Penn Capital Management Company, LLC

Penn Capital provides investment management to a mix of institutional and individual clients through multiple vehicle types, acting as the discretionary adviser or sub‑adviser to registered mutual funds (including four funds in the RBB Funds Trust), a collective investment trust available to retirement plans, separately managed accounts, wrap fee program accounts (as adviser to third‑party‑sponsored programs), and model delivery arrangements. Its client roster, as described in the brochure, explicitly includes insurance companies, state and municipal entities, pension and profit‑sharing plans, charitable organizations, corporations, pooled investment vehicles, and individual investors.

The firm’s investment process centers on its Complete Capital Structure Analysis®, an integrated credit and equity, bottom‑up research approach that vets ideas through daily team meetings and multiple investment committees and applies proprietary credit risk ratings and price targets across a security’s capital structure. Penn Capital provides both discretionary and non‑discretionary services and delivers model portfolios to intermediaries; it documents procedures for side‑by‑side management, trade aggregation/rotation, and IPO allocations to address timing and allocation differences between discretionary accounts, model accounts, and wrap programs.

Compared with many peers, Penn Capital’s combination of serving investment companies (mutual funds and a CIT) while also managing a broad set of institutional clients and participating in wrap and model delivery channels is notable, as is its use of negotiated performance‑based fee arrangements with qualified clients and percentage‑of‑AUM fee schedules. The firm’s organizational links to SGAM/Seaport Global affiliates and its described use of soft‑dollar/commission‑sharing arrangements (including a third‑party commission aggregation tool) are identified in the brochure as potential conflicts the firm addresses through written policies and oversight.