25 Capital Partners, LLC (“25 Capital”) was formed in April 2011. We specialize in valuing,
acquiring and managing performing, re-performing and non-performing residential and
commercial mortgage loans, other credit instruments, real estate and related assets.
Throughout our history we have been affiliated with the Tavistock Group of companies and its
affiliates. Tavistock is an international private investment organization founded by Mr.
Joseph C. Lewis.
In September 2012, RoundPoint Financial Group, Inc. sold all ownership interests in 25
Capital’s then-parent company, 25 Capital Holdings, LLC, to 25 Capital’s newly-created
parent company, 25 Capital Holdings, Inc. 25 Capital Holdings, Inc. is owned wholly by Sadler
Holdings, Inc. Sadler Holdings, Inc.’s shares are owned by GTC Nominee Limited as nominee
for the Sadler Trust, an irrevocable trust. The Sadler Trust’s trustee is Autumn Bay Ltd., and
the trust’s beneficial owners are Mr. Joseph C. Lewis and his lineal descendants.
25 Capital provides investment advisory services to separately managed accounts (“Separately
Managed Accounts”) and private investment funds (“Private Funds,” and, together with
Separately Managed Accounts, “Investment Vehicles”) that we seek to form with one or more
investors in response to periodic opportunities to purchase mortgage loans, other credit
instruments, real estate and related assets. We form Investment Vehicles for: investors that
are unaffiliated with us; our affiliates, our employees and our affiliates’ employees; and
combinations of the first two categories.
Unless noted otherwise, all information in this
brochure relates to Investment Vehicles with at least one investor that is not affiliated with
us, and does not relate to Investment Vehicles that we form for affiliated investors.
25 Capital Ventures (“Ventures”) was formed in August 2012 as a joint venture between: (a)
25 Capital; (b) Atlantic Asset Management L.L.C., a Delaware limited liability company
(“Atlantic”), an investment adviser registered with the Securities and Exchange Commission
(“SEC”) and otherwise unconnected to 25 Capital; and (c) 25 Capital ACV, LLC (“ACV”), a
company established to receive 25 Capital’s portion of the carried interest distributions (see
Performance-Based Compensation Fees and Side-by-Side Management section below) from
Fund I (as defined in the next paragraph). 25 Capital and its affiliates own and control ACV.
25 Capital is the majority owner and manager of Ventures, and it controls Ventures’ business,
operations and all investment decisions made on behalf of Fund I. In March 2015, Hughes
Capital Management, LLC, a Virginia limited liability company (“Hughes”), a company
unrelated to Atlantic and 25 Capital, purchased Atlantic, merged it with Hughes, and named
the resulting company Atlantic Asset Management, LLC, a Virginia limited liability company
(“New Atlantic”). However, New Atlantic did not purchase any of Atlantic’s rights to receive
any carried interest distributions from Ventures, which Atlantic transferred to a new entity,
AAM Partners Holdings, LLC (“AAM Holdings”), owned by certain former employees of
Atlantic. AAM Holdings was admitted to Ventures as a member at that time. 25 Capital
purchased all of New Atlantic’s interests in Ventures effective December 31, 2015, leaving 25
Capital, ACV and AAM Holdings as Ventures’ members. From December 31, 2015, neither
Atlantic nor New Atlantic has any right to receive any portion of Ventures’ management fees.
Ventures is the investment manager for one Private Fund focused primarily on managing U.S.
residential mortgages and related assets (“Fund I”). Fund I has been closed to new investors
since December 2013 and is Ventures’ only client.
Typically each Investment Vehicle includes a special purpose general partner, managing
member or similar entity controlled directly or indirectly by 25 Capital (each a “General
Partner”). Potential investors should consult the applicable Governing Documents (as defined
below) for more information.
Investments in the Investment Vehicles are not registered under the Securities Act of 1933, as
amended (the “Securities Act”), and the Investment Vehicles are not registered under the
Investment Company Act of 1940, as amended (the “Investment Company Act”). Accordingly,
interests in the Investment Vehicles are offered and sold exclusively to investors satisfying
the applicable eligibility and suitability requirements, either in private transactions within
the United States or in offshore transactions.
Before accepting an investment in an Investment Vehicle, 25 Capital will provide each eligible
potential investor with a copy of the following documents for the Investment Vehicle, each to
the extent applicable to the Investment Vehicle: private placement memorandum; related
advisory or management agreements; limited liability company/partnership agreement; and
any other governing documents (the “Governing Documents”).
Typically, investors may not restrict investments by the Investment Vehicles in any capacity.
Investment restrictions are described in the Governing Documents.
Potential investors should
review the applicable Governing Documents carefully for additional information before
investing in an Investment Vehicle. If there is any inconsistency between the Governing
Documents and this brochure, the Governing Documents’ terms will control.
We do not provide legal, tax or accounting advice or services, and you should not assume we
are providing you such services at any time.
As of December 31, 2019, we managed on a discretionary basis $351,301,070 in regulatory
assets under management.
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25 Capital Partners
For managing an Investment Vehicle, 25 Capital typically receives compensation from fees
based on a percentage of capital under management, carried interest distributions and
certain other fees or expenses related to transactions, all in accordance with the applicable
Governing Documents. Potential investors should review the applicable Governing Documents
to fully understand the total amount of fees to be paid by an Investment Vehicle and,
indirectly, by its investors.
The General Partner of a particular Investment Vehicle will either call capital for
management fees and other expenses or pay such fees and expenses out of current income
and disposition proceeds from the Investment Vehicle. We may negotiate an investor’s fee
depending upon circumstances including, but not limited to, account composition and
complexity, as well as other investor, employee or family relationships, etc. These
negotiations may result in us charging different fees to different investors. We may charge
our affiliates, our employees, our affiliates’ employees, and their family-related accounts a
reduced fee, or no fee, for our services.
In addition to the management fee discussed above, 25 Capital typically receives a
performance-based fee, to the extent allowed by law, usually subject to us meeting certain
goals for the Investment Vehicle. We typically calculate this fee based on a share of capital
gains or capital appreciation of the Investment Vehicle’s assets.
An investor’s ability to withdraw from an Investment Vehicle is limited by the terms of the
applicable Governing Documents. As a consequence, an investor’s ability to terminate the
obligation to pay applicable management fees or carried interest distributions or to terminate
their investment in the Investment Vehicle is limited.
For more specific information regarding fees, potential investors should review the applicable
Governing Documents for the Investment Vehicle in which they consider investing. See
Performance-Based Fees and Side-by-Side Management section below for a further discussion
of fees and the potential conflicts of interest they can create.
25 Capital Ventures
Ventures received a 2.0% per year Management Fee based on Fund I’s total capital
commitments during the investment period. Thereafter, the management fee is 2.0% per
year of capital used for investments, and expenses allocable to investments, that have not
been disposed of or written off prior to the first day of the applicable quarter.
The management fee is payable quarterly and in advance and is pro-rated for partial
quarters. Ventures deducts management fees from Fund I and does not bill investors for
management fees.
In addition to the management fee discussed above, under certain circumstances Ventures
will receive a 20.0% profit distribution, called a carried interest distribution, from Fund I at
least quarterly. Fund I will pay the carried interest distribution only if certain criteria (a
return of client capital plus a preferred rate of return) are met. Fund I’s Governing
Documents contain a full description of the criteria that must be satisfied before Ventures
receives any carried interest distribution. Ventures chose to reduce the management fee and
the carried interest distribution for certain investors, and waived such fees entirely for other
investors employed by Ventures’ members and their affiliates. See the Performance-Based
Fees and Side-by-Side Management section below for a further discussion of fees and the
potential conflicts of interest they can create.
From December 31, 2015, neither Atlantic nor New Atlantic has any right to receive any
portion of Ventures’ management fees. As discussed in the Advisory Business section above,
certain former employees of Atlantic, through AAM Holdings, retain Atlantic’s rights to
receive any carried interest distributions from Ventures. See Other Financial Industry
Activities and Affiliations and Client Referrals and Other Compensation sections below for
further information regarding Atlantic and New Atlantic.
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As described above under the Fees and Compensation section, we typically receive
performance-based fees and carried interest distributions based on the profit distributions to
investors from Investment Vehicles. The fact that a significant portion of our compensation
(and our investment professionals’ compensation) is directly tied to profit distributions
generated by certain Investment Vehicles may create an incentive for us and our professionals
to make investments on behalf of the Investment Vehicles that are riskier or more speculative
than would be the case in the absence of such compensation. To the extent any Investment
Vehicle is not charged a performance fee, we may have an incentive to favor Investment
Vehicles for which we receive a performance fee.
We take the following steps to address any potential conflicts caused by our fee
arrangements:
We use the applicable Governing Documents to disclose our compensation structure
for a specific Investment Vehicle to all potential investors before they invest; and
We provide appropriate training for our employees regarding our duties to our clients,
including treating all clients equitably, regardless of fee arrangement.
Prospective investors should consult the Governing Documents of the applicable Investment
Vehicle for more information on fees.
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25 Capital Partners and 25 Capital Ventures
We provide management and discretionary investment advisory services to Investment
Vehicles directly, as described in the Advisory Business section above. We do not provide
advisory services individually to the investors in the Investment Vehicles. Investment Vehicle
investors may include, but are not limited to, financial institutions, trusts, pension plans and
other entities, as well as individuals. We do not accept investments from all client types, and
many of our Investment Vehicles are subject to restrictions such as minimum investment size.
The minimum commitment for an investor in an Investment Vehicle is generally $1,000,000,
however, we typically have discretion to accept less than the minimum investment amount,
as set forth in the applicable Governing Documents. In addition, we may reduce or raise the
minimum commitment for any future Investment Vehicle. In addition, the Investment
Vehicles may enter into separate agreements, commonly known as “side letters,” with
certain investors, including our affiliates, to provide such investors with additional, or
different, terms than those specifically described in the applicable Governing Documents.
Under certain circumstances, these side letters could create preferences or priorities for such
investors with respect to other investors.
Investors are typically required to meet certain suitability qualifications as described in the
applicable Governing Documents, such as being an “accredited investor” within the meaning
set forth in Rule 501(a) of Regulation D under the Securities Act. Also, investors will be
required to make certain representations when investing in an Investment Vehicle, including
but not limited to, that: (i) they are acquiring an interest for their own account, (ii) they
received, or had access to, all information they deem relevant to evaluate the merits and
risks of the prospective investment; and (iii) they have the ability to bear the economic risk
of an investment in the Investment Vehicle.
Details concerning the relevant investor suitability criteria are contained in the applicable
Investment Vehicle’s Governing Documents.
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25 Capital Partners and 25 Capital Ventures
When acquiring and managing assets for Investment Vehicles, 25 Capital uses an analytical
investment and portfolio management approach. Our investment strategy begins by
identifying potentially attractive opportunities, followed by an asset-level due diligence
process. Our Investment Committee must approve all purchases and sales. We manage the
assets using proprietary analytics and net present value models.
You should understand that no analytic method or investment strategy is riskless.
Participation in an Investment Vehicle is speculative in nature. There is a high degree of risk
and there is the possibility that you could lose your invested capital. There is also no
guarantee that our investment strategy will succeed and be profitable for you.
Investors should understand that 25 Capital’s business depends significantly on our
personnel’s skill and expertise. In particular, if Shaun Ahmad (President) or Scott Shultz
(Managing Director) were to leave 25 Capital, your investment performance may be affected
negatively. Ownership changes may also cause personnel changes. The Tavistock Group and
its affiliates may decide that it is more profitable to sell any of their portfolio companies,
including 25 Capital. If 25 Capital’s ownership structure, described in the Advisory Business
section above, changes, then there is a risk that some or all 25 Capital personnel may leave
the company.
You should also understand the particular risks associated with investments in mortgages and
other real estate-related strategies. Examples of risks in these strategies include, but are not
limited to:
real estate price fluctuations;
mortgage borrower default;
the mortgage could be invalid or unenforceable to pre-existing legal errors or other,
more senior, liens;
mortgage borrower bankruptcy; and
changes in regulations by federal, state and local governments
Though the specific terms may vary depending on the Investment Vehicle, clients typically
cannot withdraw their capital from an Investment Vehicle, nor are clients allowed to transfer
their Investment Vehicle interests without 25 Capital’s consent. Once you commit capital to
an Investment Vehicle, that capital remains committed throughout the Investment Vehicle’s
life, which may be multiple years, and there is no guarantee that any capital will be returned
to you before the Investment Vehicle is dissolved.
The success of Investment Vehicles might depend partially on 25 Capital’s ability to find
suitable investments. 25 Capital faces competition from other purchasers such as banks,
other investment advisors and institutional investors. This competition might result in
increased purchase prices, which might in turn reduce the Investment Vehicle’s returns to
clients.
This section contains only a brief overview of some of the unique risks associated with our
investment strategies. This section is not intended to serve as an exhaustive list or a
comprehensive description of all risks and conflicts that may arise in connection with the
management and operations of the Investment Vehicles. If you are considering an investment
in an Investment Vehicle, you should carefully consider the risks described in the applicable
Governing Documents. You should review the applicable Governing Documents carefully
before deciding to make an investment in an Investment Vehicle. You should also consult your
own advisors, including financial, legal and tax advisors, as you deem necessary before
investing in any Investment Vehicle.
DISCIPLINARY HISTORY 25 Capital Partners and 25 Capital Ventures
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to an investors, or potential investor’s,
evaluation of the adviser or the integrity of the adviser’s management. Neither 25 Capital
nor Ventures nor any of their management persons has any disciplinary events to report.
OTHER FINANCIAL INDUSTRY AFFILIATIONS 25 Capital Partners only
25 Capital uses RoundPoint Mortgage Servicing Corporation (“RoundPoint”), to service
residential mortgage loans owned by Investment Vehicles managed by 25 Capital and
Ventures. 25 Capital and RoundPoint are separate portfolio companies of the Tavistock Group
and its affiliates. Due to the affiliation between 25 Capital and RoundPoint, there is a risk
that the decision to use RoundPoint’s services may not be made solely in clients’ best
interests due to influence caused by the affiliation. Though 25 Capital will always attempt to
engage RoundPoint on terms and conditions at least as favorable as those available from other
mortgage servicers, our affiliated status means negotiations are not at arms-length and may
not be as favorable to the Investment Vehicles or investors as a servicing arrangement with an
unaffiliated company. We will disclose this affiliated relationship in the Governing
Documents for any Investment Vehicle for which RoundPoint will provide services. Unless
disclosed otherwise in the applicable Governing Documents, no RoundPoint or Tavistock
Group representative will make, or participate in making, investment advisory decisions
regarding an Investment Vehicle. No RoundPoint or Tavistock Group employee or
representative serves on 25 Capital’s Investment Committee or Asset Management
Committee.
Prospective investors can find additional information relating to this potential conflict of
interest in the Governing Documents for the applicable Investment Vehicle. Prospective
investors should carefully review the applicable Governing Documents before deciding to
make an investment in an Investment Vehicle.
25 Capital Ventures only
As noted in the Advisory Business section above, Ventures was formed in August 2012 as a
joint venture between: (a) 25 Capital; (b) Atlantic Asset Management L.L.C., a Delaware
limited liability company (“Atlantic”), an investment adviser registered with the Securities
and Exchange Commission (“SEC”) and otherwise unconnected to 25 Capital; and (c) 25
Capital ACV, LLC (“ACV”), a company established to receive 25 Capital’s portion of the
carried interest distributions (see Performance-Based Compensation Fees and Side-by-Side
Management section below) from Fund I (as defined in the next paragraph). 25 Capital and its
affiliates own and control ACV. 25 Capital is the majority owner and manager of Ventures,
and it controls Ventures’ business, operations and all investment decisions made on behalf of
Fund I. In March 2015, Hughes Capital Management, LLC, a Virginia limited liability company
(“Hughes”), a company unrelated to Atlantic and 25 Capital, purchased Atlantic, merged it
with Hughes, and named the resulting company Atlantic Asset Management, LLC, a Virginia
limited liability company (“New Atlantic”). However, New Atlantic did not purchase any of
Atlantic’s rights to receive any carried interest distributions from Ventures, which Atlantic
transferred to a new entity, AAM Partners Holdings, LLC (“AAM Holdings”), owned by certain
former employees of Atlantic. AAM Holdings was admitted to Ventures as a member at that
time. 25 Capital purchased all of New Atlantic’s interests in Ventures effective December 31,
2015, leaving 25 Capital, ACV and AAM Holdings as Ventures’ members. From December 31,
2015, neither Atlantic nor New Atlantic has any right to receive any portion of Ventures’
management fees.
Fund I uses RoundPoint’s services for mortgage loans. Because of the common ownership of
25 Capital and RoundPoint, the servicing agreement for Fund I’s loans was not negotiated at
arms-length and may not be as favorable to Fund I as a servicing arrangement with a
mortgage servicer unaffiliated with 25 Capital. RoundPoint’s then-current fees are disclosed
in Fund I’s private placement memorandum. Ventures appointed certain Fund I investor
representatives to an Advisory Committee. Fund I’s Advisory Committee must approve any
changes to the RoundPoint fees listed in Fund I’s private placement memorandum.
No RoundPoint or Tavistock Group representative makes, or participates in making,
investment advisory decisions regarding Fund I. No RoundPoint or Tavistock Group employee
or representative serves on 25 Capital’s Investment Committee or Asset Management
Committee or the Advisory Committee of Fund I.
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TRADING 25 Capital Partners and 25 Capital Ventures
25 Capital Partners has a written Code of Ethics that includes monitoring employees’ personal
securities transactions in order to seek to avoid conflicts of interest with our transactions on
clients’ behalf. Employees must submit quarterly duplicate statements of their personal
securities transactions and an annual acknowledgement confirming that they have submitted
all required duplicate statements during the previous year. Our Code of Ethics also contains
policies and procedures intended to prevent misuse of material non-public information. A
copy of our Code of Ethics is available to current and prospective investors upon request by
contacting us through the contact information provided on this brochure’s cover page.
Certain inherent conflicts of interest will arise from the fact that 25 Capital and its affiliates
may provide investment management services and conduct investment activities for multiple
Investment Vehicles, their own accounts or family members, friends and other accounts in
which a particular Investment Vehicle has no interest. One Investment Vehicle may be
subject to fees or terms that are more favorable to 25 Capital and its affiliates than those of
any other Investment Vehicle.
25 Capital and its affiliates may give advice and recommend investments to one Investment
Vehicle, which advice or investments may be identical to, or differ from, advice given to, or
investments recommended or bought or sold for, any other Investment Vehicle, even though
their investment objectives may be the same or similar. 25 Capital and its affiliates will
determine how investment opportunities are allocated among the Investment Vehicles they
manage, even though they may face potential conflicts of interest in making such allocations.
25 Capital and its affiliates are not obligated to disclose or refer to an Investment Vehicle any
particular investment opportunity, and 25 Capital may choose not to allocate a particular
investment opportunity to an Investment Vehicle for a wide variety of reasons.
The portfolio strategies employed by 25 Capital, Ventures or their affiliates for one
Investment Vehicle could conflict with the transactions and strategies employed for any other
Investment Vehicle. Conversely, participation in specific investment opportunities may be
appropriate, at times, for multiple Investment Vehicles. In particular, one Investment
Vehicle may make investments alongside one or more other Investment Vehicles. In such
cases, the opportunities will be allocated in a fair and equitable manner among the
Investment Vehicles. 25 Capital may at times allocate certain asset types on a preferential
basis to certain Investment Vehicles managed or advised by 25 Capital or an affiliate that are
in the process of being organized or were recently organized.
To the extent that Investment Vehicles participate in the same investment opportunity, or
use or benefit from a shared service, 25 Capital will allocate expenses in connection
therewith among the Investment Vehicles, and may have a conflict of interest in making such
expense allocations.
Except as set forth in an Investment Vehicle’s Governing Documents, 25 Capital and its
affiliates will not be restricted from forming additional Investment Vehicles, entering into
other investment management relationships or engaging in other business activities, even
though such activities may be in competition with an Investment Vehicle and/or may involve
substantial time and resources of 25 Capital and its affiliates. These activities could be
viewed as creating a conflict of interest in that the time and effort of 25 Capital, and its
employees will not be devoted exclusively to an Investment Vehicle’s business, but will be
allocated between the Investment Vehicle’s business and other business activities of 25
Capital and its affiliates. An Investment Vehicle’s Governing Documents may restrict 25
Capital temporarily from creating or sponsoring an Investment Vehicle with a strategy similar
to that used by an existing Investment Vehicle. For example, the Governing Documents may
restrict 25 Capital from pursuing a strategy similar to the Investment Vehicle’s strategy unless
the Investment Vehicle’s investment period ends, unless the Investment Vehicle has deployed
a specified percentage of committed capital, or unless a certain percentage of the
Investment Vehicle’s investors agree to waive the restriction.
Investors should review the applicable Governing Documents for further information regarding
conflicts of interest.
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25 Capital Partners and 25 Capital Ventures
25 Capital does not ordinarily deal with any financial intermediary such as a broker-dealer,
and commissions are not ordinarily payable in connection with investments made by the
Investment Vehicle because of the nature of the Investment Vehicles’ investments. To the
extent 25 Capital engages an intermediary, we will consider the following factors in selecting
or recommending brokers for transactions and in determining the reasonableness of the
compensation or other payment to the brokerage firms:
quality of support services and technology provided;
trade implementation costs;
value of research and related information provided;
market liquidity provided;
confidentiality of trading intentions;
investment styles (compatibility between us and the broker);
financial stability;
ability to execute difficult trades; and
other factors we may identify periodically.
As deemed appropriate, we will evaluate our brokerage practices periodically and the
reasonableness of compensation or other payment paid to brokerage firms and monitor our
efforts to seek best execution of transactions for the Investment Vehicles.
25 Capital does not have any soft dollar arrangements in connection with brokerage
transactions and does not engage in directed brokerage transactions.
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25 Capital’s Investment Committee reviews all investment acquisition decisions. The
Investment Committee consists of our: President; Managing Director of Capital Markets; and a
Director of Capital Markets. 25 Capital’s Portfolio Management Committee reviews clients’
accounts periodically. Our Portfolio Management Committee consists of our: President;
Managing Director of Capital Markets; two Directors of Capital Markets; and Vice President of
Capital Markets.
25 Capital may provide periodic reports to investors in accordance with the terms of the
applicable Investment Vehicle’s Governing Documents.
Investment Vehicle investors may receive written reports from a fund administrator directly,
as described in the Custody section below.
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25 Capital Partners
Though we do not do so currently, we may enter into written agreements occasionally with
other persons or companies who refer potential investors or investors to us in exchange for a
referral or solicitor fee. That referral or solicitor fee will likely be a percentage of the fee
we receive from the referred investor for our services, including services we provide to
Investment Vehicles in which the investor invests. This means the persons, who may be
licensed investment adviser representatives or broker-dealer registered representatives, or
the companies who refer potential clients to us, will have a financial interest in your
selecting us to provide you services. If you are referred to us through an arrangement such as
this, you will receive a written document disclosing: our arrangement with the solicitor; any
affiliation between the solicitor and us; and a description of the compensation we will pay
the solicitor if you establish an account with us. Please refer to the Brokerage Practices
section for information on other economic benefits we may receive for providing services to
you.
25 Capital Ventures
As noted in the Advisory Business, Performance-Based Fees and Side-by-Side Management,
and Other Financial Industry Affiliations sections above, certain former Atlantic employees
are eligible to receive carried interest distributions from Ventures’ Private Fund. From
December 31, 2015, neither Atlantic nor New Atlantic has any right to receive any portion of
Ventures’ management fees. Please refer to the Brokerage Practices section for information
on other economic benefits we may receive for providing services to you.
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25 Capital or Ventures may be deemed to have custody over the cash and securities held by
an Investment Vehicle because 25 Capital, Ventures or the applicable General Partner serves
as manager, adviser and general partner or managing member (or similar capacity) to such
Investment Vehicle. As required by Rule 206(4)-2 under the Advisers Act (the “Custody
Rule”), 25 Capital maintains cash and securities with an independent qualified custodian.
Any existing or future Investment Vehicle managed by 25 Capital, directly or indirectly, is, or
will be, subject to an annual independent audit, and audited financial statements prepared in
accordance with generally accepted accounting principles are, or will be, distributed to each
Investment Vehicle’s investors in accordance with the Custody Rule.
Depending on an Investment Vehicle’s circumstances and investor requests, we may send
account information as described above in the Review of Accounts section. Unless noted
otherwise in the applicable Governing Documents, investors in a Private Fund will receive
account statements from the Private Fund’s administrator directly on a quarterly basis. You
should review these statements carefully and compare them to statements you may receive
from us for any discrepancies. In addition, we may provide investors with additional reports
in accordance with the applicable Governing Documents or at an investor’s request.
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25 Capital Partners and 25 Capital Ventures
25 Capital generally has discretionary authority to determine the investments in which the
Investment Vehicles invest and to perform the day-to-day investment operations of the
Investment Vehicles, in each case, according to Governing Documents’ terms and conditions.
The Governing Documents may place restrictions on this authority or describe limitations to
it. You should review the applicable Governing Documents in order to understand the
discretion that 25 Capital may exercise with respect to a particular Investment Vehicle.
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Neither 25 Capital nor Ventures has ever filed for bankruptcy and neither is aware of any
financial conditions that could impair its ability to manage the Investment Vehicles.
BROCHURE SUPPLEMENT (Form ADV Part 2B) Shaun Ahmad
25 Capital Partners, LLC
13024 Ballantyne Corporate Place, Suite 425, Charlotte NC 28277
704.426.8849
March 19, 2020
This brochure supplement provides information about Shaun Ahmad that supplements the
25 Capital Partners, LLC (“25 Capital”) firm brochure. You should have received a copy of
that brochure. Please contact 25 Capital at 704.426.8849 if you did not receive the 25
Capital firm brochure or if you have any questions about the contents of this supplement.
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Shaun Ahmad
Year of Birth: 1977
The Johns Hopkins University, BA in Economics, 2000
25 Capital Partners, LLC, President, April 2011 to Present
RoundPoint Capital Group, LLC, President, January 2008 to April 2011
Banc of America Securities, Vice President, June 2000 to November 2007
DISCIPLINARY INFORMATION
This section does not apply to Shaun Ahmad
OTHER BUSINESS ACTIVITIES This section does not apply to Shaun Ahmad
ADDITIONAL COMPENSATION This section does not apply to Shaun Ahmad
SUPERVISION 25 Capital Partners has written procedures in place to supervise the activities of Shaun
Ahmad. Mr. Ahmad is one of the three members of 25 Capital’s Investment Committee,
which operates via majority consent. In addition, 25 Capital Partners monitors the
services and advice provided by Shaun Ahmad through the use of a Portfolio Management
Committee, which reviews the firm’s client accounts on at least a quarterly basis.
Shaun Ahmad is President of 25 Capital Partners. As such, he is not subject to direct
supervision by another employee of the firm, although Mr. Ahmad does report to the
Board of Directors of 25 Capital Holdings, Inc., which can be contacted through Adam
Cyrus, fellow Board of Directors member at 407.909.9000.
BROCHURE SUPPLEMENT (Form ADV Part 2B) Michael Scott Shultz
25 Capital Partners, LLC
13024 Ballantyne Corporate Place, Suite 425, Charlotte NC 28277
704.426.8849
March 19, 2020
This brochure supplement provides information about Michael Scott Shultz that supplements
the 25 Capital Partners, LLC (“25 Capital”) firm brochure. You should have received a copy
of that brochure. Please contact 25 Capital at 704.426.8849 if you did not receive the 25
Capital firm brochure or if you have any questions about the contents of this supplement.
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Michael Scott Shultz
Year of Birth: 1974
The University of South Carolina, BS in Finance, 1997
25 Capital Partners, LLC, Vice President, April 2011 to Present
RoundPoint Capital Group, LLC, Vice President, October 2008 to April 2011
Banc of America Securities, Principal, September 2000 to August 2008
DISCIPLINARY INFORMATION
This section does not apply to Michael Scott Shultz
OTHER BUSINESS ACTIVITIES This section does not apply to Michael Scott Shultz
ADDITIONAL COMPENSATION This section does not apply to Michael Scott Shultz
SUPERVISION 25 Capital Partners has written procedures in place to supervise the activities of Michael
Scott Shultz. Mr. Shultz is one of the three members of 25 Capital’s Investment
Committee, which operates via majority consent. In addition, 25 Capital Partners
monitors the services and advice provided by Michael Scott Shultz through the use of a
Portfolio Management Committee, which reviews the firm’s client accounts on at least a
quarterly basis.
Mr. Shultz’s supervisor is Shaun Ahmad who can be reached at 704.426.8849.
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