Bengal Asset Management, LLC

Bengal Asset Management, LLC, established in April 2013 and registered with the SEC in April 2018, is a Santa Monica-based investment adviser specializing in discretionary investment advice for proprietary pooled investment vehicles. Bengal's investment strategy focuses on equity and equity-linked investments in Japanese issuers, utilizing a hedged approach with long and short positions. The firm manages approximately $168,462,000 in regulatory assets under management as of December 31, 2024, all on a discretionary basis. Bengal's fee structure includes a management fee of 2.0% per annum for Feeder Funds, with potential performance fees of 20%. The firm may engage in cross trades for portfolio rebalancing and does not participate in wrap fee programs. Bengal has a Code of Ethics in place to ensure fair treatment of clients and adherence to insider trading policies. The firm may utilize soft dollar arrangements for research and brokerage services within the parameters of Section 28(e). Bengal exercises full discretion in selecting broker-dealers and seeks best execution for client transactions. The firm does not typically vote proxies but reviews corporate governance issues related to proxy matters. Bengal does not require prepayment of fees and has a sound financial condition without any history of bankruptcy. For more detailed information, interested parties can contact Robert Santos, Manager of Bengal Asset Management, LLC.