Regulatory disclosures for Cotra Capital Management, LLC.
This page summarizes key regulatory disclosures relating to Cotra Capital Management, LLC, a Registered Investment Adviser, and the private funds it advises.
Form ADV
Cotra Capital Management, LLC files Form ADV Parts 1 and 2 with the SEC. These filings are publicly available on the Investment Adviser Public Disclosure website. Prospective investors should review Cotra’s Form ADV in advance of making any investment.
Risk factors
An investment in a Cotra fund involves a high degree of risk, including illiquidity, leverage, concentration, execution, real estate cycle, interest rate, and regulatory risk. Investors could lose all or a substantial portion of their invested capital. Detailed risk factors are set forth in each fund’s private placement memorandum.
Performance disclosures
Target returns are hypothetical, based on Cotra’s underwriting and assumptions, and are not a guarantee of future results. Cotra does not charge a management fee on any fund. Any references to performance, when applicable, are net of carried interest and are calculated in accordance with industry standards.
Conflicts of interest
Cotra is a vertically integrated operator that also advises private funds. This structure creates potential conflicts of interest, including with respect to allocation of opportunities, use of affiliated services, and cross-fund transactions. Cotra maintains policies and procedures — reviewed by the Compliance Committee and Advisory Board — designed to identify, disclose, and mitigate conflicts.
Marketing rule
All investment adviser communications with prospective and existing clients are governed by the SEC marketing rule. Testimonials, endorsements, and third-party ratings, where used, are accompanied by required disclosures.
Investor eligibility
Cotra funds are offered only to qualified purchasers and/or accredited investors, as applicable, pursuant to Regulation D and Section 3(c)(7) of the Investment Company Act. Eligibility is confirmed as part of the subscription process.
Audit and valuation
Cotra funds are audited annually by PricewaterhouseCoopers. Valuation policies and procedures are reviewed by the Risk & Valuation Committee and applied consistently across the platform.
Complaints and whistleblowing
Complaints and whistleblower reports may be directed to [email protected]. Cotra prohibits retaliation for good-faith reports.
Contact
Compliance: [email protected]. Legal: [email protected].