Variant Investments LLC

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Variant Investments LLC
CRD #289261
SEC #801-113357
CIK #0001737404
AUM 2,638.5 M (2026-05-29)
Employees 33 (97% Investors, 15% Brokers)
Fees
Minimum
Phone503-563-0700
Address10200 SW Greenburg Road
Portland, OR 97223
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
4.03.22.41.60.80.02010201520212027
Fees and Compensation — Form ADV Part 2A (5/29/2026) [Brochure]
Item 5. Fees and Compensation

Variant is compensated for its advisory services through asset-based advisory fees. In addition,
affiliates of Variant, including VIO GP, are eligible to earn other income as described below. Asset-
based advisory fees and other income, if earned, reduce the returns to equity investors in the Funds.

Registered Fund Fees and Compensation. Variant earns an Investment Management Fee (as
defined in each Registered Fund’s Offering Documents) from each Registered Fund. The
Investment Management Fee is calculated daily, deducted from Fund assets (see below for
additional detail), and payable monthly in arrears. Because the Investment Management Fee is
based on Managed Assets (defined below for each Registered Fund), Variant is paid more if the
Registered Fund uses leverage, which creates a conflict of interest for Variant. Variant seeks to
manage that potential conflict by utilizing leverage only when it determines such action is in the

best interests of the Registered Fund. The Investment Management Fee is paid to Variant before
giving effect to any repurchase of shares in the Registered Fund effective as of that date, and
decreases the net profits or increases the net losses of the Registered Fund that are credited to
Registered Fund shareholders.

For VAIF and ALF, the Investment Management Fee is a percentage based on the Registered
Fund’s average daily “Managed Assets” (defined in the VAIF and ALF prospectuses as total assets
of the Registered Fund (including any assets attributable to leverage that may be outstanding)
minus the sum of accrued liabilities (including accrued fees and expenses and other than debt
representing financial leverage and the aggregate liquidation preference of any outstanding
preferred shares)). VAIF’s annual Investment Management Fee is 0.95%. ALF’s annual
Investment Management Fee is 1.25%.

For Impact, the Investment Management Fee is a percentage based on Impact’s average daily
“Managed Assets” (defined in the Impact prospectus as total assets of Impact (including any assets
attributable to leverage that may be outstanding) minus the sum of accrued liabilities (other than
debt representing financial leverage and the aggregate liquidation preference of any outstanding
preferred shares)). Impact’s annual Investment Management Fee is 1.25%.

Variant does not receive compensation from the Registered Funds beyond the Investment
Management Fee.

Private Fund Fees and Compensation. Variant currently advises only one Private Fund, VIO. The
annual Management Fee (as defined in VIO’s Offering Documents) for VIO payable to Variant is
1.25% of each VIO limited partner’s capital account. Variant has also entered into, or may in the
future, in its sole discretion, enter into additional agreements or “side letters” with certain investors
to provide specific investors specified benefits, in addition to the benefits available to all other
similarly situation investors, such as reduction or waiver of certain fees or other compensation
payable to Variant, waiver of any early redemption lockup periods or fees, or similar benefits and
rights not extended to other investors pursuant to VIO’s Offering Documents.

In addition to the Management Fee payable to Variant by VIO, VIO GP or its delegate is entitled
to receive an incentive allocation of 12.5% of all net profits, if at the end of the fiscal year limited
partners have been allocated at least 6% of net profits. Such allocation is subject to loss
carryforward provisions, all as more fully described in VIO’s Offering Documents.

Because VIO GP is allocated a percentage of VIO’s net profits, Variant’s involvement regarding
valuation of VIO’s portfolio presents a potential conflict of interest because Variant would benefit
from higher valuations. Higher valuations, which are generally associated with better
performance, also result in higher Management Fees paid to Variant. Variant seeks to manage

these conflicts by adhering to its investment policies and procedures, and making all management
decisions based on the best interests of VIO and its limited partners.

Fund Expenses. Each Fund is required to pay all of its related expenses, as defined and set forth
in each respective Fund’s Offering Documents, prior to making any distributions to investors in
the Fund. Fund expenses differ from Fund to Fund, and this is not intended to be a comprehensive
discussion of those expenses (refer to each Fund’s Offering Documents). The expenses payable
by each Fund may include, but are not limited to: costs and expenses relating to the organization
of the Fund; expenses related to the offer and sale of interests in a Fund (including government
filing fees, stamp duties, taxes, legal and accounting fees, printing and mailing expenses,
registration, exemption, and investor subscription filings); expenses of preparing, amending,
printing, and distributing the prospectus, private placement memorandum, sales materials, reports,
notices, proxy materials, and other communications; expenses of preparing, printing, and filing
reports and other documents with government agencies; costs and expenses relating to any
organizational documents; management and administration fees; fees and expenses of any
custodian, sub-custodian, transfer agent, registrar, and other agents; bank service fees and charges
for equipment or services used in communicating information regarding transactions; third-party
administration costs, including investor communications, reporting, audit, and accounting
services; fees and expenses related to negotiating agreements with investors or partners, including
side letters; all fees and expenses directly related to portfolio transactions and positions, including
origination, acquisition (including expenses related to transactions that are not consummated),
holding, monitoring, financing, repayment, or disposition of investments; commissions and
...
Account Minimums and Types of Clients — Form ADV Part 2A (5/29/2026) [Brochure]
Item 7. Types of Clients

Variant only provides discretionary investment advisory services to the Funds, each a pooled
investment vehicle. Each Registered Fund is organized as a Delaware statutory trust, registered
under the 40 Act as a non-diversified, closed-end management investment company. Each
Registered Fund operates as an interval fund under Rule 23c-3, conducting quarterly repurchase
offers at net asset value (“NAV”). Each Registered Fund has elected and intends to qualify as a
regulated investment company for federal tax purposes.

The Private Fund is organized as a limited partnership, exempt from Securities Act registration
under Rule 506(b) of Regulation D and exempt from 40 Act registration under Section 3(c)(7).
Because the Private Fund claims exempt status of Section 3(c)(7) of the 40 Act, all investors in the
Private Fund must be “qualified purchasers,” as that term is defined in the 40 Act. Additionally,
because Variant is entitled to receive performance-based compensation from the Private Fund, all
investors must also be “qualified clients,” as that term is defined in Rule 205-3 under the Advisers
Act.

Investors in any Fund must satisfy certain eligibility and suitability requirements, as described in
each Fund’s Offering Documents. For example, each Fund’s investment minimum (subject to
waiver by each Fund’s manager) is as follows: $1,000,000 for VAIF and Impact; $50,000,000 for
ALF; $5,000,000 for VIO. Variant does not provide any investment advice to investors in the
Funds, or to other investors. The Funds are Variant’s only clients.
Type Form D Funds Date Sold AUM
Other Variant Income Opportunities Fund LP 2026-02-20 20.1 M
HF Variant Alternative Income Fund LP [2017-11-08] 10.0 M 18.5 M
Filed 2017-10-23 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($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 3 2.6
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 1 0.0
(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 4 2.6
By Discretionary
Discretionary 4 2.6
Non-Discretionary 0 0.0
Total 4 2.6
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 2.6
Total 4 2.6
Form D Directors Role # Filings # Firms 2011 - 2026
Curtis Fintel Executive Officer 5 3
Robert Elsasser Executive Officer 1 1
Jerald Hayes Executive Officer 1 1
EDGAR Form CIK 2011 - 2026
3 [0001737404]
Firm Profile (Form ADV)
Clients3
ServesInstitutional
Fund TypesHedge Fund
Form 3/4/5 Subject 2011 - 2026
Variant Alternative Lending Fund
Variant Investments LLC
Variant Alternative Income Fund
Variant Impact Fund
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