Polen Capital CLO Management LLC

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Polen Capital CLO Management LLC
CRD #330470
SEC #801-129899
CIK #
AUM 808.4 M (2026-03-26)
Employees 46 (61% Investors, 9% Brokers)
Fees
Minimum
Phone781-283-8500
Address1075 Main Street, Suite 320
Waltham, MA 02451
Source [IAPD] [Website] [LinkedIn]
Total AUM ($M)
90072054036018002010201520212027
Fees and Compensation — Form ADV Part 2A (3/26/2026) [Brochure]
Item 5         Fees and Compensation
Compensation for Advisory Services and Expenses

Each Client pays Polen CLO Management (or an affiliate) certain fees as compensation for advisory
and other services provided. Additionally, each Client bears certain expenses in connection with
their operation. The actual fees and expenses for each Client, including how they are calculated, can
vary from Client to Client. The particular fees paid, and expenses borne, by a Client are described in
the Client’s governing documents. The discussion herein is intended as a general summary and is
qualified in all respects by the governing CLO Documents as it relates to any particular Client.

It is critical that Clients of Polen CLO Management as well as prospective investors refer to
their respective governing documents for a complete understanding of how Polen CLO
Management and its affiliates are compensated for their services.

CLO Collateral Management Fees. In most cases, Polen CLO Management, or an affiliate of Polen CLO
Management, will be entitled to receive from a CLO: (i) a senior collateral management fee and (ii) a
subordinate collateral management fee (both of which typically begin to accrue on the closing date
of a CLO and are paid quarterly in arrears). Certain CLOs will additionally provide that if Polen CLO
Management achieves a level of performance, as specified in the CLO Documents, Polen CLO
Management will also receive an incentive collateral management fee (collectively with the senior
collateral management fee and the subordinate collateral management fee, the “Collateral
Management Fees”). Collateral Management Fees are payable only to the extent that funds are
available for that purpose, in accordance with the priority of payments waterfall described in the
relevant CLO Documents (the “CLO’s Waterfall”). The senior collateral management fee occupies a
higher priority in the CLO’s Waterfall than the subordinate collateral management fee and, where
present, the incentive collateral management fee. Where a CLO is subject to an incentive collateral
management fee, that fee would represent performance-based compensation and would typically be
only payable to the extent that: (i) funds are available in the CLO’s Waterfall for such purpose on each
payment date, and (ii) certain specified returns hurdles are achieved, as described in the applicable
CLO Documents.

CLO Warehouse Fees. In certain cases, CLO warehouses will pay customary management fees,
structuring fees, and/or “warehouse success fees” (collectively “Warehouse Fees”) to Polen CLO
Management or an affiliate under the warehouse’s CLO Documents, as negotiated on a case-by-case
basis; however, in other cases, Polen CLO Management will not receive any Warehouse Fees from its
management of CLO warehouses. Warehouse Fees may include fees similar to the Collateral
Management Fees described above, as well as certain fees negotiated in connection with a CLO payoff
of a warehouse facility or upon the closing of a CLO, in each case as described in the relevant CLO
Documents.

Expenses. Management Fees charged to CLOs and CLO warehouses are exclusive of various costs and
expenses that are incurred in connection with the provision of advisory services by Polen CLO

                                  Polen Capital CLO Management, LLC
                                    Part 2A of Form ADV: Brochure
                                            - Page 3 of 34 -

Management. As described in more detail below and in the relevant governing documents, the costs
and expenses that will be borne by Clients (and, indirectly, by their investors, in particular investors
in the Equity of a CLO) include, but are not limited to: organizational, custodial, brokerage, audit, line
of credit, legal, risk management, consulting, third party administration, research-related fees,
transfer taxes, wire transfer, and electronic fund fees, and other fees, expenses, and taxes on
brokerage accounts maintained, and securities transactions effected, for the Client.

Direct and Indirect Expenses Incurred by CLOs. In addition to the fees paid to Polen CLO Management
for its collateral management services, and as set forth in the relevant CLO Documents, CLOs pay (and
in particular investors in the Equity of a CLO bear) a variety of other expenses related to the CLO’s
operations. These expenses will be the responsibility of the CLO and can be paid directly by the CLO
or by Polen CLO Management or an affiliate for and on behalf of the CLO (in which case, Polen CLO
Management or the affiliate will be entitled to reimbursement from the CLO). Examples of allocable
direct expenses that could be borne by a CLO include, but are not limited to, the following:

    •   All fees and out-of-pocket costs and expenses incurred by Polen CLO Management in
        connection with the formation of a CLO and its consummation including, without limitation,
        legal and other expenses (excluding travel) incurred in connection with the offer and sale of
        interests in the CLO (i.e., organizational expenses);
    •   Expenses associated with the operation of the CLO under the CLO Documents in connection
        with the management of the CLO’s Assets including expenses related to purchases and sales
        of Assets, workouts, research systems, and compliance monitoring (some of which could be
        expenses shared with other clients of Polen CLO Management or its affiliates, as described
        below);
    •   Other operating expenses, including brokerage commissions and other charges for
        transactions in securities, other instruments, and investments;
    •   Borrowing charges on margin accounts, credit facility charges, and the costs of other
        indebtedness;
    •   Insurance costs;
    •   Governmental charges;
    •   Licensing costs;
    •   Audit fees;
    •   Valuation expenses;
    •   Financing and interest costs and expenses;
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/26/2026) [Brochure]
Item 7         Types of Clients
As of February 28, 2026, Polen CLO Management manages two CLOs as its sole Clients. Investments
in CLOs are generally available only to institutional investors, such as banks, thrift institutions,
pension and profit-sharing plans, sovereign wealth funds, trusts, estates, charitable organizations,
university endowments, corporations, limited partnerships and limited liability companies or other
business entities.

To the extent that Polen CLO Management manages one or more Funds in the future, such Funds are
generally expected to be organized as exempted limited partnerships formed under the laws of
Delaware or the Cayman Islands, excepted from the definition of an “investment company” pursuant
to Section 3(c)(7) of the Investment Company Act of 1940, as amended (the “1940 Act”), and the
securities they issue will be exempt from registration under the Securities Act of 1933, as amended

                                 Polen Capital CLO Management, LLC
                                   Part 2A of Form ADV: Brochure
                                          - Page 11 of 34 -

(the “Securities Act”), pursuant to Regulation D and/or Regulation S thereunder, although other
exceptions could be relied on in certain circumstances.

It is expected that each Client’s investors will acquire interests in private placement transactions and
will be either (i) non-U.S. Persons acquiring through offshore transactions in reliance on Regulation
S or (ii) (a) in the case of CLOs, both “qualified institutional buyers” (as defined in Rule 144A under
the Securities Act) and “qualified purchasers” (as defined in Section 2(a)(51) of the 1940 Act), or (b)
in the case of Funds, “qualified purchasers”. In certain cases, an investor in a CLO or a Fund could
include persons or entities that are both “accredited investors” as defined in Section 501(a) of
Regulation D under the Securities Act and either qualified purchasers or “knowledgeable employees”
within the meaning of Rule 3c-5 under the 1940 Act.

Additional details concerning applicable investor criteria will be provided in each Client’s governing
documents.
Type Form D Funds Date Sold AUM
SA Polen Capital CLO 2025-2 Ltd 2026-03-26 402.6 M
SA Polen Capital CLO 2025-1 Ltd 2025-03-27 405.8 M
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 2 808.4
(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 2 808.4
By Discretionary
Discretionary 2 808.4
Non-Discretionary 0 0.0
Total 2 808.4
By Non-United States Persons
Non-United States Persons 808.4
United States Persons 0.0
Total 2 808.4
Firm Profile (Form ADV)
ServesInstitutional
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