C.M. Capital is a fee-only SEC-registered investment adviser with its principal place of
business located in Palo Alto, CA. Although C.M. Capital is a registered investment
adviser, registration itself does not require and should not be interpreted to imply any
particular level of skill or training. C.M. Capital is a wholly owned subsidiary of C.M.
Capital Corporation, and has been in business since 2008. C.M. Capital Corporation is a
wholly owned subsidiary of C.M. Capital (DE) Inc. which is wholly owned by Alphamill
Trust whose Trustee is Alphamill Limited.
Assets Under Management
Discretionary assets under our firm’s management were $430,876,553 as of
December 31, 2023.
Non-discretionary assets under our firm’s management were $1,722,726,732 as of
December 31, 2023.
Investment Management Services
C.M. Capital provides investment management services on both a discretionary and non-
discretionary basis primarily to two private investment funds: (i) the C.M.C. Absolute
Return Fund, L.P. (including each of its respective feeder funds, as described below); and
(ii) the CMC Master Fund, LP (hereinafter collectively, “the Funds”). C.M. Capital may
in the future manage separate accounts and/or create and offer new investment funds.
The Funds’ investment objectives (as described in greater detail below) are achieved
principally through the allocation of assets to independent investment managers and/or
investments in pooled investment vehicles managed by independent investment managers
(commonly referred to as a “fund of funds” strategy).
The C.M.C. Absolute Return Fund, L.P.
The C.M.C. Absolute Return Fund, L.P. (the “Absolute Return Fund”) is a limited
partnership formed in the Cayman Islands. The Absolute Return Fund is a master fund in
a master-feeder arrangement which includes the following feeder funds: C.M.C.
Domestic AR Feeder, L.P., a Delaware limited partnership (the “Domestic Feeder”) and
C.M.C. Offshore AR Feeder, L.P., a Cayman Islands limited partnership (the “Offshore
Feeder”). The Domestic Feeder and the Offshore Feeder invest all or substantially all of
their assets in, and conduct their investment activities through, the Absolute Return Fund.
The Absolute Return Fund invests in a diversified portfolio of hedge funds, with a focus
on long-term returns. C.M. Capital is the Fund Manager for this investment vehicle and is
also the owner of the General Partner of the Absolute Return Fund and its associated
feeder funds. As Fund Manager and owner of the General Partner, C.M. Capital is
responsible for finding and selecting investment opportunities with unaffiliated third-
party separate account investment managers. C.M. Capital’s selection of investment
managers for the Absolute Return Fund is done on a discretionary basis.
The CMC Master Fund, LP
The CMC Master Fund, LP (the “Master Fund”) is a Delaware limited partnership. The
Master Fund invests in a multi-asset class portfolio composed primarily of investment
vehicles managed by independent third party investment managers. The Master Fund is
not open for investment by any unaffiliated third-party investors; it is an investment
fund created and maintained only for the benefit of one private family. C.M. Capital is
the Fund Manager for this investment vehicle, and is responsible for recommending
investments with unaffiliated investment managers to the General Partner of the Master
Fund. C.M. Capital’s final selection of investment managers for the Master Fund is done
on a non-discretionary basis.
The Funds are not required to register under the Securities Act of 1933 or the Investment
Company Act of 1940 in reliance upon certain exemptions available to issuers whose
securities are not publicly offered. We manage the Funds in accordance with the terms
and conditions of each Fund's offering and organizational documents. Each of the Funds
is a “fund
of funds” and, as a result of this investment approach, we generally do not
directly buy or sell any security for the Funds except for interests in the underlying funds
or as a result of an in-kind distribution from the underlying funds.
Each Fund is governed by a limited partnership agreement or similar document (as
applicable) that sets forth the specific investment guidelines and restrictions applicable to
each Fund (the “Governing Documents”). In addition, investors in each Fund are
provided with offering documents prior to their investment, which also contain
information regarding the intended investment program for such Fund.
In acting as the Fund Manager, and as a fiduciary to our clients, all recommendations and
investment decisions are made independently and objectively and are based exclusively
on the suitability of a given selection in terms of its risk-reward profile in accordance
with the organizational and offering documents of each fund. All selected managers
generally must either have historically demonstrated a specialized expertise in a given
investment strategy and a consistent, repeatable investment process or we have
investigated the fund manager and are satisfied that such manager does have expertise
and skill in a given investment strategy and a satisfactory back office.
Our independent third party manager search and selection process is the result of
extensive internal research and a proprietary due diligence process. The process
encompasses a comprehensive review of both historical performance data and underlying
quantitative analytics as well as in-depth reviews of qualitative measures including such
things as ownership, investment philosophy, staffing, back office competence, acceptable
vendors, compliance, code of ethics, risk management, policy and procedures and trading
efficiencies.
C.M. Capital will determine whether a potential manager's portfolio management style is
appropriate for each Fund. Factors considered in making this determination include
account size, risk tolerance and the investment philosophy of the selected third-party
manager. As part of the selection process, we review each third-party manager’s
disclosure document(s) regarding the particular characteristics of any program and
managers selected by us.
C.M. Capital will regularly and continuously monitor the performance of the selected
manager(s). For the Absolute Return Fund, for which we have discretionary authority, if
we determine that a given third party investment manager(s) is not meeting our agreed
upon management expectations, we will terminate the investment manager(s) and place
the client's assets with another suitable investment manager(s) at our discretion and
without prior consent from the client. For the Master Fund, for which our firm does not
have discretionary authority, if we believe that a particular manager is performing
inadequately, or if we believe that a different manager may be more suitable for the
client's particular needs, then we may recommend that the general partner of the Master
Fund contract with another third-party manager. Under this scenario, we will select and
recommend to the general partner of the Master Fund a new manager, and upon approval
by the general partner of the Master Fund, invest with that new manager and monitor that
manager’s performance. However, any move to a new manager for the Master Fund is
solely at the discretion of the client.
ADDITIONAL CONSIDERATIONS: The information provided herein merely
summarizes the detailed information provided in each Fund’s offering and organizational
documents. Prospective investors in any one or more of the Funds should be aware of
additional risks and requirements associated with investment. Prospective investors
should refer to the appropriate Fund offering and organizational documents for important
additional information and considerations.