Climbing Rose Capital LLC

Climbing Rose Capital acts as the investment manager to a single pooled Delaware limited partnership offered under the 3(c)(1) exemption to accredited investors, providing discretionary portfolio management and the operational oversight of the Fund. The adviser emphasizes that it does not tailor Fund investments to individual limited partners and requires investor suitability representations consistent with a private pooled vehicle.

The firm’s investment approach is research-driven and bottom‑up, emphasizing patience, discipline and opportunism while employing long and short equity positions, options, ETFs/ETNs, small- and micro-cap securities and participation in new issues; the Fund has broad, flexible authority and may use leverage and short selling. The Fund is managed on a discretionary basis, reports monthly on an unaudited basis, and uses a prime broker and a third-party administrator for custody and treasury functions.

Distinctive aspects disclosed in the brochure include an operational affiliation with an independent broker‑dealer that provides research to the Fund at no charge (while the adviser generally does not use that firm for trade execution), a stated use of soft‑dollar arrangements, and the possibility of negotiated side‑letter terms for certain investors. The Fund also recognizes organizational expenses on an amortized basis (a departure from GAAP presentation) and operates a concentrated, higher‑volatility strategy, features investors should weigh alongside the Fund’s private‑fund structure.