Steele Creek Investment Management LLC

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Steele Creek Investment Management LLC
CRD #170209
SEC #801-79139
CIK #
AUM 1,738.0 M (2026-03-24)
Employees 12 (100% Investors, 0% Brokers)
Fees
Minimum
Phone704-343-6011
Address201 South College Street
Charlotte, NC 28244
Source [IAPD] [Website]
Total AUM ($B)
4.03.22.41.60.80.02010201520212027
Fees and Compensation — Form ADV Part 2A (3/24/2026) [Brochure]
Item 5.        Fees and Compensation

A. Advisory Fees and Compensation

Management fees, performance fees and other fees we earn may be negotiated. The fees we
charge are described in detail in the Governing Agreements and investor offering documents.

Fund Investors will experience different types of fees depending on the fund. For CLO Funds,
we charge a “senior management fee” which is senior to payments to other tranches of investors
in a CLO Fund, and a “subordinate management fee” which is subordinate to non-equity
tranches of investors in a CLO Fund (collectively, the “CLO Management Fees”). We generally
also charge an “incentive” or performance fee once the Fund has achieved a certain return target
typically in the form of an IRR hurdle. The BSL Fund will pay a management fee based on
outstanding loan par (the “BSL Management Fee”). The BDC has a management fee calculated
at a maximum annual rate of 1.0% of the average of the weighted average (based on the number
of shares outstanding each day in the quarter) of our gross assets (including assets funded with
borrowings) at the end of each of the two most recently completed calendar quarters; however
we may waive all or part of that fee (the “BDC Management Fee”) (collectively, the CLO
Management Fees, the BSL Management Fee and the BDC Management Fee will be referred to
as the “Management Fees”).

Generally our CLO Funds will pay the following fees:

Senior management fees (in aggregate) of ranging between 0.10-0.25% annually; a subordinate
management fee ranging between 0.125-0.225% annually; and an incentive fee of 20% once a

                                                                                         5|Page

12-15% return on investment has been achieved. Specific fee rates and the methodology for
calculating these fees will be described in the Governing Agreements which will be provided to
prospective investors.

The 2025 Warehouse does not charge management fees or performance fees currently; upon
conversion to a CLO, the 2025 Warehouse will change fees in line with our CLO Funds as
described in its Governing Agreement.

Please refer to each Fund and its Governing Agreements for a complete description of fees and
charges.

B. Payment of Fees.

   •   Management Fee.

       Management Fees are generally payable in arrears to the extent of funds available for that
       purpose, on the payment date defined in the offering documents or Governing
       Agreements of the CLO Fund, BSL Fund or BDC. Management Fees are paid by the
       Fund Trustee or BSL Fund in accordance with the payment waterfall set forth in the
       Governing Agreements. Management Fees paid by the BDC are subject to waiver as set
       forth in the BDC Governing Documents. Certain of these fees may be shared with
       investors under side letters.

   •   Performance Allocation (as discussed below in Item 6).

       Performance fees are assessed periodically according to each CLO Fund’s governing
       documents following the achievement of a specified return on investment. These fees are
       typically paid by the Fund Trustee in accordance with the payment waterfall set forth in
       the CLO Governing Agreements or as set forth in the BDC Governing Documents.

C. Other Fees and Expenses.

Other fees and expenses may be paid out of cash otherwise distributable to the Fund Investors.
These fees include taxes, governmental fees, registered office fees, administrator expenses,
accountants, consultants, including those assisting with Advisers Act compliance, data service
fees, legal fees, rating agency fees, trustee fees, registration fees to Steele Creek and some Steele
Creek expenses that are reimbursable by the Funds. The treatment of such fees will be detailed
in the applicable Governing Agreements; specifically the indenture, the limited partnership
agreement, or PPM for each Fund sets out categories of fees and expenses which may be
reimbursed. These fees and expenses will be paid directly from each Fund as set forth in our
expense allocation policy, generally with each Fund responsible for its pro rata portion of such
fees and expenses, based on the aggregate assets under management of all Funds to which such
costs or expenses are allocable.

See item 12 below for additional information.

                                                                                           6|Page

D. Additional Compensation and Conflicts of Interest.

Neither we nor our supervised persons accept compensation for the sale of securities or other
investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/24/2026) [Brochure]
Item 7.        Types of Clients

Steele Creek currently provides investment advisory services to eight CLO Funds, the 2025
Warehouse, one BSL Fund and one BDC. Our business focuses on origination, execution,
management, and redemption of loan portfolios. We intend to launch other CLO Funds in the
upcoming year(s). Investments in the CLO Funds and the BSL Fund are privately offered only
to qualified purchasers, typically institutional investors. Investors in the BDC may be accredited
investors and those interests are privately offered. The majority of such investments will be in
debt instruments, rather than in equity interests.

The minimum initial amount that may be invested in the CLO Funds and the BSL Fund is
$1,000,000 although the Firm reserves the right to increase the minimum or to accept lesser
amounts in its sole discretion. The minimum amount that may be invested in the BDC is
$25,000, or $5,000 for each subsequent investment.
Type Form D Funds Date Sold AUM
SA Steele Creek CLO 2022-2 Ltd 2023-03-21 0.1 M
SA Steele Creek CLO 2022-1 Ltd 2022-03-27 347.3 M
SA Steele Creek CLO 2019 Xi Ltd 2020-03-25 147.8 M
SA Steele Creek CLO 2019-2 Ltd 2019-03-30 274.3 M
PE Steele Creek Loan Fund I LP 2019-03-30 119.0 M
SA Steele Creek CLO 2017-1 Ltd 2018-03-26 128.3 M
SA Steele Creek CLO 2018-1 Ltd 2018-03-26 127.1 M
SA Steele Creek CLO 2018-2 Ltd 2018-03-26 134.2 M
SA Steele Creek CLO 2019-1 Ltd 2018-03-26 231.4 M
SA Steele Creek CLO 2016-1 Ltd 2016-03-29 99.2 M
SA Steele Creek CLO 2015-1 Ltd 2015-03-31
SA Steele Creek CLO 2014-1R Ltd 2014-01-23 79.0 M
AUM Breakdown Accounts AUM ($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 0 0.0
(e) Business development companies 1 0.1
(f) Pooled investment vehicles 10 1.6
(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 11 1.7
By Discretionary
Discretionary 11 1.7
Non-Discretionary 0 0.0
Total 11 1.7
By Non-United States Persons
Non-United States Persons 1.5
United States Persons 0.2
Total 11 1.7
Firm Profile (Form ADV)
Discretionary AUM$0.2B
ServesInstitutional
Fund TypesPrivate Equity
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