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| Pavaki Capital Management LLC
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|---|---|
| CRD # | 316395 |
| SEC # | 801-136179 |
| CIK # | |
| AUM | 410.1 M (2026-04-06) |
| Employees | 2 (100% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 719-542-7223 |
| Address | |
| Source | [IAPD] [Website] [Twitter] [LinkedIn] [Facebook] [Instagram] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (7/23/2026) [Brochure] |
|---|
Item 5 — Fees and Compensation
Pavaki does not charge a management fee for its advisory services. The Firm's
compensation is derived entirely from performance-based fees (incentive allocation).
Performance-Based Fees / Incentive Allocation
The General Partner receives an incentive allocation equal to 20% of the net profits
generated in each investor's capital account, subject to a high-water mark. Investors retain
80% of the profits. The incentive allocation is calculated and allocated on a quarterly basis.
The high-water mark is applied on a per-investor basis and resets quarterly in accordance
with the terms of the Fund's Limited Partnership Agreement.
Performance-based fee arrangements may create an incentive for the Firm to make
investments that are riskier or more speculative than would be the case in the absence of
such arrangements. The high-water mark provision is intended to mitigate this risk by
ensuring that the General Partner does not receive an incentive allocation unless the Fund
has recovered any prior losses.
Other Expenses
The Fund bears its own transaction-related expenses, including brokerage commissions
and other costs directly related to the execution of securities transactions. All other
operating expenses, including legal fees, accounting and auditing fees, organizational
expenses, administration fees, and custodial fees, are borne by the General Partner, as
described in the Fund's Private Offering Memorandum.
The Firm does not receive compensation for the sale of securities or other investment
products.
Lock-Up Period and Early Redemption Fees
Each capital contribution made by a Limited Partner is subject to an Initial Lock-Up Period of
thirty-six (36) months from the date of the capital contribution. During the Lock-Up Period, a
Limited Partner may not request redemption of their investment except with the consent of
the General Partner.
If a Limited Partner redeems their interest during the Lock-Up Period, the following early
redemption fees will apply:
5 May 7, 2026
Pavaki Capital Management, LLC — Form ADV Part 2A
• Redemption within the first 12 months of purchase: 50% redemption fee
• Redemption between 12 and 24 months of purchase: 40% redemption fee
• Redemption between 24 and 36 months of purchase: 35% redemption fee
In the event of an early withdrawal during the Lock-Up Period, there shall be no
reconciliation for profits and losses allocated to the Limited Partner's Capital Account.
Accordingly, no excess performance fees, if any, shall be refunded. The early redemption
fees are designed to protect the Fund and its remaining investors from the costs and
disruptions associated with premature withdrawals.
After the expiration of the Initial Lock-Up Period, a Limited Partner may withdraw from the
Fund entirely by providing sixty (60) days' prior written notice to the General Partner.
Distributions of any withdrawal will generally be made within fifteen (15) business days after
the withdrawal date.
Investors should carefully consider the Lock-Up Period and early redemption fees before
investing, as these terms significantly restrict liquidity.
6 May 7, 2026
Pavaki Capital Management, LLC — Form ADV Part 2A |
| Account Minimums and Types of Clients — Form ADV Part 2A (7/23/2026) [Brochure] |
|---|
Item 7 — Types of Clients
Pavaki provides investment advisory services exclusively to one private fund, Pavaki
Capital Partners, LP. The Fund is offered to accredited investors as defined in Rule 501(a) of
Regulation D under the Securities Act of 1933, and qualified clients as defined in Rule 205-3
under the Investment Advisers Act of 1940.
The minimum investment commitment for the Fund is $5,000,000, generally representing
50 Partnership Interests at $100,000 each. The General Partner may, in its sole discretion,
accept subscriptions for lesser amounts.
Not applicable. Pavaki Capital Management, LLC is a registered investment adviser with the
SEC (SEC File No. 801-136179).
8 May 7, 2026
Pavaki Capital Management, LLC — Form ADV Part 2A |
| Type | Form D Funds | Date | Sold | AUM |
|---|---|---|---|---|
| HF | Pavaki Capital Partners LP | [2021-10-08] | 410.1 M | |
| Filed 2026-03-30 (D) · Exemption 506(c), 3(c), 3(c)(1) · Minimum $5,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Over $100,000,000 | ||||
| AUM Breakdown | Accounts | AUM ($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 | 410.1 |
| (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 | 410.1 |
| By Discretionary | ||
| Discretionary | 1 | 410.1 |
| Non-Discretionary | 0 | 0.0 |
| Total | 1 | 410.1 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 410.1 | |
| Total | 1 | 410.1 |
| Form D Directors | Role | # Filings | # Firms | 2011 - 2026 |
|---|---|---|---|---|
| Ashok Patel | Executive Officer | 1 | 1 | |
| Nitu Dhanda | Executive Officer | 1 | 1 |
| Firm Profile (Form ADV) | |
|---|---|
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