Overview
A. Description of Firm and Principal Owners. Cornell Capital LLC, a Delaware limited liability
company, is a privately-held investment adviser founded in 2013 and indirectly wholly owned by
its Chief Executive Officer, Henry Cornell. Cornell Capital HK Limited, a company incorporated in
Hong Kong, is a relying adviser of Cornell Capital LLC. References to “Cornell” or “the Firm” herein
include Cornell Capital LLC, Cornell Capital HK Limited and their respective affiliates, which are
all operated as a single advisory business.
B. Description of Advisory Services. Cornell provides and is expected to continue to provide
investment advisory services to closed-end, private equity, and privately-placed limited
partnerships (referred to below, “Private Funds” or a “Fund”). Each Fund, depending on the
investment mandate, may invest in a single portfolio company or multiple portfolio companies.
The Private Funds may be structured as limited partnerships organized domestically or offshore.
Investment advisory services provided by Cornell are provided directly to each Private Fund and
not individually to the investors of the Private Fund.
Cornell has also established certain co-investment vehicles, which
may, to the extent available
and at the discretion of Cornell, offer co-investment opportunities alongside other Funds.
Cornell has affiliated general partners for several Private Funds. Cornell serves as the investment
adviser with discretionary authority to implement investment decisions for the Private Funds.
Cornell’s investment decisions and advice with respect to the Private Funds are in accordance
with the investment objectives and restrictions set forth in the constituent documents of each
Private Fund. The investors in the Funds may not direct investments by the Funds, and except in
limited circumstances, investors are not permitted to withdraw from a Fund prior to completion
of such Fund’s winding up.
C. Tailoring Advisory Services to Individual Needs. Cornell tailors its advisory services to the Private
Funds as set forth in the constituent documents associated with each Private Fund. Investment
advice is provided directly to each Private Fund and not individually to investors in the Private
Funds.
D. Wrap Fee Programs. Cornell does not participate in wrap fee programs.
E. Regulatory Assets Under Management. As of December 31, 2023, Cornell had $5,950,709,255 in
discretionary regulatory assets under management.