KULA Investments LLC

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KULA Investments LLC
CRD #312388
SEC #801-123247
CIK #0001911190
AUM
Employees 16 (62% Investors, 0% Brokers)
Fees
Minimum
Phone312-883-4996
Address333 S Wabash Ave
Chicago, IL 60604
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($M)
70056042028014002009201420192025
Fees and Compensation — Form ADV Part 2A (3/28/2023) [Brochure]
Item 5: Fees and Compensation

Our fees and compensation are described in the advisory contracts we enter into with the
Funds or SMAs, as well as in the Funds’ Offering Documents or the SMAs’ Investment
Management Agreements. All of our Investors are “qualified purchasers” (as defined in
Section 2(a)(51) of the Investment Company Act of 1940, as amended. A brief summary of
such fees is provided below. All fees are deducted from a Client’s assets. Persons reviewing
this Brochure should not construe this as an offering of the Funds described herein, which will
only be made pursuant to the delivery of Offering Documents to prospective investors.

Management Fee

The Master Fund will pay a monthly management fee (“Management Fee”) to Kula
Investments equal to 0.1667% (a 2.0% annual rate) of the aggregate Gross Asset Value of each
Sub-Account, in each case as of the last calendar day of each calendar month. The
Management Fee will be appropriately pro-rated for partial months.

Incentive Fee

As of each December 31, the Master Fund will pay an incentive fee (“Incentive Fee”) to Kula
Investments equal to 20% of New Appreciation (if any) then attributable to each Investor’s
Sub-Account.

Incentive Fees do not themselves reduce New Appreciation or Appreciation for purposes of
calculating future Incentive Fees—i.e., the Firm does not need to “earn back” Incentive Fees
previously paid in order to generate additional Incentive Fees.

If an Investor has multiple Sub-Accounts, the Incentive Fee (and Appreciation, New
Appreciation and the High Water Mark) will be calculated separately with respect to each Sub-
Account. That is, the Incentive Fee will be calculated and made separately with respect to each
Capital Contribution made by an Investor, irrespective of the overall performance of the
Funds, such Investor’s Capital Account or all Interests held by such Investor.

Incentive Fees do not, until paid, reduce the Proportionate Share of a Sub-Account for
purposes of allocating Net Income or Net Loss. An Investor’s “Proportionate Share” with
respect to each Sub-Account will equal the fraction (expressed as a percentage) the numerator
of which is the Gross Asset Value of such Sub-Account, and the denominator of which is the
aggregate Gross Asset Value of all Capital Accounts. “Net Loss” means, with respect to any
given Accounting Period, the decrease in the Net Asset Value of the Funds from the beginning
to the end of such Accounting Period. “Net Income” means, with respect to any given
Accounting Period, the increase in the Net Asset Value of the Funds from the beginning to the
end of such Accounting Period. “Gross Asset Value” means Net Asset Value prior to reduction
for any accrued Incentive Fee.

In the discretion of Kula Investments, the Incentive Fee may be paid to the Firm or its affiliate
at the level of the Funds (rather than at the level of the Master Fund). If the Incentive Fee is
paid at the Funds’ level, there will be no Incentive Fee paid at the Master Fund level on the
assets of the Funds invested in the Master Fund.

Kula Investments, LLC                                                          Form ADV Part 2A

Other Types of Fees or Expenses

Kula Investments is authorized to incur and pay in the name and on behalf of its Clients all
expenses which they deem necessary or advisable.

The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary
administrative and overhead expenses, including, without limitation, all costs and expenses
related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all
salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm.

To the extent that expenses to be borne by the Clients are paid by the Firm, the Clients will
reimburse the Firm for such expenses. We may waive any such reimbursement with respect
to any Client expenses. Any waiver by us for reimbursement of any Client expenses shall not
serve as a waiver of reimbursement for any future Client expenses to be paid by us.

Neither Kula Investments nor its employees accept compensation, including sales charges or
service fees, from any person for the sale of securities or other investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/28/2023) [Brochure]
Item 7: Types of Clients

Kula Investments currently provides investment management and administrative services to
private pooled investment vehicles and SMAs for institutional investors, which are all qualified
purchasers.
Sector Form 13F Holdings Value ($M)
Berkley W R Corp 3.3
General Motors Co 3.0
Western Union Co 2.6
NetApp Inc 2.4
Allstate Corp 2.4
Hilton Worldwide Holdings Inc 2.3
Conocophillips 2.3
Abbott Laboratories 2.3
Genuine Parts Co 2.3
Union Pacific Corp 2.2
View All
Holdings by Sector ($M)
4503602701809002022202220232024
Type Form D Funds Date Sold AUM
HF KULA Equity Market Neutral Master Fund LP [2022-06-17] 17.9 M 226.3 M
Filed 2023-04-11 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $5,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($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 4 226.3
(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 3 381.9
Total 7 608.2
By Discretionary
Discretionary 7 608.2
Non-Discretionary 0 0.0
Total 7 608.2
By Non-United States Persons
Non-United States Persons 317.9
United States Persons 290.3
Total 7 608.2
Form D Directors Role # Filings # Firms 2011 - 2026
Senthil Sundaram Executive Officer 3 2
Kula Equity Market Neutral Fund GP LLC Promoter 2 2
Kula Investments LLC Executive Officer 2 2
Jeffrey Applebaum Executive Officer 2 2
EDGAR Form CIK 2011 - 2026
13F-HR [0001911190]
Firm Profile (Form ADV)
ServesInstitutional
Fund TypesHedge Fund
LEI5493003J6MIEXAG
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