First Principles Capital Management LLC

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First Principles Capital Management LLC
CRD #132466
SEC #801-64744
CIK #
AUM
Employees 8 (25% Investors, 0% Brokers)
Fees
Minimum
Phone212-458-6082
Address28 Liberty Street
New York, NY 10005
Source [IAPD] [Website] [LinkedIn]
Total AUM ($B)
151296302003201020172025
Fees and Compensation — Form ADV Part 2A (4/5/2023) [Brochure]
Item 5 - Fees and Compensation
FPCM charges clients and private fund investors an investment management fee for the advisory services
it provides. A number of factors are considered in determining the fees including, but not limited to,
portfolio type, type of security held, portfolio size, client service needs, existing relationship with FPCM,
and other factors deemed relevant by FPCM. The fees paid by separate account clients are set forth in a
written investment management agreement and, for private fund investors, in the fund’s subscription
documents. The specific manner in which fees are charged by FPCM is stated in the governing
documents. The terms of such governing documents supersede this Brochure.

FPCM receives the following fee types:

    •   Percentage of Assets Under Management

Annual Percentage of Assets Under Management

FPCM may charge a percentage fee based on the net asset value of assets under management for its
advisory services. Such fee will be paid in arrears on a period subject to negotiation with the client
(typically monthly or quarterly). This fee is negotiable, but will generally range from 0.20% to 2.50%
annually. The fee to a particular client, along with the payment frequency and timing, will be detailed in
the investment management agreement or fund subscription documents. Once fees are paid they are non-
refundable.

Trade and Fund-Specific Expenses

Clients typically bear expenses that are trade related (“Trade Expenses”), or a fund’s administrative and
operating expenses (“Fund-Specific Expenses”).

Trade Expenses may include:

    •   brokerage commissions, mark-ups, mark-downs, spreads and other transactional costs;
    •   trade-specific external legal expenses and other third-party fees and expenses incurred in
        connection with the evaluation of prospective transactions;
    •   redemption fees charged by other funds (if any);
    •   interest expense;
    •   fees and costs incurred with respect to securing access to markets, investments and investment
        opportunities; and
    •   custody costs and expenses.

Fund-Specific Expenses may include:

    •   third-party legal, audit and tax preparation expenses;
    •   other professional fees, administrator fees, director fees, registered office expenses and taxes;
    •   regulatory expenses incurred in connection with the funds’ ongoing compliance with any laws,
        rules or regulations currently in effect or adopted in the future; and

    •   all expenses incurred in connection with any threatened, pending or anticipated litigation,
        examination or proceeding or as a result of the fund’s obligation to indemnify FPCM, its
        affiliates, the administrator and certain other parties against losses, liabilities and expenses
        incurred in connection with the performance of their duties on behalf of, or the provision of
        services to, the funds.

Side Letters and Other Agreements

FPCM and the funds have entered into (and may enter into in the future) side letters and other agreements
granting more favorable rights or terms to certain investors, including affiliates of FPCM. These rights or
terms may include:

    •   investment capacity rights to make future investments in a fund, other investment vehicles or
        managed accounts;
    •   special liquidity or redemption or withdrawal rights relating to frequency, notice, fees, expedited
        payment of redemption or withdrawal proceeds and/or other terms;
    •   limitations on paying redemptions in kind;
    •   notice of certain regulatory events with respect to FPCM;
    •   rights to receive reduced rates of fees; and
    •   limits on expenses that can be charged to such investors.

These agreements could create preferences or priorities for certain investors as compared to other
investors.

FPCM or the funds will enter into these separate agreements without the consent of, or notice to, other
investors. Investors are not entitled to participate in any special arrangement without the prior approval of
FPCM. Investors not offered a special arrangement do not have any right or claim against FPCM or the
funds.
Account Minimums and Types of Clients — Form ADV Part 2A (4/5/2023) [Brochure]
Item 7 - Types of Clients
FPCM provides investment management services to a pooled investment vehicle operating as private fund
that was offered to investors on a private placement basis. The investors who receive investment
supervisory advice are primarily comprised of qualified institutional and high net worth investors who are
financially sophisticated and able to bear investment risks.

Generally, FPCM shall impose an engagement balance or an annual minimum fee for its investment
advisory services. Any deviation of these minimum investment amounts will be subject to manager’s
discretion and approval. FPCM’s minimum investment size varies by fund for investment advisory
services provided to the individual funds. All minimum investment amounts for private funds can be
identified in the fund Private Placement Memorandum.
Type Form D Funds Date Sold AUM
PE AIG First Principles Alternative Income Fund LLC 2018-03-29 9.1 M
PE First Principles Structured Income Fund LLC [2013-03-27] 47.7 M 16.2 M
Filed 2019-10-04 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other FPCM Emerging Markets Inflation-Linked Securities Fund LP [2013-03-27] 35.9 M 24.1 M
Filed 2015-08-20 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
HF FPCM Inflation-Linked Opportunities Fund - B 2013-03-27 92.1 M
PE Catena Capital LLC 2012-04-02 28.4 M
Other FPCM Inflation-Linked Opportunities Fund - A 2012-04-02 290.1 M
Other FPCM Investments LLC 2012-04-02 61.3 M
HF FPCM Treasury Fund I Limited [2012-04-02] 823.1 M 61.2 M
Filed 2012-05-02 (D/A) · Exemption 506 · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other Liberty Maiden Funding Ltd 2012-04-02 420.2 M
AUM Breakdown Accounts AUM ($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 1 0.0
(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 0.0
By Discretionary
Discretionary 1 0.0
Non-Discretionary 0 0.0
Total 1 0.0
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 0.0
Total 1 0.0
Form D Directors Role # Filings # Firms 2011 - 2026
Stephen Miller Executive Officer 36 7
David Ho Executive Officer 9 3
Robert Lewis Executive Officer 40 2
Mark Lieberman Executive Officer 10 2
Hong Chen Executive Officer 6 2
Douglas Dachille Executive Officer 5 2
Richard Dolan Executive Officer 5 2
Mark Alexandridis Executive Officer 5 2
James van Epps Executive Officer 5 2
Michael Baek Executive Officer 5 2
View All
Firm Profile (Form ADV)
Discretionary AUM$3.8B
ServesInstitutional
Fund TypesHedge Fund, Private Equity
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