Belstar Management Company, LLC has been in business since March 2009. Its sole
owner is Daniel Yun who owns 100% of the firm.
The following individuals are the executive officers of Belstar Management
Company, LLC and are also the individuals responsible for determining general
investment advice given to advisory clients:
Daniel Yun (Born 1967) is the Chief Executive Officer, Head Portfolio Manager, and
Chief Compliance Officer of Belstar Management Company, LLC. From 1998 to
2005, Mr. Yun was the Managing Partner of Voyager Advisors, LLC, a special
situations hedge fund based in New York. Before that, Mr. Yun held senior positions
in the sales and trading divisions of Lehman Brothers and Goldman Sachs in New
York. Mr. Yun graduated from the United States Military Academy at West Point with
a Bachelor of Science in Economics in 1989. He was commissioned as a second
lieutenant in the U.S. Army, and served two tours of duty as a company commander in
Korea. While in the U.S. Army, Mr. Yun completed Airborne and Air Assault School
(attended Ranger Schools but did not complete), and obtained a Master in Public
Administration from the University of Oklahoma.
Joonho Lee is an executive and director of Belstar Management Company, LLC. Mr.
Lee has extensive experience in project sourcing and analysis, and investment
structuring for major Korean institutions including pension funds, securities
companies, insurance companies, and corporations. Prior to joining Belstar, Mr. Lee
was the Founder and CEO of Cretium Capital LLC, an advisory firm for cross border
investment between Korean investment capital and US alternative investment
opportunities. Prior to that, Mr. Lee was a Vice President at KPMG Financial Advisory
Service and managed over 10 corporate M&A and loan transactions including non-
performing loans with aggregate principal balance of $20 billion. Mr. Lee received a
Bachelor of Arts in Social Science from Yonsei University and an MBA from New
York University's Leonard N. Stern School of Business.
Belstar Management Company, LLC serves as the investment manager (“Investment
Manager”) to a Cayman Islands exempted segregated portfolio company (the Belstar
Credit Opportunities Fund, Ltd.) which operates as a private investment fund (the
“Fund”). In this capacity, Belstar Management Company, LLC (or its Sub Advisors)
receive management fees, typically between 1.50% and 1.72% per annum of the
assets under management and an incentive allocation or incentive fee based upon the
net profits of the Fund.
See Fees below.
The management fees and incentive fees are specified in the private placement
memoranda and investment management agreement for the Fund. In addition,
Belstar Management Company, LLC may, and has, entered into agreements with
certain investors in the Fund granting them, among other things, portfolio
transparency, fee waivers or reductions, interests having different voting rights or
restrictions, additional or different Fund reports, and different or more favorable
investment terms.
The investment management agreement between Belstar Management Company,
LLC and the Fund may be terminated by the Fund prior to the expiration date. The
investment management agreement specify how soon, and upon what conditions,
an early termination will take effect after notice of termination is received from the
Fund (e.g., 90 days after notice is received). Investors in the Fund are not parties to
the investment management agreement with Belstar Management Company, LLC;
however, the Fund provides the investors, under certain conditions, rights to
withdraw from the Fund. The Fund has the option to impose significant restrictions
on such withdrawals. The withdrawal/redemption rights of investors in the Fund are
set forth in the private placement memoranda and other documents related to
making an investment in the Fund.
Individuals involved in determining or giving investment advice to the Fund have
practical and business experience in dealing with a wide range of investment
instruments, as well as practical and business experience with the operations and
investment structure of the relevant investment.
Investors in the Fund are generally limited to those who qualify as (a) “accredited
investors” within the meaning of Regulation D under the Securities Act of 1933, as
amended, (b) “qualified purchasers” within the meaning of the Investment Company
Act of 1940, as, and/or (c) “qualified clients” within the meaning of Rule 205-3 of the
Investment Advisers Act of 1940, as amended. Generally, investors must invest a
minimum amount in order to make an investment in a Fund, which minimum amounts
range between $5,000,000 and $10,000,000 per investor, are set forth in the private
placement memoranda and Subscription Agreements for the Fund. The directors of
the Fund, who are affiliated with Belstar Management Company, LLC, have the option
to accept, in their discretion, lesser investments from any particular investor. They
also have the right, in its sole and absolute discretion, to accept, or to decline to
accept, any investment, in whole or in part for any or no reason.
Belstar Management Company, LLC, in its sole discretion, has the authority, for and
in the name of the Fund, to determine the allocation of the Fund assets and the
timing of such allocations in an attempt to meet the Fund objective as stated in the
Fund’s private placement memoranda. In addition, while Belstar does not have the
authority to withdraw client funds or securities, it has the authority to direct the
custodian to pay the Fund’s expenses (usually on a monthly basis), and to instruct
the custodian to pay redemptions back to the original investors. The discretion of
Belstar Management Company, LLC to purchase on behalf of the Fund certain types
of assets and/or securities in certain amounts are limited by the terms set forth in the
Fund’s private placement memoranda. Such authorities and limitations are disclosed
to prospective investors prior to making any investment in the Fund.
Belstar Credit Opportunities Fund, Ltd. (the “BCOF Ltd.Fund”) was launched in
September 2012. The approximate value of assets under management in the BCOF
Ltd. Fund at December 31, 2017 was approximately $93 million. The BCOF Ltd
Fund’s objective is to take advantage of credit market dislocations caused by
European sovereign credit crisis to generate attractive returns. The Fund, through its
three different Segregated Portfolios, invests in (i) investment grade debt including
single-issuer obligations as well as CLOs and CDO tranches (“Class A-1 Investment
Grade”) and (ii) non-investment grade debt and unrated loans, including participations
in structured loans facilities related trade and other asset secured finance (“Class B
Diversified” and “Class B-1 Trade Finance”). Belstar Management Company. LLC
engaged a Sub-Investment Manager (Inmost Discovery Capital, LLC) to manage the
Class B Diversified Segregated Portfolio. No guarantees can be made that the BCOF
Ltd. Fund’s objectives will be achieved, nor can guarantees be made that the Fund
portfolios will not lose principal.
Belstar Management Company, LLC does not participate in, or advise, wrap
fee programs; does not have any managed accounts; and does not have
any client accounts other than the Fund described above.
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Belstar Management Company, LLC serves as investment manager to Belstar Credit
Opportunities Fund Ltd. which operates as a private investment funds. In this
capacity, Belstar Management Company, LLC (and/or the Sub-Investment Manager)
receive management fees, typically between 1.50% and 1.72% per annum of the
assets under management, and to the extent imposed, an incentive allocation or
incentive fee based upon the net profits of the Fund.
The management fees and incentive fees are specified in the Fund’s private
placement memoranda and investment management agreement. In addition, Belstar
Management Company, LLC has entered into agreements with certain investors in the
Fund granting them, among other things, portfolio transparency, fee waivers or
reductions, interests having different voting rights or restrictions, additional or different
reports, and different or more favorable investment terms.
DetailsofFeesandExpensesfortheFundManagementFeesInvestors in Belstar Credit Opportunities Fund, Ltd. pay, on a monthly basis, a
management fee (the “Management Fee”) in respect of the services provided by
Belstar Management Company, LLC (or its Sub-Investment Manager) each year until
the Fund’s final liquidating distribution. For the Belstar Credit Opportunities Fund, Ltd
the management fee is payable monthly in arrears and equal to 0.125% (1.5% per
annum) of Net Asset Value for Class A-1 and Class B-1 Investors and equal to
0.1433% (1.72% per annum) of Net Asset Value for Class B Investors. Belstar
Management Company, LLC has the option, in its sole discretion, to waive all or a
portion of the Management Fee due in respect of any investor in the Fund.
IncentiveAllocationFor the Belstar Credit Opportunities Fund, Ltd (all classes) the Fund pays to the
Investment Manager (or its affiliate) a 20% Incentive Allocation on an annual basis
following the end of each fiscal year over an 8% Net Return. The Incentive Allocation
is calculated on a cumulative basis and is not payable until prior net losses (a “loss
carry forward”) with respect to a Series are recouped (excluding any Incentive
Allocation and Management Fees from the calculation of such net losses) and the Net
Asset Value exceeds its high water mark. The high water mark is the greater of (i) the
subscription price per Share of the Series and (ii) the highest previous Net Asset Value
per Share of the Series. “Net Return” means the Net Asset Value of an investor’s
shares in the Fund at the end of the applicable fiscal year minus the Net Asset Value
of the investor’s shares at the beginning of the applicable fiscal year, adjusted as
appropriate to reflect redemptions.
OrganizationalandInitialOfferingCosts
The Fund pays for their organizational expenses, which are amortized over a period of
sixty (60) months from the date of the commencement of the Fund’s investment
activities. The Fund is also responsible for all of the necessary expenses of their
operation including, without limitation, the cost of maintaining the Fund's registered
office in the Cayman Islands, the Fund's annual Cayman Islands registration fees,
insurance costs, fees in connection with custody of the Fund’s assets, any brokerage
commissions, research expenses, Directors’ fees, legal and auditing expenses,
accounting, Fund administration, investment and compliance related consultants and
other service provider expenses, any investment related travel costs, expenses for
preparation of the Fund’s annual reports and other financial information and similar
ongoing operational expenses. Any allocation of shared expenses to different Fund
classes are done on an equitable basis as determined by the Investment Manager in
consultation with the Fund’s administrator and are audited by the Fund’s auditors.
AdditionalFeesandExpensesAdvisory fees payable to Belstar Management Company, LLC and its affiliates do not
include all the fees that the Fund pays when Belstar Management Company, LLC
purchases, sells, and manages Fund investments and the Fund. The following lists of
fees or expenses are what the Fund pays directly to third parties, whether investments
are being purchased, sold or held by the Fund. Fees are charged by sub advisors,
independent broker dealers, custodians, or service providers, as applicable.
Belstar Management Company, LLC does not receive, directly or indirectly any of
these fees charged. They are paid by the Fund to the brokers, the custodian, or other
service providers. The fees include, but are not limited to:
• Brokerage commissions;
• Transaction fees;
• Exchange fees;
• SEC fees;
• Advisory fees charged by Sub-Investment Managers;
• Custodial Fees;
• Wire transfer and electronic fund processing fees;
• Commissions or mark-ups / mark-downs on security transactions; or,
• Legal and Compliance fees.
Belstar Management Company, LLC does not have, nor does it employ, any
employee that receives (directly or indirectly) any compensation from the sale of
securities or investments that are purchased or sold for the Fund to which it provides
investment advisory services. As a result, Belstar Management Company, LLC is a
“fee only” investment adviser. Belstar Management Company, LLC does not have
any potential conflicts of interest present that relate to any additional (and un-
disclosed) compensation from investors or Fund assets that Belstar Management
Company, LLC manages.
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Belstar Management Company, LLC serves as investment manager to the Fund
which operates as a private investment fund. In this capacity, Belstar Management
Company, LLC receives management fees and to the extent imposed, an incentive
allocation or incentive fee based upon the net profits of the Fund.
See, Fee
discussion above in Item 5.
The management fees and incentive fees are specified in the private placement
memoranda and investment management agreement of the Fund and in other
documents provided to the Fund investors. In addition, Belstar Management
Company, LLC has entered into agreements with certain investors in the Fund
granting them, among other things, portfolio transparency, fee waivers or reductions,
interests having different voting rights or restrictions, additional or different fund
reports, and different or more favorable investment terms.
In addition, as more fully described in Item 5 above, Belstar Management Company,
LLC does charge performance-based fees. The Fund have "claw back" features that
could require Belstar Management Company, LLC to return a portion of already paid
out performance fees at a future date. Any such obligations are calculated and
monitored by the Fund’s Administrators and by Belstar Management Company, LLC
and reported in the audited financial statements of the Fund.
Further, Belstar Management Company, LLC does not engage in side-by-side
management of both mutual funds and hedge funds simultaneously.
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Belstar Management Company, LLC serves as investment adviser to the Fund and
has no other Clients.
Investors in the Fund are generally limited to those who qualify as (a) “accredited
investors” within the meaning of Regulation D under the Securities Act of 1933, as
amended, (b) “qualified purchasers” within the meaning of the Investment Company
Act of 1940, as, and/or (c) “qualified clients” within the meaning of Rule 205-3 of the
Investment Advisers Act of 1940, as amended. Generally, investors must invest a
minimum amount in order to make an investment in the Fund, which minimum
amounts range between $5,000,000 and $10,000,000 per investor, are set forth in the
private placement memoranda for the Fund. The Directors of the Fund (who
effectively act as the general partner of the Fund and who are employees or affiliates
of Belstar Management Company, LLC,) have the option to accept, at their discretion,
lesser investment amounts from any particular investor. The Directors of the Fund
also have the right, in their sole and absolute discretion, to accept, or to decline to
accept, any investment, in whole or in part for any or no reason.
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Investing in securities involves risk of loss that investors should be prepared to bear
such loss.
MethodsofAnalysis,InvestmentStrategies
The Belstar Credit Opportunities Fund Ltd. was formed to take advantage of the market
dislocations deriving from the European sovereign credit crisis to generate attractive
returns. The investment objective is to make credit investments in securities, loans/debt
and derivative contracts in strategies that extract value from different markets and
different types of borrowers who have been impacted. Investments are focused on
providing liquidity to support fundamentally sound borrowers whose access to or cost of
funds from traditional sources has been negatively affected directly or indirectly as
European and other lenders have stepped back from the credit markets.
The Fund invests in (i) investment grade and non-investment grade debt including
single-issuer obligations as well as CLOs and CDO tranches; and (ii) unrated
corporate loans, including participations in structured loan facilities related to trade and
other asset secured finance. The Fund may use both cash and derivative contracts to
gain exposure to its targeted asset classes. There can be no assurance that the
investment objective of the Fund will be achieved.
The investment programs of the Fund are speculative and entail substantial risks.
Since market risks are inherent in all investments to varying degrees, there can be no
assurance that the investment objective of the investment vehicles will be achieved or
that the investment vehicles will be profitable, and certain investment practices
employed by the Investment Manager can, in some circumstances, increase any
adverse impact on the investment portfolio.
RiskofLoss
All investments in securities and loans include a risk of loss of principal (invested
amount) and loss of any profits that have not been realized (the securities and loans
were not sold to “lock in” the profit). Stock markets, bond markets, and the securities
and debt markets in general, fluctuate substantially over time. In addition, positive
performance of any investment is not guaranteed. As a result, there is a risk of loss
to the assets that in not in our control.
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Belstar Management Company, LLC is obligated to disclose any disciplinary event
that would be material to a client when evaluating Belstar Management Company,
LLC to initiate a Client / Adviser relationship, or to continue a Client /Adviser
relationship with Belstar Management Company, LLC. This statement applies to our
Firm, and to every employee.
Belstar Management Company, LLC does not have any legal, financial or other
disciplinary items to report.
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Belstar Management Company, LLC does not have any management personnel that
are registered, or have an application pending to register, as a broker-dealer,
registered representative of a broker-dealer, futures commission merchant,
commodity trading advisor, or an associated person of any of these entities.
Belstar Management Company, LLC is related to Belstar Holdings, LLC; EMP Belstar
Corp. and EMP Belstar LLC.
• Belstar Holdings, LLC is owned by Daniel Yun and sponsor of the Belstar
Credit Opportunities Fund, Ltd.
• EMP Belstar LLC is 50% owned by Daniel Yun and is a sponsor, managing
member and limited partner for private equity investments.
The above entities share resources and have the same location as Belstar
Management Company, LLC.
Belstar Management Company, LLC is also related to EMP Belstar Corp.
• EMP Belstar Corp., located in Seoul, South Korea, is owned by Daniel Yun and
Joonho Kim and is the General Partner of the DMSE Global Strategic Growth
Fund, L.P.; a fund for Korean institutional investors that owns securities of
companies related to the shipbuilding industry. EMP Belstar also performs
investor relation services for the Fund managed by Belstar Management
Company, LLC. EMP Belstar Corp. share resources, but does not have the same
location as Belstar Management Company, LLC.
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AndPersonalTrading
In accordance with Section 204, Rule 204A-1 under the Advisers Act, Belstar
Management Company, LLC has adopted its Code of Ethics and policy regarding
insider trading. The purpose of the Code of Ethics is to establish guidelines and
procedures that are reasonably designed to identify and prevent employees who have
knowledge of Belstar Management Company, LLC’s investments (and investment
intentions) from breaching their fiduciary duties to Belstar Management Company,
LLC’s clients, and to address other situations that pose a real or potential conflict of
interest or the appearance of a real or potential conflict of interest.
Our Code does not prohibit personal trading by employees (or our firm). As a result,
we have the ability to purchase or sell the same or similar securities (or securities that
are suitable for an employee or related account but not suitable for any client) at the
same time that Belstar Management Company, LLC places transactions for the Fund.
Such purchases must be approved first by the Chief Compliance Officer.
Belstar Management Company, LLC will provide a copy of its Code of Ethics
upon request.
The employees of Belstar Management Company, LLC have the ability to invest in
the Fund, which creates a possible conflict of interest among Belstar Management
Company, LLC, its employees and the investors in the Fund. The conflict arises in
that Belstar Management Company, LLC earns fees based on the advice given to the
Fund and on the performance of the Fund. The conflict is mitigated by the policies
and procedures in place at Belstar Management Company, LLC which require
adherence to the firm’s Code of Ethics and personal trading policies. In addition, the
Chief Compliance Officer for Belstar Management Company, LLC, Daniel Yun, is
responsible for the oversight and compliance of Belstar Management Company, LLC.
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Daniel Yun is the head Portfolio Manager of the Belstar Credit Opportunities Fund
Ltd. and Belstar Credit Opportunities Fund LLC. In this role he is responsible for
selecting or recommending broker-dealers for the funds’ transactions in securities
and for determining the reasonableness of their compensation.
In order to accomplish this Mr. Yun works with a variety of counterparties, such as
RBS Securities, Goldman Sachs, Barclays Capital, Credit Suisse, Bank of America,
and Deutsche Bank if and when transactions are executed.
Belstar Management Company, LLC receives basic published research (research that
is made available for free to all customers of the specific firm) but does not receive
other products or services other than execution from broker-dealers or a third party in
connection with client securities transactions (“soft dollar benefits”).
Belstar Management Company, LLC does not consider, in selecting or
recommending broker-dealers, whether Belstar Management Company, LLC or a
related person receives client referrals from a broker-dealer or third party.
Belstar Management Company, LLC does not have an incentive to select or
recommend a broker-dealer based on Belstar Management Company, LLC interest in
receiving client referrals, rather than on clients’ interest in receiving most favorable
execution.
Belstar Management Company, LLC does not direct client transactions to a
particular broker-dealer in return for client referrals.
Belstar Management Company, LLC does not routinely recommend, request or
require that the Fund execute transactions through a specified broker-dealer. Belstar
Management Company, LLC and the broker-dealers with which it transacts business
are not affiliates nor have another economic relationship that creates a material
conflict of interest.
Belstar Management Company, LLC does not aggregate the purchase or sale of
securities for various client accounts, as this is a function left to the Fund that is the
client of Belstar Management Company, LLC.
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The investment management of the Fund is under continuous review with regard to
investment policy objectives and the investment objectives of the Fund. Fund
investment activities are continuously reviewed by Daniel Yun, the head Portfolio
Manager, the Chief Executive Officer and Chief Compliance Officer of Belstar
Management Company, LLC.
Unless requested otherwise, investors in the Fund will receive written
reports/statements on a monthly basis directly from the Fund’s Administrator,
Maitland Administration, Ltd (or Maitland Administration (US) LLC) or from
Flemming Financial Services, P.C. (who provides sub-administration services
for the Fund).
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Belstar Management, LLC has no arrangements for client referrals. However, Belstar
Holdings, LLC and its affiliates have historically, from time–to-time, entered into
marketing agreements with third party firms to help distribute to prospective investors
interests in the Fund. Pursuant to these agreements, a portion of the management
and/or incentive fees received by Belstar Management Company LLC, or an affiliate,
from the Fund are shared with the referring firms.
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Belstar Management Company, LLC does not maintain custody of client or the Fund
securities or funds. All funds and securities are held by DMS Bank and Trust LTD, or
prime brokers as qualified custodians for the Fund. Investors in the Fund are provided
with statements for the Fund at least on a quarterly basis from Maitland Administration,
Ltd and Maitland Administration (US) LLC and as applicable, from other administrators
or custodians. Belstar Management Company, LLC confirms the accuracy and delivery
of the statements to Fund investors.
While the administrators/custodians for the Fund provide Fund investors account
information directly, Belstar Management Company, LLC from time-to-time upon
request will provide information to investors regarding the Fund. Fund investors
should carefully review such information for accuracy. In this instance, Belstar
Management Company, LLC urges investors to compare the Fund information
received from the administrators/custodians and the information provided by Belstar
Management Company, LLC. Note, however, that the administrator’s/custodian’s
statement is the official record of the Fund.
Belstar Management Company, LLC provides to investors in the Fund audited
financial statements of the Fund within 120 days of the end of the fiscal year
(December 31). Stout, Causey & Horning, an independent auditor registered with the
Public Company Accounting Oversight Board, was engaged in December 2018 to
perform prepare/audit financial statements as of December 31, 2018.
Belstar Management Company, LLC is aware of no circumstance where its
financial condition would be such as to be reasonably likely to impair Belstar
Management Company, LLC’s ability to meet contractual commitments to Fund
investors.
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Belstar Management Company, LLC has discretionary authority to manage
transactions on behalf of the Fund. Investors in the Fund are generally limited to those
who qualify as (a) “accredited investors” within the meaning of Regulation D under the
Securities Act of 1933, as amended, (b) “qualified purchasers” within the meaning of
the Investment Company Act of 1940, as, and/or (c) “qualified clients” within the
meaning of Rule 205-3 of the Investment Advisers Act of 1940, as amended.
Generally, investors must invest a minimum amount in order to make an investment in
a Fund, which minimum amounts range between $5,000,000 and $10,000,000 per
investor, are set forth in the private placement memoranda for the Fund. The Directors
of the Fund who are employees/affiliates of Belstar Management Company, LLC have
the option to accept at their full discretion lesser investments from any particular
investor. The Directors of the Fund also have the right, in their sole and absolute
discretion, to accept, or to decline to accept, any investment, in whole or in part for
any or no reason.
Belstar Management Company, LLC, in its sole discretion, shall have the authority, for
and in the name of the Fund, to determine the allocation of the Fund’s assets and the
timing of such allocations in an attempt to meet the Fund’s objective as stated in the
Fund’s private placement memoranda and other fund documents, including, without
limitation, to pay expenses of the Fund, or to fund redemption requests. The discretion
of Belstar Management Company, LLC to purchase on behalf of the Fund certain
types of assets and/or securities in certain amounts is limited by the terms set forth in
the Fund’s private placement memoranda. Such limitations are disclosed to
prospective investors prior to making any investment in the Fund.
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As noted above, Belstar Management Company, LLC has full discretionary authority
over the Fund’s investment and sales activities. Belstar Management Company, LLC
does not have custody of the Fund’s securities or fund’s. Belstar Management
Company, LLC has no financial commitment that impairs its ability to meet
contractual and fiduciary commitments to clients, and has not been the subject of a
bankruptcy proceeding.
Belstar Management Company, LLC does not require or solicit prepayment of more
than $1,200 in fees per client, six months or more in advance.
Item19–RequirementsforState-RegisteredAdvisersNot Applicable - Belstar Management Company, LLC is registered with the U.S.
Securities & Exchange Commission.
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