Form ADV Part 2A, Item 4
CFT Capital Management, LLC (“CFTCM”), was organized in January 2022 as a Delaware limited liability
company. Warren Woo and Carey Kim are the principal owners of CFTCM. CFTCM offers investment advisory
services on a discretionary basis primarily to a private pooled investment vehicle and investment advisory
services on a non-discretionary basis to family offices.
The pooled investment vehicle to which CFTCM provides advisory services is referred to herein as the “Fund.”
The Fund is structured as a U.S. limited partnership that is not registered or required to be registered under the
Investment Company Act of 1940, as amended (the “Investment Company Act”), or the Securities Act of 1933,
as amended (the “Securities Act”). In addition, CFTCM may, from time to time, sponsor and manage
investment vehicles on a transaction-by-transaction basis to allow certain persons to invest alongside the Fund
in specific portfolio companies and other assets of the Fund (each such vehicle, a “Co-Investment Fund”). Co-
Investment Funds are typically limited to investing in securities relating to the transaction or transactions with
respect to which they were organized. As a general matter, co-investments by Co-Investment Funds may be on
terms and conditions more favorable than the terms and conditions of the investment by the Fund.
Persons and entities that invest in the Fund may be referred to in this brochure as “investors” or “limited
partners.” CFTCM provides investment advice and other services directly through the Fund and separately to
family offices (the Fund and family offices are collectively referred to herein as the “Clients”). Our investment
advice to our Clients focuses on (i) alternative asset investments including without limitation private equity,
private debt, growth capital, venture capital, real estate, and preferred equity in private and public companies.
Investments of the Fund may be subject to certain diversification and/or geographic
limitations as set forth in
the investment management agreement and Fund Documents. Further, CFTCM may enter into side letters with
certain investors of the Fund which impose further restrictions on investing in certain types of securities,
countries, geographies or businesses with respect to such investor.
CFTCM manages assets for and markets primarily to “qualified purchasers” (as defined in the Investment
Company Act of 1940 (“Investment Company Act”)) and “accredited investors” (as defined in Regulation D
under the Securities Act of 1933 (“Securities Act”)).
Investment guidelines and constraints for the Fund managed by CFTCM are based upon the investment
objectives and limitations of the Fund as stated in the Fund Documents. CFTCM does not tailor its investment
management to the individualized needs of any Fund investor.
Investment advice provided to family offices may be reasonably tailored to a Client’s needs. CFTCM and the
Client will work to determine appropriate investment objectives, policies and restrictions, including restrictions
on investing in certain securities or types of securities. The terms negotiated between the Client and CFTCM
(with respect to this and other terms including Management Fees (as defined below)) will typically be
memorialized in the form of a term sheet, investment management contract or written investment advisory
agreement (each, an “Investment Management Agreement”).
As noted above, CFTCM typically provides investment advice or portfolio advice to family office clients on a
non-discretionary basis. CFTCM’s fee in such non-discretionary arrangements will likely be different than its fee
for providing investment advisory services where it has full discretion.
As of December 31, 2022, CFTCM managed $543,735,240 of Client assets on a discretionary basis and
$796,423,988 on a non-discretionary basis.
CFTCM does not currently participate as manager in any wrap fee programs.