Kelly Park Investment LLC, doing business as Kelly Park Capital, is a Delaware limited liability
company formed in September of 2018 and provides discretionary investment advice to private
funds and non-discretionary investment advice to a single non-fund client who is itself a registered
investment adviser. Kelly Park Management LLC is an affiliate and relying adviser of Kelly Park
Investment LLC and serves as the general partner to private funds advised by Kelly Park Investment
LLC. These firms are collectively referred to as “Kelly Park” or the “Firm”. The principal owners
of the Firm are, Dean M. Rubino, Sean E. Westley and Scott A. Fine.
The Firm provides discretionary advisory services solely to the KPC Funds and non-discretionary
advisory services to a third-party investment adviser. The Firm does not offer advisory services
that are primarily for personal, family or household purposes.
Kelly Park primarily provides investment advice with regard to the selection of difficult to source
securities, including private placements in investment funds managed by third parties and direct
investments in private securities. Implementation of this advice is effected through the Firm’s
private funds, collectively “the KPC Funds”, as described below.
KPC Funds:
The KPC Investment Fund comprises a master and two feeder funds, the KPC Investment Master
Fund Ltd, and its respective domestic and offshore feeder funds, KPC Investment Fund LP and KPC
Investment Offshore SPC. The KPC Investment Fund is designed to allow investors, typically under
the guidance of their financial advisor, to customize exposure to investment strategies managed
by third party investment managers, typically though privately offered investment vehicles, (each
an “Underlying Fund”) that have been selected based upon Kelly Park’s investment, operational
and business risk analysis and evaluation of such Underlying Fund and its third-party investment
manager.
Kelly Park may, upon request, assist investors and/or their wealth advisors with understanding the
combined effect of grouping various Underlying Funds together. For example, when requested,
Kelly Park will design model portfolios of Underlying Funds for demonstration purposes based on
investor input factors such as the
allocation size, return mandate, risk sensitivity, and overall
investment objectives.
The KPC PE IPO Fund is a private equity fund composed of a master fund and a feeder fund, the
KPC PE IPO Master Fund Ltd and a domestic feeder fund, KPC Investment Fund LP. The KPC PE
IPO Fund is designed to provide investors access to investments in private company securities
through either direct deals or Underlying Funds.
Non-Discretionary Services:
Kelly Park provides non-discretionary investment management services to select institutional
clients regarding private pooled investment vehicles, including hedge fund and private equity
funds (also “Underlying Funds”) managed by third-party investment managers. The Firm provides
these services in accordance with the non-discretionary consulting agreements, advisory
agreements and client organization documents.
Non-discretionary services include continuous and ongoing management and supervisory services
including, but not limited to, manager sourcing, selection, evaluation, asset allocation and ongoing
monitoring of Private Funds to these portfolios on a non-discretionary basis, where each client
makes the ultimate decision regarding each investment. The services provided by the Firm include
sourcing, vetting, evaluating, selecting and recommending one or more Underlying Funds that the
Firm reasonably believes would be appropriate investment vehicles for the client based on the
investment objectives and strategies of the client, as well as confidential information, research
and analyses that the Firm compiles about certain Underlying Funds.
Kelly Park provides investment advisory services to the KPC Funds based on the investment
objectives described in the KPC Funds' offering documents, which permit Kelly Park some ability
to tailor investment advice to individual investors as described further in the fund documents.
Kelly Park tailors its investment advice to non-discretionary clients based on their individual needs
as documented in the investment advisory agreement.
As of December 31, 2023, the Firm had approximately $28,161,000 in assets under management
on a discretionary basis in the KPC Funds and $100,000,000 in assets advised on a non-
discretionary basis.