Overview
Raffles Capital Management, LLC (“Raffles”) is a Delaware limited liability company
formed in May 1996 with its principal place of business located at 5 Penn Plaza, 19th Floor, New
York, NY 10001. Raffles is controlled by Mr. Paul H. O’Leary who has the overall responsibility
for the day-to-day supervision and management of Raffles’ business.
At this time, Raffles provides investment advice solely to one private investment fund,
Raffles Associates, L.P., a Delaware limited liability company (the “Fund”). The Fund is what is
commonly referred to as a 3c-1 fund (referring to a section of the Investment Company Act of
1940, as amended) and the Fund is open to investors that satisfy the “qualified client” standard of
the Advisers Act. The general partner of the Fund is Raffles Capital Advisors, LLC, a Delaware
limited liability company (“RCA”), which is also controlled by Paul H. O’Leary.
Raffles directs the investment program of the Fund on a discretionary basis using a “value”
based investment strategy, as described in Item 8: Method of
Analysis, Investment Strategies and
Risk of Loss. Raffles conducts its own fundamental research of a wide range of companies to
determine their qualification for initial and continuing investment by the Fund. As part of its
investment strategy, the Fund may invest and trade in a variety of securities, including equity, debt
or convertible securities, options, domestic and foreign securities and non-publicly traded
securities.
Raffles provides portfolio advisory and management services to the Fund based on its
investment objectives, not based on the criteria or investment objective of any individual investor
that contributes assets to the Fund (an “Investor”). Services are provided to the Fund in accordance
with an advisory agreement between Raffles and the Fund and/or the organizational documents of
the Fund.
Raffles does not participate in wrap fee programs.
As of December 31, 2023, Raffles managed approximately $167,965,412 on a
discretionary basis. Raffles does not manage any assets on a non-discretionary basis.