KLS Diversified Asset Management LP

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KLS Diversified Asset Management LP
CRD #155837
SEC #801-72408
CIK #0001616051
AUM
Employees 41 (51% Investors, 0% Brokers)
Fees
Minimum
Phone212-905-0800
Address217 East 70th St
New York, NY 10021
Source [IAPD] [EDGAR] [Website]
Total AUM ($B)
2016128402009201420192025
Fees and Compensation — Form ADV Part 2A (6/9/2021) [Brochure]
ITEM 5 – FEES AND COMPENSATION

It is critical that Fund Investors and Managed Account clients refer to the relevant Governing
Documents for a complete understanding of fees and expenses they may pay to KLS. The
information contained herein is a summary only and is qualified in its entirety by such
documents.

A.     Advisory Fees and Compensation

       All Managed Account clients and Fund Investors are “accredited investors” within the
       meaning of Rule 501 of Regulation D under the Securities Act of 1933, as amended,
       and “qualified purchasers” under the Investment Company Act of 1940, as amended
       (the “Investment Company Act”) (other than certain KLS personnel who are
       “knowledgeable employees” within the meaning of Rule 3c-5 of the Investment
       Company Act). Each of the Funds pays KLS a management fee based on a percentage
       of the net assets of the applicable Fund attributable to each Fund Investor’s account (the
       “Management Fee”) and a performance-based fee or allocation calculated on a high
       watermark basis (the “Incentive Allocation”). KLS has the discretion to alter, reduce or
       waive the standard management fees and/or Incentive Allocations set forth in the
       Governing Documents of the Funds. KLS allows current KLS employees who are
       authorized to invest in the Funds to do so on a fee-free basis, and KLS (or an affiliate)
       has agreed in some cases to waive or reduce fees for certain Fund Investors.

       Information concerning the RICs, including a description of the services provided by
       KLS to the RIC Manager and the fees charged by the RICs to its investors, a portion of
       which are paid to KLS in compensation for its sub-advisory services to the RIC
       Manager, is contained in the applicable RIC’s prospectus. A copy of each prospectus
       may be found at https://www.principalfunds.com/investor/forms/prospectuses.htm.

       With respect to the UCITS Sub-Fund, KLS receives (i) an Investment Management Fee
       of up to 2% per year of the Net Asset Value of the relevant Share Class and (ii) a
       Performance Fee of up to 15% of New Net Appreciation. Capitalized terms used in this
       paragraph and not defined shall have the definitions assigned to them in the UCITS
       Supplement.

       Fee arrangements for Managed Accounts and single investor Funds are generally
       individually negotiated and may differ from those of the Funds.

B.     Payment of Fees

       KLS generally deducts its fees from Fund Investors’ assets invested in the Funds.
       Fund Investors do not have the ability to choose to be billed directly for fees
       incurred. The Management Fee generally is paid from the relevant Fund to KLS
       quarterly in advance.

       Generally, the Incentive Allocation applicable to each Fund Investor is made to the
       relevant General Partner as of the end of each year, on a high watermark basis. The

     Incentive Allocation applicable to a Fund Investor may be made at the time a Fund
     Investor withdraws/redeems from the applicable Fund.

     Managed Accounts are generally charged Management Fees and are invoiced
     quarterly or monthly in advance for such fees. In addition, to the extent a Managed
     Account pays a performance-based fee, such fee will generally be deducted from such
     Managed Account’s assets on an annual basis (or at such other time as the agreement is
     terminated) after the Managed Account receives an invoice.

     The RIC Manager is charged a sub-advisory fee computed daily and paid monthly, at an
     annual rate based on each RIC’s net assets allocated to KLS’ management.

     The UCITS Sub-Fund Management Fees are calculated and accrued daily as an expense of
     the relevant Share Class and are payable monthly in arrears.

C.   Other Client Fees and Expenses

     Fees, costs and expenses paid by the Advisory Clients may include: management fees;
     organizational and formation expenses of Funds and other vehicles through which the
     Funds may invest; legal and accounting fees and disbursements; audit and tax
     preparation expenses; indemnification expenses; investment related expenses (including
     without limitation: commissions; clearing fees; fees, interest and other costs on margin
     accounts or other financings or re-financings; borrowing charges on securities sold
     short; custodial fees; bank service fees; investment and trading consultant expenses;
     research, pricing and quotation fees and expenses; portfolio management expenses;
     expenses in connection with proposed transactions (including transactions that fail to
     close); and any other reasonable expenses (at the discretion of the General Partner or
     KLS, as applicable) related to the purchase, sale, holding or transmittal of assets or
     liabilities); liability insurance premiums with respect to the General Partner and KLS;
     expenses relating to maintaining the registered offices of a General Partner and certain
     Funds in the Cayman Islands, expenses relating to all necessary filings with and all fees
     required by any U.S. federal or state government agency, the Cayman Islands Registrar
     or other U.S. or foreign government body; third-party administrator fees; extraordinary
     expenses and other similar expenses. Please refer to Item 12 of this Brochure for a
     description of KLS’s brokerage practices.

     In addition, the Funds invest substantially all of their assets in a master fund through a
     “master feeder” structure or a trading vehicle. Each Fund will indirectly bear the
     administrative and other expenses of the master fund or trading vehicle pro rata based
     on its interest in such master fund or trading vehicle.

D.   Advance Payment of Fees

     As noted above, Management Fees applicable to Fund Investors are paid quarterly in
...
Account Minimums and Types of Clients — Form ADV Part 2A (6/9/2021) [Brochure]
ITEM 7 – TYPES OF CLIENTS

KLS provides investment advisory services to the Funds, the Managed Accounts, the UCITS
Sub-Fund and through a sub-advisory relationship described above, to the RIC Manager.

The Funds offer interests/shares only to certain qualified investors and admission to the Funds
is not open to the general public. The minimum initial contribution (or minimum capital
commitment, in the case of the Structured Income Fund) for Fund Investors is generally
$1,000,000. Note that minimum initial contributions are subject to reduction or waiver at the
discretion of the relevant General Partner or Fund directors, as applicable (though not below
applicable Cayman Islands minimums, where relevant).
Type Form D Funds Date Sold AUM
HF KLS Structured Income Fund A LP [2020-06-30] 4.1 M 42.5 M
Filed 2020-05-22 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration One year or less · Revenue Decline to Disclose
HF KLS Structured Income Fund B LP [2020-06-30] 10.0 M 50.7 M
Filed 2020-05-22 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration One year or less · Revenue Decline to Disclose
HF KLS Special Situations Fund A LP [2018-10-26] 103.7 M 5.9 M
Filed 2019-06-28 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration One year or less · Revenue Decline to Disclose
HF KLS Special Situations Fund B LP [2018-10-26] 17.0 M 1.0 M
Filed 2019-06-28 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration One year or less · Revenue Decline to Disclose
SA Dorset Rise DAC 2015-03-27 1.4 M
HF KLS Credit Opportunities Fund LP [2013-07-02] 330.9 M 72.7 M
Filed 2020-05-22 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration More than one year · Commission $75,679 · Net Assets Decline to Disclose
HF KLS Macro Rates Master Fund LP 2012-11-28 1.0 M
HF KLS Diversified Master Fund LP [2012-03-26] 2,213.3 M 4,887.1 M
Filed 2020-09-14 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1 · Remaining Indefinite · Duration More than one year · Commission $13,305,152 · Net Assets Decline to Disclose
HF KLS Focus Performance Fund Ltd 2012-03-26 327.2 M
AUM Breakdown Accounts AUM ($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 2 0.7
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 6 6.2
(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 0.0
(k) Insurance companies 2 0.1
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 2 1.8
(n) Other 0 0.0
Total 12 8.9
By Discretionary
Discretionary 12 8.9
Non-Discretionary 0 0.0
Total 12 8.9
By Non-United States Persons
Non-United States Persons 6.1
United States Persons 2.8
Total 12 8.9
Form D Directors Role # Filings # Firms 2011 - 2026
Gary Linford Executive Officer 176 42
Robert Rosen Executive Officer 51 3
Stephen Casper Executive Officer 17 2
Daniel Napoli Executive Officer 8 2
Jeffrey Kronthal Executive Officer 8 2
John Steinhardt Executive Officer 7 2
Harry Lengsfield Executive Officer 7 2
Michael Zarrilli Director 1 1
Donald Layton Director 1 1
EDGAR Form CIK 2011 - 2026
13F-HR [0001616051]
3 [0001616051]
4 [0001616051]
SC 13D [0001616051]
SC 13G [0001616051]
Form 13D/13G Filer Form 13D/13G Subject Filed
KLS Diversified Asset Management LP Penn Virginia Corp [2018-01-29]
KLS Diversified Asset Management LP Penn Virginia Corp [2017-02-22]
KLS Diversified Asset Management LP Verso Corp [2016-09-26]
Firm Profile (Form ADV)
Discretionary AUM$3.7B
ServesInstitutional
Fund TypesHedge Fund
LEI549300GNP41K7WVJDT93
Form 3/4/5 Subject 2011 - 2026
KLS Diversified Asset Management LP
Principal Real Asset Fund
Ranger Oil Corp
Insider Transaction (Form 3/4/5) Date Action Shares Price Value ($)
Ranger Oil Corp PVAC
Common Stock
2018-05-23 Sell 4,700 $66.61 313,067
Ranger Oil Corp PVAC
Common Stock
2018-05-23 Sell 6,500 $65.15 423,475
Ranger Oil Corp PVAC
Common Stock
2018-05-23 Sell 10,100 $64.01 646,501
Ranger Oil Corp PVAC
Common Stock
2018-05-22 Sell 15,344 $65.16 999,815
Ranger Oil Corp PVAC
Common Stock
2018-05-22 Sell 32,823 $67.52 2,216,209
Ranger Oil Corp PVAC
Common Stock
2018-05-22 Sell 41,808 $66.77 2,791,520
Ranger Oil Corp PVAC
Common Stock
2018-05-21 Sell 21,356 $66.99 1,430,638
Ranger Oil Corp PVAC
Common Stock
2018-05-21 Sell 41,780 $66.26 2,768,343
Ranger Oil Corp PVAC
Common Stock
2018-05-16 Sell 17,387 $63.63 1,106,335
Ranger Oil Corp PVAC
Common Stock
2018-05-16 Sell 34,557 $64.51 2,229,272
Ranger Oil Corp PVAC
Common Stock
2018-05-15 Sell 200,000 $60.94 12,188,000
Ranger Oil Corp PVAC
Common Stock
2018-05-14 Sell 5,500 $63.15 347,325
Ranger Oil Corp PVAC
Common Stock
2018-05-14 Sell 16,128 $61.61 993,646
Ranger Oil Corp PVAC
Common Stock
2018-05-14 Sell 10,154 $62.55 635,133
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