Overview
A. Principal Owners and Background
White Rock Capital Management, L.P., a Texas limited partnership (the “Advisor,” “we” or “us”) was formed in 1997 to
provide investment advisory services to an unregistered private fund (“Fund I”). The principal owners of the Advisor are
Thomas Barton and Joseph Barton through their majority ownership and control of White Rock Capital, Inc., a Texas
corporation, which is the general partner of the Advisor and their ownership of limited partner interests in the Advisor.
B. Types of Advisory Services
In addition to serving as general partner of Fund I, we are an investment manager to two unregistered private funds (“Fund
I” and “Fund II” and collectively, the “Funds”). We expect to serve in similar capacities for other pooled investment vehicles
in the future. Our investment advisory
services include the investing and re-investing in securities, financial instruments
and/or other assets, as described in more detail in Item 8 below, and in accordance with the clients’ investment objectives
and guidelines as described in a fund’s offering and/or governing documents (the “Governing Documents”).
As provided in Governing Documents, we typically have broad investment discretion over Fund assets. In addition, we
provide non-discretionary investment advisory services to a separately managed account (the “SMA” and together with the
Funds, the “Clients”).
C. Assets Under Management
As of March 31, 2024, we have approximately $90,054,600 in assets under management on a discretionary basis and
$55,000,000 on a non-discretionary basis.
D. Wrap Fee Programs
Not Applicable.