12.B............................................................................................................................26
Item 13: Review of Accounts .........................................................................................................27
Item 13.A and 13.B ............................................................................................................27
Item 13.C............................................................................................................................27
Item 14: Client Referral and Other Compensation ........................................................................28
Item 14.A ...........................................................................................................................28
Item 14.B............................................................................................................................28
Item 15: Custody ............................................................................................................................29
Item 16: Investment Discretion ......................................................................................................30
Item 17: Voting Client Securities ...................................................................................................31
Item 17.A and 17.B ............................................................................................................31
Item 18: Financial Information ......................................................................................................32
Item 4.A
Coltrane is a Delaware exempted limited partnership as of March 2022. Previously Coltrane was
a Cayman Islands Limited partnership founded in May 2012 by Mandeep Manku, who is the
principal owner. Coltrane is a New York City based alternative asset management firm.
Coltrane manages pooled investment vehicles (together, the “Funds,” and each individually, a
“Fund”).
Details of Coltrane’s investment objectives are set forth in each Fund’s private placement
memorandum or limited partnership agreement or other applicable agreement (the “Offering
Documents”). For certain Funds the objective is to maximize absolute returns with a focus on long
term compounding. Coltrane employs an investment strategy built around a value-oriented
methodology focusing on security selection in equities but also, for certain Funds,
opportunistically investing in credit. Our predominant focus has been to invest in European
securities, but we also invest globally. Certain Funds intend to invest in emerging markets, but
may only invest up to 15% of overall net exposure in emerging markets, based on invested capital,
at the time of investment.
The Funds are formed as limited partnerships and offshore corporations. The Funds that are
offered within the United States as well as to U.S. Persons are available only to persons who are
“accredited investors” under the Securities Act of 1933 and only to persons who are “qualified
purchasers” under the Investment Company Act of 1940 (the “IC Act”). Additionally, all investors
must also be “qualified clients” under the Advisers Act of 1940. The Funds are not registered as
investment companies under the IC Act and are not made available to the general public.
Coltrane’s Funds are managed by Coltrane in its sole discretion. Interests in the Funds are offered
only by means of each Fund’s Offering Documents. The Funds are funded through capital
contributions and withdrawals/redemptions are permitted for certain Funds at stated intervals at
then current net asset values as set forth in each Funds’ Offering Documents.
Coltrane makes all investment decisions on behalf of the Funds pursuant to the terms of an
investment management agreement between each Fund and Coltrane. Coltrane’s primary
responsibilities are to identify, review, and select investment opportunities that it believes will
achieve the investment objectives of the Funds. This requires Coltrane to monitor investments and
determine whether to modify investment allocations. Coltrane and its affiliates (identified in Item
10.C) also provide administrative and management services to the Funds. Coltrane tailors its
investment advice pursuant to the agreed upon terms set forth in the Offering Documents. Coltrane
does not tailor its advice to the investment objectives of individual investors in the Funds
(“Investors”). However, Coltrane retains broad flexibility to invest on behalf of its Funds, as set
forth in the respective Offering Documents.
Coltrane currently does not provide investment advisory services to clients apart from its
management of the Funds and does not participate in wrap fee programs. Coltrane may, from time
to time in the future, serve as the investment adviser or management company for additional funds
or other accounts.
As of December 31, 2023, Coltrane managed on a discretionary basis approximately
$285,317,622, which represents the regulatory assets under management of the Funds as of such
date. Coltrane does not manage any assets on a non-discretionary basis.