Advisory Business
OCM is a Florida limited liability company formed on April 2, 2014, and maintains its
principal place of business in Tampa, Florida. OCM provides discretionary investment
advisory services to privately offered pooled investment vehicles (each a “Fund” and,
collectively, the “Funds”) exempt from registration under the Investment Company Act
of 1940, as amended. OCM’s principal owners are Michael Babb and Benjamin Moe. Mr.
Babb serves as the Firm’s Chairman and Mr. Moe serves as the Firm’s sole Managing
Partner.
OCM pursues its investment strategy through managing the Funds and will have broad
discretion with respect to investment decisions made for the Funds. OCM provides
investment advisory services to a Fund based on the investment objectives and strategies
described in each Fund’s confidential offering memorandum and governing documents
(referred to collectively as “Offering Documents”). Through each Fund’s investment
committee (the “Investment Committee”), OCM will provide advisory services to
each Fund by seeking to invest in opportunities where the target business exhibits certain
fundamental attributes, including: (i) proven, experienced management, (ii) profitability,
(iii)
appropriate size, and (iv) low customer concentration.
For purposes of the Investment Advisers Act of 1940, as amended (the “Advisers Act”),
OCM’s advisory clients are the Funds. OCM will follow the investment strategy described
in the relevant Fund’s Offering Documents.
OCM does not tailor its advisory services to the individual needs of underlying investors
in the Funds. However, OCM reserves the right to enter into side letters and other
agreements and arrangements with certain investors in the Funds that may be provided
terms and conditions that are more advantageous than those set forth in the respective
Funds’ offering materials. Such terms and conditions may include special rights to make
future investments in the Funds or other investment vehicles or accounts managed by
OCM, different transparency rights, reporting rights, different withdrawal/redemption
rights, different fee terms, and/or terms to accommodate an investor’s particular legal, tax
or regulatory requirements.
OCM does not participate in wrap fee programs.
As of December 31, 2023, OCM manages approximately $361,219,000 in regulatory assets
under management, all of which is managed on a discretionary basis.