True Capital Management LLC

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True Capital Management LLC
CRD #142962
SEC #801-67503
CIK #0001697333
AUM
Employees 37 (38% Investors, 5% Brokers)
Fees
Minimum
Phone415-538-3600
Address101 Montgomery Street
San Francisco, CA 94104
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($M)
18001440108072036002007201320192025
Fees and Compensation — Form ADV Part 2A (3/30/2023) [Brochure]
Item 5. Fees and Compensation
ASSET BASED FEE SCHEDULE:
Investment advisory fees are based on the following schedule

                    Investment Management Services
            Household Value ($)            Annual Fee (%)
               $0-$10,000,000                   1.00%
          $10,000,001-$20,000,000               0.90%
          $20,000,001-$50,000,000               0.75%
          $50,000,001-$75,000,000               0.60%
          $75,000,001-$100,000,000              0.50%
               $100,000,001+                  CUSTOM
An investment management fee of up to 2% may be charged on client assets held in certain private equity funds.

FLAT ANNUAL FEE:
Business Management Services - based on level of service:            $5,000 - $150,000:

In addition to the advisory fee for Investment Management Services, a flat fee for Business Management Services may be
assessed on a monthly or quarterly basis. Fees are deducted directly from the Client's Account unless other arrangements are
agreed upon. Investment Management Fees are deducted directly from the client’s brokerage accounts held at Pershing, LLC.
Business Management fees are deducted from the client’s bank account at First Republic Bank or City National Bank. Please
refer to Item 15 – Custody for more details.

TCM may charge a one-time, fixed consulting fee of up to 5% on the amount of assets a client is investing in certain alternative
or private equity deals. The fixed consulting fee is charged to cover TCM’s time, legal costs and other miscellaneous expenses
incurred.

Fees are typically paid quarterly in advance based upon the market value of the account on the last day of the prior quarter.
When the advisory agreement begins or ends in the midst of a quarter or month, or when material cash flows come into the
account, a pro-rated calculation will be made and the appropriate fee amount will be debited or credited to the account. All
fees are negotiable based on individual client circumstances and at the discretion of TCM.

Investment advisory agreements can be cancelled at any time for any reason, by either party, upon receipt of a 30-day written
notice.

Advisory personnel of TCM, through True Capital Insurance Services (TCIS), an insurance entity licensed in CA, FL, TX,
and NY, may receive commissions for the recommendation of /sale of annuities and other insurance products. Although
TCM’s advisory personnel endeavor at all times to put the interests of the client first, clients are informed and should be
aware that the receipt of commissions, in their separate capacities as insurance agents, itself could create a conflict of interest
and may affect the judgment of these individuals when making recommendations. This conflict of interest is disclosed to
clients.

PRIVATE FUND MANAGEMENT FEES:
TCM does not charge an “investment advisory” fee for serving as investment advisor on the Private Funds. Instead, TCM or
an affiliated TCM Company will serve as General Partner or Managing Member to the Private Funds. As General Partner or
Managing Member, TCM or its affiliate will receive an annual management fee based on the Private Fund’s total assets or
contributed capital, in lieu of an investment advisory fee. The fee generally ranges up to 2% per year based on contributed
capital and continue through the investment period of the Private Fund. The annual management fee is computed quarterly,
and in most cases in arrears. The fee will be deducted directly from the Private Fund. Each Private Fund will set forth its
specific fee structure in its applicable PPM, LLC Agreement as well as in the Subscription Agreement executed by the client.
The client’s fee is calculated based on the amount of the client’s contributed capital and is allocated to the client on a quarterly
basis. The fee expense reduces the client’s capital account balance within the private fund. TCM will charge a fixed fee
ranging up to $50,000 for due diligence conducted on behalf of the True Capital Real Estate Funds.

For clients who invest directly in TCM Private Funds, the value of their investment in the Private Fund will be included in
their overall Investment Management Fee if TCM, or its affiliate serving as General Partner, does NOT charge a management

fee through the private fund. However, if a management fee is charged by TCM or its affiliate directly through the private
fund, the value of the client’s investment in that fund will be excluded from the quarterly investment management fee.

In addition to the annual management fee, TCM may also receive a performance-based fee as described below. Please see
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2023) [Brochure]
Item 7. Types of Clients
TCM provides services to individuals, high net worth individuals, trusts, corporations and small business entities. TCM also
serves as investment adviser to privately offered, pooled investment vehicles (i.e. Private Funds). TCM does not impose a
minimum investment amount in order to engage our services, but all clients must execute a standard client contract.
Sector Form 13F Holdings Value ($M)
Apple Inc 12.6
Palantir Technologies Inc 8.0
Facebook Inc 5.8
Nvidia Corp 3.9
Tesla Motors Inc 3.8
Alphabet Inc 3.8
Alphabet Inc 3.5
Coinbase Global Inc 3.4
Amazon Com Inc 3.2
Microsoft Corp 2.6
View All
Holdings by Sector ($M)
15012090603002022202220232024
Type Form D Funds Date Sold AUM
VC True-Cresset Palantir LLC [2021-03-26] 11.2 M 33.4 M
Offered $11,210,000 · Filed 2020-09-03 (D) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $25,000 · Duration One year or less · Net Assets Decline to Disclose
VC True-Es [2021-03-26] 5.5 M 17.3 M
Offered $5,515,000 · Filed 2020-09-02 (D) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $5,000 · Duration One year or less · Net Assets Decline to Disclose
VC True Capital Ventures II LLC - Series F [2019-03-29] 2.1 M 1.7 M
Offered $2,150,000 · Filed 2017-09-26 (D/A) · Exemption 506(b) · Duration One year or less · Net Assets Decline to Disclose
VC True Capital Ventures II LLC - Series C [2017-03-31] 8.2 M 6.7 M
Offered $8,158,300 · Filed 2016-05-09 (D) · Exemption 506(b) · Duration One year or less · Net Assets Decline to Disclose
VC Spain Fitness Ventures LP 2016-03-30 15.8 M
VC True Capital Ventures LLC - Series IX 2016-03-30 1.8 M
Other Direct Access II LLC 2015-03-30 0.6 M
Other Direct Access LLC 2015-03-30 0.3 M
VC True Capital Ventures LLC - Series III Palantir 2015-03-30 13.9 M
Other Sctcm LLC DBA Premium Lending 2014-03-27 0.8 M
View All
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 194 184.4
(b) Individuals (high net worth individuals) 180 1,043.7
(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 54 363.7
(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 3 1.9
(n) Other 0 0.0
Total 431 1,593.8
By Discretionary
Discretionary 413 1,258.2
Non-Discretionary 18 335.6
Total 431 1,593.8
By Non-United States Persons
Non-United States Persons 24.9
United States Persons 1,568.8
Total 431 1,593.8
Form D Directors Role # Filings # Firms 2011 - 2026
Heather Goodman Director 15 3
Tcmv LLC Director 5 2
NA True Ventures Management Company LLC Director 4 2
True Capital Management LLC Director 3 2
Tcmv Director 2 1
EDGAR Form CIK 2011 - 2026
13F-HR [0001697333]
Firm Profile (Form ADV)
Discretionary AUM$0.4B
Clients6,364,013 (1 non-US)
ServesInstitutional, Retail, Research
Fund TypesPrivate Equity, Real Estate
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