Barnegat Fund Management Inc.

Barnegat Fund Management, Inc. acts as the investment manager and manager to private placement pooled vehicles operating in a master-feeder structure, advising Barnegat Fund Limited (the master fund) and Barnegat Investments Limited (the feeder). It provides discretionary portfolio management and trading services for these pooled vehicles geared to sophisticated investors, with investor eligibility limited to certain foreign persons and accredited investors.

The firm’s stated investment approach is fixed-income relative value (arbitrage), seeking pricing anomalies across government bonds, swaps, futures and related instruments in large, liquid developed markets and implementing positions by buying the relatively cheap product and selling the relatively expensive one. Portfolio management is implemented using derivative instruments, leverage and short positions as warranted, with continuous monitoring, trade-error procedures and regular reporting to investors under the Funds’ governing documents.

Among features that distinguish the firm from many peers are its master-feeder private-placement structure and an Employee Series that allows employees to invest under different fee treatment, as well as its dual registration as a Commodity Trading Advisor and Commodity Pool Operator. Regulatory disclosures for the firm also indicate an affiliation with a law firm and that the firm publicizes third‑party ratings—both items that are less common among investment managers in this category.