Raffles Capital Management, LLC

Raffles Capital Management, LLC is a Delaware limited liability company established in May 1996, specializing in providing investment advice solely to one private investment fund, Raffles Associates, L.P. The firm, controlled by Mr. Paul H. O’Leary, employs a discretionary investment strategy focused on value-based investing. Raffles conducts fundamental research to select securities for the Fund, which may include equity, debt, options, and foreign securities. The Fund is open to investors meeting the "qualified client" standard, with a minimum investment requirement of $250,000. Raffles charges a management fee of 0.25% quarterly and a performance-based allocation of 20% of profits exceeding a threshold rate. The firm does not participate in wrap fee programs and manages approximately $179.6 million on a discretionary basis as of December 31, 2024. Raffles' investment philosophy aims for long-term capital appreciation while minimizing the risk of permanent capital loss through a value-based strategy. The firm's code of ethics emphasizes placing client interests first and avoiding conflicts of interest. Raffles reviews accounts regularly, votes proxies in the best interest of the Fund, and uses Jefferies LLC as the custodian for the Fund's assets. The firm exercises investment discretion for the Fund, including determining securities to buy or sell, total amounts, executing brokers, and commission rates.