Boone Capital Management LLC

The firm provides discretionary investment management to a family of private pooled investment funds organized in a master-feeder structure and, as of the firm’s last filing, manages approximately $963 million in regulatory assets. It does not manage individual client accounts and serves investors through private fund vehicles offered pursuant to private placement exemptions.

The adviser pursues a long-biased, healthcare-focused strategy across U.S. and non-U.S. companies of varying market capitalizations, typically holding a concentrated portfolio (generally on the order of 20–50 positions) while using short positions and leverage to pursue absolute returns. The firm also employs a range of equity-related instruments and derivatives and executes trades through prime brokerage relationships, using soft-dollar arrangements to obtain research and brokerage services.

What is distinctive about the firm is its trading in commodity futures and options alongside its equities-focused strategy and its reliance on a CFTC Rule 4.13(a)(3) exemption (i.e., an exemption from registration as a commodity pool operator), which is relatively uncommon for managers in this category. The investment program is run on a fund-centric basis with an affiliated general partner that receives performance-based compensation and the manager exercising full discretion over the funds rather than tailoring services to underlying individual investors.