Rose Grove Capital Management, LLC

Rose Grove Capital Management serves institutional and pooled-vehicle investors as the investment manager to several domestic and offshore limited partnerships (including master-feeder structures) and selectively to separately managed accounts (SMAs); SMAs generally have a high minimum capital requirement and the Funds are offered to accredited and qualified purchasers. The firm provides discretionary investment management across these pooled vehicles and SMAs and administers reporting and governance consistent with private placement fund structures.

The firm pursues a preferred-equities strategy that emphasizes investments in preferred stock across U.S., European and Asian markets and may use related instruments such as convertibles, swaps and structured notes to capture pricing discrepancies between equity, preferred and debt securities. Rose Grove’s disclosures permit the use of leverage and borrowing — including margin accounts, lines of credit and other lending arrangements — and cite a portfolio guideline that leverage generally will not exceed 2.5x while maintaining a stated focus on risk-adjusted returns and capital preservation.

Distinctive operational features disclosed in the brochure include charging performance-based fees to Clients, significant co-investment by the firm’s principals and employees in the Funds, and engagement of third‑party solicitors (JP Morgan Securities LLC and Triad Securities Corp.) to introduce investors. The firm’s governance and compliance practices additionally note broad discretionary authority for the general partner over Fund affairs, the ability to provide certain investors with preferential reporting or fee arrangements, and a Code of Ethics that restricts covered persons from personal trading in certain securities, including preferred securities.