs;
   insurance costs and expenses (e.g., for the assets of the Fund, D&O, E&O); marketing and syndication
   expenses; taxes and other governmental charges; governmental licensing, filing, and exemption fees
...
Account Minimums and Types of Clients — Form ADV Part 2A (4/1/2024) [Brochure]
Item 7 - Types of Clients

Creighton AI advises pooled investment vehicles and provides investment management services through
sub-advisory arrangements to institutions and pooled investment vehicles. Additionally, Creighton AI
advises a pension fund. Creighton AI’s clients primarily consist of private funds and sophisticated financial
institutions. Investments into Creighton AI’s Fund generally require a minimum investment of $1 million
USD. Creighton AI may waive or increase minimum account sizes and decline to accept new investments
in its sole discretion. Creighton AI will determine if an investor fits the criteria to invest in the Fund in
accordance with the Fund’s private placement memorandum and consistent with applicable minimum
requirements.
Type Form D Funds Date Sold AUM
Other Australia Catholic Superannuation & Retirement Fund - Longreach CAI 2022-06-28 73.3 M
Other CAI Australian Share Fund 2022-06-28 7.2 M
HF Creighton AI Fund LP [2021-03-29] 42.2 M 77.5 M
Filed 2024-01-29 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($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 2 84.7
(g) Pension and profit sharing plans 1 218.1
(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 3 302.8
By Discretionary
Discretionary 3 302.8
Non-Discretionary 0 0.0
Total 3 302.8
By Non-United States Persons
Non-United States Persons 225.3
United States Persons 77.5
Total 3 302.8
Form D Directors Role # Filings # Firms 2011 - 2026
Robert Thomas Director 113 16
Simon Nock Director 13 4
Ryan Willson Executive Officer 3 3
Creighton Capital Management LLC Executive Officer 2 2
John Siciliano Executive Officer 2 2
James Creighton Executive Officer 2 2
Paul Holthe Executive Officer 2 2
Firm Profile (Form ADV)
Discretionary AUM$0.2B
ServesInstitutional, Retail
Fund TypesHedge Fund
LEI2549009D9K919PAHHY84
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