Our Advisory Firm. Eagle Capital Management, LLC (“Eagle”) was formed in 1988 by Ravenel
Boykin Curry, III and his wife, Elizabeth Curry, who died in 2015. Their vision was to create an
environment in which equity investment decisions would be made through original, thoughtful
research and rigorous valuation techniques. Our principal owner is Mr. Curry who controls over
25% of Eagle. Over time, Mr. Curry has broadened ownership at Eagle such that now 25 of the
firm’s 42 employees have ownership interests. Twenty of Eagle’s employees are women, of which
11 have ownership interests.
Except as disclosed in Item 10, Eagle has no affiliation with any outside entities and Eagle partners
hold no positions with any other asset management firm. In 1995 the organizational structure of
the firm was changed to a limited liability company.
Our Advisory Services. The firm’s main strategy is the “Eagle Equity Strategy”, which it has been
managing since its inception. The Eagle Equity Strategy invests primarily in U.S. traded public
equities. From time to time, we also identify non-U.S. companies with equity interests that trade in
the form of American Depository Receipts (“ADRs”) that fit our investment criteria. Each Eagle
Equity Strategy model portfolio typically holds 25-35 positions. While the Eagle ETF follows a
strategy that is substantially similar to the Eagle Equity Strategy, it is expected to be more
concentrated than the Eagle Equity Strategy. For more information on the strategy pursued by the
Eagle ETF, please see Items 8 and 12 below.
As is disclosed in Part 1A of our Form ADV, our clients are primarily high net worth individuals
(including family offices), pension and other retirement plans, charitable institutions and other
institutional investors for whom we manage investment accounts (“Separate Account Clients”),
and pooled investment vehicles (including private and UCITS funds (the “UCITS Fund”) and an
exchange-traded fund, the Eagle ETF.
For the majority of our clients, we generally manage client portfolios by seeking to replicate the
Eagle Equity Strategy model portfolio and we strive to ensure that client accounts conform to the
model portfolio at all times. However, as described more fully in Item 8 and Item 12, client
portfolios often deviate from the model portfolio; this deviation occurs for a number of reasons,
especially in conjunction with anticipated or actual capital flows within a single account or across
a broader subset of accounts. Eagle has adopted and follows allocation policies designed to
mitigate these situations.
Eagle does not provide financial planning services. Our clients and their consultants determine that
the Eagle Equity Strategy portfolio is appropriate for their circumstances.
We serve as the investment adviser, with discretionary trading authority, to a private pooled
investment vehicle, Eagle Capital Equity Fund, L.P. (the “Fund”), a Delaware limited partnership;
the securities of which are offered to investors on a private placement basis. The Fund’s investment
strategy largely tracks that of the Eagle Equity Strategy. Additional information regarding the Fund
can be found in Item 8, below and in the Fund’s offering documents. Eagle’s clients are under
absolutely no obligation
to consider or make an investment in the Fund.
We also serve as the investment adviser, with discretionary trading authority, to an actively
managed open-end management ETF registered under the Investment Company Act of 1940 (the
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“1940 Act”), Eagle Capital Select Equity ETF, a series of The 2023 ETF Series Trust (the “Eagle
ETF”). The Eagle ETF’s common shares are traded on NYSE Arca, Inc. with the ticker EAGL.
While the Eagle ETF’s investment strategy is substantially similar to the Eagle Equity Strategy, in
certain situations there may be differences between the strategy and investment program of the
Eagle ETF and the Eagle Equity Strategy. Additional information regarding the Eagle ETF can be
found in Items 8 and 12 below. Although Eagle’s clients may, they are under absolutely no
obligation to consider or make an investment in the Eagle ETF. Further information regarding the
Eagle ETF is also available in its registration statement, available at https://www.eaglecap.com/.
Tailoring of Services. We do accept Separate Account Client modifications to the extent that we
are able to jointly determine with such client that the restrictions do not significantly alter the Eagle
Equity Strategy’s investment philosophy. In the event of a client’s death or incapacity, Eagle will
continue to manage the account according to the client’s contract until we receive written
instructions from an authorized representative.
Our investment decisions and advice with respect to the Fund and the Eagle ETF will be subject to
each vehicle’s investment objectives and guidelines, as set forth in such vehicle’s offering
documents or public filings and disclosures, as applicable.
Wrap Fee Programs. Eagle provides investment management for Separate Account Client
portfolios participating in wrap fee programs and receives management fees in relation to the
provision of these services. In some cases, Eagle’s fee is included in the wrap fee. Other than upon
client request, there is no difference between Eagle’s investment management services provided to
wrap fee clients and the investment management services provided to other clients.
Assets Under Management. As of March 21, 2024, Eagle managed approximately $29,103,339,891
of client assets on a discretionary basis. We do not manage assets on a non-discretionary basis.
This brochure does not constitute an offer to sell or solicitation of an offer to buy any securities.
The securities of the Fund are offered and sold on a private placement basis under exemptions
promulgated under the Securities Act of 1933 and other applicable state, federal or non-U.S. laws.
Significant suitability requirements apply to prospective investors in the Fund, including
requirements that they be “accredited investors” as defined in Regulation D, “qualified purchasers”
as defined in the 1940 Act, or non-“U.S. Persons” as defined in Regulation S. Persons reviewing
this brochure should not construe this as an offer to sell or a solicitation of an offer to buy the
securities of the Fund described herein. Any such offer or solicitation will be made only by means
of a confidential private placement memorandum.
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