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| KLS Diversified Asset Management LP
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| CRD # | 155837 |
| SEC # | 801-72408 |
| CIK # | 0001616051 |
| AUM | |
| Employees | 41 (51% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 212-905-0800 |
| Address | 217 East 70th St New York, NY 10021 |
| Source | [IAPD] [EDGAR] [Website] |
| Total AUM ($B) |
|---|
| 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 | $3.7B |
| Serves | Institutional |
| Fund Types | Hedge Fund |
| LEI | 549300GNP41K7WVJDT93 |
| Form 3/4/5 Subject | 2011 - 2026 |
|---|---|
| KLS Diversified Asset Management LP | |
| Principal Real Asset Fund | |
| Ranger Oil Corp |
| Insider Transaction (Form 3/4/5) | Date | Action | Shares | Price | Value ($) |
|---|---|---|---|---|---|
|
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 |