Venator Management LLC

Venator Management LLC, established in 2013, is a registered investment advisor specializing in managing Venator Capital Partners LP and separately managed accounts since September 2020. The firm's principal owner, Constantine W. Mamakos, follows an opportunistic, value-oriented investment approach. Venator offers portfolio management, investment research, trading, proxy voting, and client service. Clients grant Venator limited power of attorney for discretionary management. The Hedge Fund follows an opportunistic and value-oriented strategy, while separately managed accounts utilize the Multi Cap Value Strategy. Venator manages $428.45 million in regulatory assets under management as of December 31, 2024. The minimum investment for separately managed accounts is $250,000, subject to negotiation. Management fees for separately managed accounts range from 0.50% to 1.00% based on account size. Venator charges a 1% annual management fee for the Hedge Fund and receives a performance allocation of 15% of net profits. Venator does not charge performance-based fees for separately managed accounts. The firm acts as a fiduciary, with Constantine W. Mamakos and David R. Fallgren serving as portfolio managers. Venator's investment philosophy involves fundamental analysis and value-oriented strategies, with a focus on long-term investments. Clients are advised on potential risks, including market fluctuations and investment-specific risks. Venator maintains a Code of Ethics, ensuring client interests are prioritized. The firm practices trade aggregation and allocation, with a focus on best execution and fair trade practices. Venator complies with proxy voting policies and procedures, ensuring votes are cast in the best interests of clients. Clients receive regular account reviews and statements to monitor investment performance. Venator does not have any disciplinary events and maintains custody of client assets with qualified custodians. The firm does not receive compensation for client referrals and discloses its brokerage practices, including soft dollar benefits and trade error policies. Venator provides comprehensive financial information and adheres to regulatory requirements.