Old Bellows Partners L.P.

Old Bellows Partners L.P. primarily manages pooled investment vehicles and currently serves as investment manager to two share classes of the Scoggin Worldwide Funds organized in a master-feeder arrangement; at the date of the brochure the Funds are the Firm’s only clients, though the Firm may in the future accept pooled vehicles or qualified separate accounts. Services are provided on a discretionary basis, with the Firm (together with an affiliated sub‑advisor) responsible for all investment and trading activity for those funds.

The Firm pursues a multi‑disciplinary, event‑driven approach that emphasizes distressed credit, bank debt, high‑yield bonds, trade claims and other special situations, and may employ short sales, options, derivatives and limited leverage to implement ideas. It also allocates a small portion of assets to the most liquid digital assets (Bitcoin and Ether) and has engaged an affiliated sub‑advisor that implements a short‑term, liquidity‑based trading model in investment‑grade credit and executes intraday trades and high‑turnover strategies for one fund class.

What is notable relative to many peers is the firm’s affiliated, multi‑entity operating model — it works closely with affiliated advisers and a sub‑advisor and has detailed allocation formulas and side‑by‑side management policies to address conflicts among affiliated funds. The firm’s strategies include commodity‑related derivatives and futures activity (including instruments that may be subject to CFTC clearing), and its flagship funds do not rely on a standard percentage‑of‑assets management fee structure, with compensation arrangements for affiliated managers structured differently than a typical AUM fee model.