Firm Description and Principal Owners
Great Elm Capital Management, Inc. is a Delaware corporation with its principal office at 3801 PGA Boulevard,
Suite 603, Palm Beach Gardens, Florida 33410. Great Elm Capital Management, Inc. is registered as an
investment adviser with the Securities and Exchange Commission (the “SEC”) and is subject to the rules and
regulations governing registered investment advisers under the Investment Advisers Act of 1940, as amended
(the “Advisers Act”). Great Elm Capital Management, Inc. was formed in May of 2016. As used in this brochure,
“Great Elm” refers to Great Elm Capital Management, Inc.
The principal owner of Great Elm is Great Elm Group, Inc. (a publicly traded corporation).
Types of Advisory Services
Great Elm manages one or more portfolios invested in debt instruments, equity securities and derivatives
including credit default swaps (“CDS”). Great Elm offers investment advice with respect to both international
and domestic securities.
Great Elm currently provides investment advisory services to several clients: a business development company,
Great Elm Capital Corp. (the “BDC”);; and three private investment funds sponsored by Great Elm, Great Elm
Opportunities Fund I, L.P. - Series A, Great Elm Opportunities Fund I, L.P. - Series D and Great Elm Credit
Income
Fund, LLC (collectively, the “Series Funds”) which are offered to “accredited investors” and “qualified
purchasers” only (each, a “Private Fund,” and together with the BDC, the “Clients”).
Great Elm may manage other pooled investment vehicles or separate accounts, or sub-advise other registered
investment companies, in the future.
Tailored Relationships
Each of the BDC’s and each Private Fund’s investment strategy is set forth in its respective offering documents.
Great Elm makes all investment decisions on behalf of all Clients, subject to the Client’s governing documents
and advisory agreements. Investors in a Client will not participate in the decision of whether or not the Client
makes any particular investment. Along with reviewing this brochure, it is crucial for any investor or prospective
investor in the BDC or a Private Fund to closely review the applicable offering documents with respect to, among
other things, the terms, conditions, and risks of investing.
Wrap Fee Programs
Great Elm does not participate in any wrap fee programs.
Assets under Discretionary and Non-Discretionary Management
As of December 31, 2023, Great Elm had $288,430,348 in regulatory assets under management on a
discretionary basis. Great Elm does not manage assets on a non-discretionary basis.