Kingsbarn Capital Management

Kingsbarn Capital Management, LLC is a registered investment adviser headquartered in Las Vegas, Nevada, established in July 2021. The firm manages an ETF ("KDRN") and a private fund ("PINC") focusing on publicly listed equities and U.S. treasury futures. Kingsbarn exercises full investment discretion for client accounts, providing continuous management services for $1,079,465 in client assets on a discretionary basis as of December 31, 2022. The firm's fee structure includes a 1.25% management fee for the ETF and a 0.50% management fee for the private fund, along with an incentive-based allocation for the private fund's General Partner. Kingsbarn acts as a fiduciary, aiming to act in the best interests of clients. The firm's investment strategies involve active management approaches, fundamental analysis, and scenario analysis to manage risk and achieve investment objectives. Kingsbarn's Code of Ethics emphasizes professional conduct, compliance with regulations, and prevention of conflicts of interest. The firm exercises voting rights on client securities, striving to enhance economic value and act in clients' best interests. Kingsbarn does not receive compensation for client referrals and maintains custody of client funds with qualified custodians. The firm's brokerage practices focus on best execution, trade aggregation, and allocation fairness. Kingsbarn does not engage in soft dollar arrangements, principal or agency cross transactions, or directed brokerage. The firm maintains records of proxy votes, reviews client accounts regularly, and does not participate in class action claims or litigation on behalf of clients. Kingsbarn's financial condition is stable, with no known impairments to meeting client commitments or bankruptcy proceedings.