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| Dunn Capital Management LLC
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| CRD # | 328632 |
| SEC # | 801-129466 |
| CIK # | |
| AUM | 269.0 M (2026-03-19) |
| Employees | 27 (22% Investors, 19% Brokers) |
| Fees | |
| Minimum | |
| Phone | 772-286-4777 |
| Address | 309 SE Osceola Street Stuart, FL 34994 |
| Source | [IAPD] [Website] [LinkedIn] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (3/19/2026) [Brochure] |
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Item 5: Fees and Compensation The Fund has engaged a SEC Registered Investment Adviser, Halyard Asset Management, LLC (the “Sub- Advisor”) to manage the excess cash not utilized for futures margining. For the fixed income security advisory services provided, the Fund is assessed an asset-based advisory fee, currently 19 basis points, by the Sub-Advisor. This fee is allocated proportionately among the investors in the Fund. DUNN does not share in the asset-based advisory fee paid by the Fund to the Sub-Advisor. However, DUNN owns 49% of the Sub-Advisor and accordingly DUNN indirectly benefits from the advisory fee paid to the Sub-Advisor. DUNN provides bookkeeping and accounting services to the Sub-Advisor. Neither DUNN nor any of its employees are compensated for these services and no fees related to these services are charged to the Fund. As described in Item 10 below, DUNN’s ownership interest in the Sub-Advisor may create a conflict of interest in that the Firm is further incentivized to refer advisory business to this entity. The asset-based advisory fee is deducted by the Sub-Advisor directly from the Fund’s account monthly, in advance. If the Fund were to close its account before the beginning of the next billing cycle, a pro-rata refund would be issued. The Fund may incur certain charges imposed by other third parties (e.g., transfer fees, administrative fees, and other fees) related to cash management services. The Fund may also incur certain separate charges imposed by the Fund’s custodian including wire transfer and electronic fund fees, retirement account custodial or account termination fees, in addition to certain taxes on non-retirement brokerage accounts. The Fund and its underlying investors should refer to the Sub-Advisor and custodian’s fee schedules, or the most recent version of the Fund’s Private Placement Memorandum and Disclosure Document (“PPM”), respectively, for additional information on fees and compensation. Financial Consortium International The Fund holds trading accounts with a futures clearing merchant (“FCM”). Some of these trading accounts utilize Financial Consortium International (“FCI”), an introducing broker (“IB”), CTA, and CPO. Collectively, DUNN and its owner, Martin H. Bergin DUNN Interest Trust, own 100% of FCI. FCI has operated in the futures industry since 1997 as an IB and is currently also registered as a CPO and CTA with NFA. FCI facilitates trading, clearing and back-office operations for institutional traders, many of whom are CTAs. FCI was acquired by DUNN in October 2015. FCI services and provides trading support to two trading accounts for the Fund on behalf of the Firm. Trading support includes FCI’s ability to take over trading of DUNN accounts, including the Fund, in the event of hurricane or other disaster that shut down DUNN operations. FCI is also available to provide back-office support, including trading, account reconciliation, trade-error management, and other trading related functions to the Fund and other accounts managed by DUNN. As DUNN is also the CTA and CPO for the Fund, DUNN controls the frequency of trading by the Fund. Given that DUNN and its owner own FCI, more frequent trading of the Fund’s assets would generate more commissions which would indirectly benefit DUNN. Even though the trading programs are systematic, DUNN has a conflict between its interest in generating trading profits for the Fund and its interest in generating more commission revenue for FCI. This conflict of interest could motivate DUNN to trade the accounts more than necessary. In addition, the commission rates paid by the Fund may not be the lowest rates available, in part because FCI, the affiliated IB, indirectly shares in such commissions in that FCI is compensated by the FCM. In other words, the commission rates could be lowered if FCI were not acting as IB on the Fund’s trading accounts, but then the Fund may not be entitled to the trading support provided to the Fund as described above. Generally, brokers introduced by FCI provide a greater level of service to trading operations, which is a benefit to investors, including the Fund. In an effort to mitigate this potential conflict of interest, DUNN performs periodic analysis of the commission rates charged to all the accounts it manages. |
| Account Minimums and Types of Clients — Form ADV Part 2A (3/19/2026) [Brochure] |
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Item 7: Types of Clients DUNN has one client for whom DUNN provides investment advisory service, which is the Fund. The only investment advisory services DUNN provides to the Fund is the selection and supervision for the fixed- income security advisory services to the Fund. DUNN does not offer investment advisory services to individual or retail investors or to any person or entity other than the Client. For each investor in the Fund, DUNN provides a PPM, in which the risks of loss, conflicts of interest, investment strategy and fees and compensation applicable to the Fund are explained in further detail. |
| 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 | 1 | 269.0 |
| (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 | 1 | 269.0 |
| By Discretionary | ||
| Discretionary | 1 | 269.0 |
| Non-Discretionary | 0 | 0.0 |
| Total | 1 | 269.0 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 269.0 | |
| Total | 1 | 269.0 |
| Firm Profile (Form ADV) | |
|---|---|
| Discretionary AUM | $0.2B |
| Serves | Institutional |
| LEI | 6354007QUJ4RXKFWPO02 |
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