Overview
Firm Ownership
Sea Otter is an investment adviser with its principal place of business in New York, New York and
began providing advisory services to its client in 2022. Peter D. Smith and Galvatron
Corporation each own 25% or more of Sea Otter’s LLC interests. Peter Smith and Nicholas Fahey
are Directors of Galvatron Corporation and have control over its voting securities.
Advisory Services
Sea Otter serves as the investment adviser for, and provides discretionary investment advisory
services to, Sea Otter Trading LLC (the “Fund”). The Fund is a Delaware limited liability company
and will rely on an exemption from registration under the Investment Company Act of 1940, as
amended. As further described in Item 8, Sea Otter currently will utilize the following types of
investment strategies for the Fund: a Closed-End Fund (“CEF”) strategy, a merger arbitrage strategy,
an event-driven strategy, a Special Purpose Acquisition Companies (“SPACs”) strategy.
Sea Otter does not tailor its advisory services to the individual needs of investors in the Fund. The
Firm’s investment advice and authority for the Fund will be tailored to the investment objectives of
the Fund in accordance with its limited liability company agreement (the “LLC Agreement”). Fund
investors generally cannot impose restrictions on investing in certain securities or types of securities.
Investors in the Fund participate in the overall investment program for the Fund pursuant to the terms
of the LLC Agreement.
The Firm also may offer investment advisory services in one or more strategies further described in
Item 8 through separately managed accounts to potential institutional clients (“SMA Clients”).
Should the Firm be retained to manage a SMA Client account, it would manage such account in
accordance with any investment management agreement with such client, which may include
investment objectives or guidelines specifically discussed and reviewed with such client.
Assets Under Management
The Firm manages approximately $124,700,757in assets under management (based on a valuation
of the assets managed by the Fund). These assets are managed on a discretionary basis.