Pacific Rock Capital, LLC

Pacific Rock Capital, LLC provides discretionary investment management to a pooled Delaware limited partnership and serves as the fund’s general partner, concentrating its business on a single pooled vehicle rather than individual advisory accounts. Although the firm primarily manages pooled assets, the fund’s investor base can include accredited investors and may accept high‑net‑worth and up to 35 non‑accredited sophisticated limited partners, a client mix that is less common among managers in this category.

The firm pursues a proprietary trading strategy focused on U.S. publicly traded small‑ and mid‑cap companies (with selective exposure to larger caps), employing both long and opportunistic short positions and active cash management. Research is rooted in fundamental analysis, direct engagement with company management and proprietary earnings models, with formal risk controls intended to preserve capital across varying market conditions.

Distinctive operational features include acting as general partner with indirect custody powers over fund assets and the use of prime brokerage and institutional custodial relationships, alongside disclosed soft‑dollar arrangements for research and administrative services that the firm notes may fall outside the Section 28(e) safe harbor. The fund structure incorporates performance‑based compensation and daily compliance review of investments to monitor alignment of risk with fund objectives.