Kula Investments, LLC

Kula Investments, LLC is a Registered Investment Adviser with the SEC, established in Chicago, Illinois, with a secondary office in New York City. The firm serves as the investment adviser to private, pooled investment vehicles and separately managed institutional accounts. They manage approximately $608 million in Regulatory Assets Under Management as of December 31, 2022, on a discretionary basis. Kula Investments offers management services through private funds and separately managed accounts, focusing on market-neutral strategies primarily in U.S. listed equity securities and ETFs. The firm's investment objective is to provide superior risk-adjusted returns while maintaining dollar and beta neutrality. They emphasize risk management and speculative investment strategies, warning clients of substantial capital loss risks. Kula Investments charges a monthly management fee of 2.0% annually and an incentive fee of 20% of new appreciation. The firm follows a Code of Ethics, practices best execution in brokerage, and has custody of client funds and securities. They exercise investment discretion based on client guidelines and have adopted proxy voting policies. Kula Investments does not have any disciplinary events or financial conditions that may impact client commitments. Clients receive regular financial reports and disclosures on fees and compensation.