This Brochure applies to KSCM and its relying advisers: King Street (Europe) LLP (“King Street Europe”);
King Street (Japan) Limited (“King Street Japan”); King Street (Singapore) Pte. Ltd. (“King Street
Singapore”); and Rockford Tower Capital Management, L.L.C. (“RTCM”) (collectively, the “Relying
Advisers”). KSCM was co-founded in 1995 by Brian J. Higgins, the Managing Member of KSCM’s general
partner, King Street Capital Management GP, L.L.C. (the “Investment Manager GP”). KSCM is owned by
the members of the Investment Manager GP.
King Street provides services to private investment funds, which include open-ended hedge funds that focus
on distressed debt, special situations, long/short credit and event driven strategies (the “Hedge Funds”),
closed-ended real estate funds that focus on global opportunistic investments (the “Real Estate Funds”),
and drawdown funds that focus on opportunistic or special situations investments (the “Drawdown Funds”)
(each of the foregoing, a “Fund” and collectively, the “Funds”). A related person of KSCM generally acts
as general partner or special shareholder of each Fund, and King Street acts as investment manager to each
Fund.
RTCM acts as the collateral manager to collateralized loan obligation vehicles that invest primarily in
broadly syndicated loans and collateralized bond obligation vehicles that invest in bonds and broadly
syndicated loans (collectively, the “Rockford Tower CDOs”). If required, RTCM also acts as “risk retention
provider” (as described below) with respect to the Rockford Tower CDOs. In its role as risk retention
provider, RTCM holds Rockford Tower CDO securities to the extent required by applicable risk retention
rules (“Risk Retention Interests”) and, through their investment in RTCM, certain Funds will be indirectly
exposed to the Risk Retention Interests. King Street provides certain services to RTCM relating to
management of the Rockford Tower CDOs.
The Funds and Rockford Tower CDOs are collectively referred to herein as “Advisory Clients.” References
to King Street in this Brochure include, as the context requires, affiliates through which King Street provides
investment advisory services or that act in any capacity. Each general partner, manager and special
shareholder that are related persons of KSCM are subject to the Investment Advisers Act of 1940, as
amended (the “Advisers Act”) pursuant to King Street’s registration in accordance with SEC guidance and
operate as a single advisory business.
King Street’s management of each Advisory Client is subject to, and the terms of any investor’s investment
in an Advisory Client and all other terms of each Advisory Client, are governed exclusively by, the terms
of that Advisory Client’s organizational documents, offering memorandum, limited partnership agreement
(if any), memorandum
and articles of association (if any), investment management agreement (if any), and
subscription agreement (if any), each as amended, supplemented or modified from time to time
(collectively, the “Governing Documents”). All discussions in this Brochure regarding the Advisory
Clients, including their investments, the strategies King Street pursues in managing them, the fees and
expenses borne by their investors, and all other terms of each Advisory Client, are qualified in their entirety
by reference to the relevant Governing Documents and are further described below under “Methods of
Analysis, Investment Strategies and Risk of Loss.”
Investors in the Advisory Clients participate in the overall investment program for the applicable Advisory
Client, but in certain circumstances are excused from a particular investment due to legal, regulatory or
other agreed-upon circumstances pursuant to the Governing Documents and/or Side Letters (as defined
below); for the avoidance of doubt, such arrangements generally do not and will not create an adviser-client
relationship between King Street and any investor. The Advisory Clients or King Street have entered into,
and expect in the future to enter into, side letters or other similar agreements (“Side Letters”) with certain
investors that have the effect of establishing rights under, or altering or supplementing the terms (including
economic or other terms) of, the Governing Documents with respect to such investors. As King Street
manages each Advisory Client pursuant to its investment objectives and restrictions as set forth in the
applicable Governing Documents, investors should review the relevant Governing Documents to determine
whether such an investment is appropriate for their individual circumstances.
From time to time, where investments of the Funds consist of portfolio companies or include intermediate
holding vehicles through which the Funds invest, the senior principals or other personnel of King Street or
its affiliates serve on such portfolio companies’ or holding vehicles’ respective boards of directors or
otherwise act to influence control over such entities.
As of January 1, 2024, KSCM had approximately $21,644,400,0001 in net client assets under management,
all managed on a discretionary basis. (Note that the method for computing “net client assets under
management” is different than the method for computing “regulatory assets under management” required
for Item 5.F. in Form ADV Part 1A.)
King Street currently does not provide investment advisory services to clients apart from its management
of the Advisory Clients, although it may do so in the future. Investors in the Advisory Clients have no
opportunity to select or evaluate any investments or strategies. King Street selects each Advisory Client’s
investments and determines its investment strategies.