Private company
Ranger Investment Management, L.P.
Limited partnership registered in the United States, active since 2008. Summary from the record
Last updated Oct 21, 2026.
Overview
- HeadquartersDallas, United States2
- Legal formLimited Partnership2
- Kind of organizationLimited partnership2
- LEI8945002ADB8IO4G9ZH762
- StatusActive2
- LEI statusIssued and current2
- Registered address8115 Preston Road, Suite 590, 75225 Dallas, United States2
- Registered withCorporations Section (Texas Secretary of State), 08009812792
Corporate structure
Ranger Investment Management, L.P. sits at the top of its group. 3 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of Ranger Investment Management, L.P.
- William Conrad Doenges Owns 25% to 50% of Ranger Investment Management, L.P., since 10/2004 (Form ADV)
- Andrew Ferguson Hill Owns 10% to 25% of Ranger Investment Management, L.P., since 02/2017 (Form ADV)
- Joseph Thomas Labate Owns 10% to 25% of Ranger Investment Management, L.P., since 02/2017 (Form ADV)
- Brian Bartlett Busby Owns 5% to 10% of Ranger Investment Management, L.P., since 06/2003 (Form ADV)
- Brown Vickery Mccullough Owns 10% to 25% of Ranger Investment Management, L.P., since 02/2015 (Form ADV)
- Kudu Investment US, LLC Owns 25% to 50% of Ranger Investment Management, L.P., since 12/2020 (Form ADV)
- Kudu Investment Holdings, LLC Owns control (general partner, trustee or manager) of Kudu US, LLC, since 12/2019 (Form ADV)
- Kudu Investment Owns 75% or more of Kudu Holdings, LLC, since 12/2019 (Form ADV)
- Wm Regent Ltd Owns 75% or more of Kudu Investment Management, LLC, since 10/2020 (Form ADV)
- Wm Hinson (bermuda) Ltd. Owns 75% or more of Wm International Holdings Ltd. Ltd., since 01/2023 (Form ADV)
- Robert Scott Jakacki Owns control (general partner, trustee or manager) of Kudu Investment Management, LLC, since 12/2014 (Form ADV)
- Ranger Investment Management, L.P. Dallas, Texas, United States
- Aris Water Solutions, Inc. Stake · Houston, Texas
- Excelerate Energy, Inc. Stake · The Woodlands, Texas
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); stakes of 5% or more it reported on Schedules 13D and 13G (2 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
Ranger Investment Management, L.P. is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$1.5B3 20 accounts, all with discretion
- Employees15 9 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 3 ($126.9M); Investment companies: 4 ($91.5M)
- How it is paidA percentage of assets under its management; Other: MODEL ACCOUNT ASSETS
- What it doesPortfolio management for individuals and/or small businesses; Portfolio management for investment companies; Portfolio management for pooled investment vehicles (other than investment companies); Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles); Other: MODEL ACCOUNT
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-62397, CRD 124414 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- William Conrad Doengesowns 25% to 50%, since 10/2004
- KUDU INVESTMENT US, LLCowns 25% to 50%, since 12/2020
- Andrew Ferguson Hillowns 10% to 25%, since 02/2017
- Joseph Thomas Labateowns 10% to 25%, since 02/2017
- Brown Vickery Mcculloughowns 10% to 25%, since 02/2015
- Brian Bartlett Busbyowns 5% to 10%, since 06/2003
- Wesley Conger Bellowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 02/2018
- Jonathan Adam Cramerowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 02/2018
- Robert Scott Jakackiowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 12/2014
- KUDU INVESTMENT HOLDINGS,owns general partner, trustee or manager of KUDU US, LLC, since 12/2019
- Nancy Quinn Keelerowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 01/2021
- Gavin Winston Mcleodowns general partner, trustee or manager of KUDU INVESTMENT PAREENT COMPANY HOLDINGS, LLC, since 12/2014
- Nicholas (Nmn) Plattowns general partner, trustee or manager of KUDU INVESTMENT CHIEF OPERATING OFFICER OF MANAGEMENT, PARENT COMPANY LLC, since 12/2014
- George Manning Rountreeowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 02/2018
- Charles Anthony Ruffelowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 12/2014
- Seungjun Christopher Shinowns general partner, trustee or manager of KUDU INVESTMENT MANAGEMENT, LLC, since 04/2019
- KUDU INVESTMENTowns 75% or more of KUDU HOLDINGS, LLC, since 12/2019
- WM HINSON (BERMUDA) LTD.owns 75% or more of WM INTERNATIONAL HOLDINGS LTD. LTD., since 01/2023
- WM REGENT LTDowns 75% or more of KUDU INVESTMENT MANAGEMENT, LLC, since 10/2020
- William Conrad Doengesowns 25% to 50% of RANGER INVESTMENT RANGER INVESTMENT GP, LLC GP, LLC, since 12/2020
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/25/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Ranger Investment Management, L.P. (“RIM” or the “Firm”) is an investment adviser that commenced operations in October 2002 and registered with the United States Securities and Exchange Commission (the “SEC”) in October 2003 in accordance with the Investment Advisers Act of 1940. RIM was organized as a Delaware limited partnership by Ranger Investment Group, L.L.C., a Delaware limited liability company. Effective December 31, 2020, Ranger Investment GP, LLC, a Delaware limited liability company (“RIG”) became the sole general partner of the Firm. RIG is owned by Conrad Doenges, Andrew Hill, Joseph LaBate and Brown McCullough and Mr. Doenges serves as the manager of RIG. Effective December 31, 2020, Mr. Doenges, Mr. Hill, Mr. LaBate, Mr. McCullough, and Brian Busby are limited partners of the Firm. To facilitate the December 31, 2020, separation from Ranger Capital Holdings, LP, Kudu Investment US, LLC (“Kudu”) became a Preferred Limited Partner (“PLP”) of RIM. Kudu is an independent provider of permanent capital solutions to asset and wealth managers worldwide. Kudu receives a revenue share percentage as a PLP, but Kudu does not exercise any control over the management or policies of RIM. In February 2022 Marta Cotton, Head of Marketing & Client Relations, and Dana Ousley, Chief Financial Officer, became limited partners of the Firm. In February 2023, the Firm announced that Brown McCullough was named a Portfolio Manager, and Devin Holland, Senior Analyst, became a Partner of the Firm. Effective December 31, 2023, Dana Ousley, Chief Financial Officer, retired from the Firm, no longer a partner, and no longer holds an ownership interest. Matthew Wade assumed the position of Chief Financial Officer and was named a partner of the Firm. Partnership units previously owned by Dana Ousley were transferred back to the General Partnership and subsequently transferred to Matthew Wade in January 2024. In February 2025, Kevin Zhu, Senior Analyst and Jeff Dalton, Manager of Risk & Sustainability, became limited partners of the Firm. As of December 31, 2025, the Firm managed a total of $1,483,846,197 in regulatory assets under management. Additionally, the Firm advised $413,239,089. in Model Account assets. Services provided to Model Accounts are detailed in the last paragraph of Item 4. Investment Advisory Services RIM provides continuous discretionary investment advisory services and sub advisory services to separately managed accounts (“Separate Accounts”), private pooled investment vehicles (“Private Funds”), Collective Investment Trust (“CIT”), mutual funds (“Mutual Funds”) and together with the Private Funds and Separate Accounts, the “Discretionary Accounts” or
"Clients". Additionally, RIM provides non-discretionary security recommendations in the form of model accounts (“Model Accounts” or “Model Account Clients”). Separate Accounts may include Client assets obtained through a Bank Trust relationship. Investment supervisory services include: (1) establishing a Discretionary Account’s or Model Account’s investment objectives within their applicable investment strategies; (2) buying or selling portfolio securities on behalf of each Discretionary Account; and recommending Model Account security transactions to Model Account Clients; (3) periodically reporting to Discretionary Accounts with respect to current investment holdings, valuations, transactions, capital gains or losses, investment performance, and/or outlook, and (4) periodically reporting to Model Account Clients with respect to current recommended investment holdings, recommended transactions, model investment performance, and/or outlook . The discretionary and Model Accounts (the “Portfolios”) advised by the Firm consist primarily of U.S. exchange traded equity securities of growth-oriented companies within predetermined capitalization ranges,. Generally, the Firm seeks to uncover quality investments by implementing a bottom-up, fundamental research driven security selection process by investing in companies characterized by accelerating revenue and earnings growth, high recurring revenues, strong balance sheets and strong free cash flow generation. The Firm offers the option to participate in its offered investment strategies through either Separate Accounts, interest or shares in pooled investment vehicles, or Model Accounts (as set forth below). Separate Accounts and Model Accounts may provide greater flexibility for a Client with respect to the investment parameters used within the Firm’s investment strategies or other terms of investment. Please see Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss. Investment Strategies RIM provides discretionary and non-discretionary investment advisory services to institutional investors such as mutual funds, private pooled investment vehicles, public and private pension plans, insurance companies, foundations, endowments, and high net worth individuals (which invest through Private Funds or Mutual Funds). In addition, RIM provides indirect investment advisory services to both institutional and non-institutional investors, through shares and interests in registered and unregistered pooled investment vehicles. RIM’s investment process has never and will never incorporate the use of shorting or the use of leverage in any of the Firm’s investment offerings. The Firm primarily manages portfolios of growth-oriented companies characterized by accelerating revenue and earnings growth, high recurring revenues, strong balance sheets and strong free cash flow generation within the following strategies: •
Small Cap Growth Strategy: The Small Cap Growth Strategy seeks long-term growth of capital by investing primarily in common stocks of growth-oriented domestic issuers
which, at the initial time of purchase, are within the capitalization range of issuers represented within the Russell 2000® Growth Index. •
Micro Cap Growth Strategy: The Micro Cap Growth Strategy seeks long-term growth of capital by investing primarily in common stocks of growth-oriented domestic issuers which, at the initial time of purchase, are within the capitalization range of issuers represented within the Russell Microcap® Growth Index.
The Smid Cap Growth Strategy was closed in February 2025; the All Cap Focused and Healthcare Select strategies were closed effective February 2024. In addition to each of the above-mentioned investment strategies, the Firm may, at the request of a Client or otherwise, offer advisory services in sub-strategies dedicated to industry specific segments of an investment strategy, sub-capitalization ranges or expanded capitalization ranges within an investment strategy, or high concentration versions of an investment strategy. In each case, a detailed description of the applicable investment strategy will be set forth in the applicable offering documents and/or investment management agreement. Separately Managed Accounts A separately managed account is a portfolio of securities managed on a discretionary basis by the Firm on behalf of a Client, in accordance with a pre-established investment strategy. Separately managed accounts are initiated through investment advisory, bank trust arrangement, or sub advisory agreements (“Investment Management Agreements”) with the Firm, which define the terms of the Firm’s engagement, the investment strategy, and any thirdparty custodian or other service provider chosen by the Client. The Client generally drafts the Investment Management Agreement, although at the request of the Client such agreement can be provided by the Firm. Investment Management Agreements are therefore highly negotiated agreements, the terms of which can and do differ significantly on a Client-to-Client basis, including without limitation, with respect to fees or investment guidelines. Likewise, Clients may request specific terms with respect to investment guidelines and/or objectives for inclusion within the Investment Management Agreement; and therefore, Clients can, subject to the consent of the Firm and inclusion in the Investment Management Agreement, have portfolios within a specific Investment Strategy which differs in holdings. Generally, the minimum investment threshold required by the Firm to open a separately managed account is five million dollars ($5,000,000). This minimum is negotiable on a caseby-case basis. Private Funds The Firm serves as a general partner and investment adviser to the Ranger Investment Master Fund, L.P., a Delaware limited partnership which is a pooled investment vehicle exempt from registration under the Investment Company Act of 1940. The Ranger Investment Master Fund currently offers one class of limited partnership interest to new investors but has the discretion
to add additional classes of limited partnership interest dedicated to any investment strategy, at any time without prior notice to limited partners: •
Small Cap Portfolio Class maintains a diversified growth-oriented portfolio consisting of approximately 40 to 60 U.S. exchange traded equity securities. The Small Cap Portfolio Class employs the Small Cap Strategy (as described above). This class is managed pari pasu with the Small Cap Growth Strategy.
Client The Private Fund is exempt from registration pursuant to Section 3(c)-1 of the Investment Company Act of 1940. The Firm solicits investors for the Private Fund in accordance with Rule 506 of Regulation D, the Private Fund is available to a limited number of accredited investors. Current and prospective investors should ensure that they can evaluate the merits and risks of an investment in the Private Fund, as set forth in the Private Placement Memorandum of the Private Fund and/or as may be specific to such prospective investor. Mutual Funds The Firm serves as the investment adviser to the Ranger Small Cap Fund, and the Ranger Micro Cap Fund, each a series of the Spend Life Wisely Funds Investment Trust (formerly the Ranger Funds Investment Trust – name change November 30, 2024), an investment company registered with the Securities and Exchange Commission under the Investment Company Act of 1940. The Firm has no control over the board or day-to-day operations of Spend Life Wisely Funds Investment Trust. •
The Ranger Small Cap Fund seeks long-term capital appreciation by investing in growth-oriented U.S. exchange traded equities of small capitalization companies in accordance with the Small Cap Growth Strategy.
•
The Ranger Micro Cap Fund seeks long-term capital appreciation by investing in growth-oriented U.S. exchange traded equities of micro capitalization companies in accordance with the Micro Cap Growth Strategy.
Each Mutual Fund may issue Institutional and Investor Classes of share, with the only difference between the share classes being that Institutional Share Classes have a higher minimum investment requirement and are not subject to 12b-1 fees. Currently only the Institutional Class is open and available to investors. Additional information regarding each Mutual Fund can be found in the mutual fund’s Prospectus and Statement of Additional Information, copies of which can be obtained by accessing www.spendlifewiselyfunds.com, www.rangerinvestmentsfunds.com or by contacting the Mutual Funds’ transfer agent at (866) 458-4744. Model Accounts
The Firm provides Model Account services for particular investment strategies to Clients. Model Accounts are initiated through Model Account agreements (“Model Account Agreements”) with the Firm, which define the terms of the Firm’s engagement, the investment strategy, and other investment parameters. The form of the Model Account Agreement is generally drafted by the Client, although at the request of the Client such agreement can be provided by the Firm. Under this arrangement, the Firm provides Model Account Clients with investment recommendations on a non-discretionary basis based on the agreed upon investment strategy, other investment parameters, and timing. Model Accounts are advised on a nondiscretionary basis, and as such the Firm does not possess the authority or responsibility to determine which securities a Model Account Client purchases or sells within any of such Client’s portfolios, nor does the Firm execute any trade or engage with any broker dealers on behalf of the Client. Each Model Account Client is responsible for determining which securities to buy and sell, the execution of trades, and/or engaging with broker dealers on behalf of its underlying portfolio. Therefore, a Model Account Client’s portfolio performance and security weightings under this product may differ greatly from the Firm’s other portfolios using similar investment strategies.
Item 5: Fees and compensation Fees
The Firm charges Clients advisory fees which are a fixed percentage of assets under management (“Management Fees”). Management Fees are charged in accordance with the schedule set forth in this Brochure, and in the case of a Private Fund or Mutual Fund, the offering documents, prospectus and/or statement of additional information about such fund. RIM reserves the right to negotiate Management Fees, performance fees and other compensation structures with Clients (and investors in Private Funds) which may differ from the standard schedule presented herein, based on specific circumstances and on a case-by-case basis. Examples of these circumstances include, without limitation: the relative size of a Client’s account, a Client’s affiliation to RIM, and/or a Client’s status as a seed investor. Accordingly, Management Fees incurred by Clients can vary substantially. In addition, with respect to Separate Accounts, all other terms of such investment, including terms relating to expenses and redemption terms, are negotiable on a case-by-case basis. As such, Client investments in Separate Accounts may provide flexibility with respect to investment terms which are not as readily afforded to investors in the Private Fund or Mutual Funds. Management Fees: Private Fund (Qualified Investors Only) – The Firm currently manages one Private Fund Class under the Ranger Investment Master Fund, LP– Ranger Investment Small Cap Fund. Portfolio. Management Fees may be negotiable for the Ranger Investment Small Cap Fund, are calculated and accrued monthly, payable quarterly in advance per the Private Placement Memorandum (“PPM”). Limited Partners of the Small Cap Portfolio Class are not subject to a performance allocation. To the extent that a limited partner in a Private Fund redeems its investment, the Firm will promptly refund all fees paid in advance for periods after such
applicable redemption date. It is important for private fund investors to carefully read the Fund PPM for a full description of management fees. A second Fund Class (AP3 Small Cap) was established in 2020 that included one Limited Partner. This AP3 Class was subject to a performance-based fee arrangement. This Fund Class was liquidated and closed in March 2024. Mutual Funds – Management Fees are calculated and accrued daily and wired to the RIM account on a quarterly basis by the Mutual Fund’s transfer agent. Collective Investment Trust – (Qualified Plans Only) – The CIT is available as a qualified plan investment vehicle. The CIT remains unfunded currently. Separately Managed Accounts – The time, manner, and fee schedule in which fees are invoiced and paid are negotiable on an account-by-account basis. The Firm calculates the fee based on a reconciled account valuation on a quarterly basis. Generally, the fees are calculated in arrears, but Clients do have the option to choose to be billed in advance. A detail of the fee schedule and manner of invoicing are included in the Investment Management Agreement. The Firm does not charge a minimum fee. The Firm does not maintain authority to unilaterally deduct fees from Separate Account Clients. As described in Item #6 below, performance-based fees are negotiated on a Client-by-Client basis for Qualified /Accredited investors only. Standard Fee Schedule for Available Classes of the Private Funds Private Fund – Classes of Interest
Annual Management Fee
Small Cap Portfolio Class
One Percent (1.00%)
Standard Fee Schedule for Available Classes of the Collective Investment Trust (“CIT”) CIT – Classes of Interest
Annual Management Fee
Unfunded at this time
To be determined
Standard Fee Schedule for Available Ranger Mutual Funds Mutual Fund
Annual Management Fee
Ranger Small Cap Mutual Fund (RFISX)
One Percent (1.00%)
Ranger Micro Cap Mutual Fund (RFIMX)
One Percent (1.00%)
* Non-Institutional share classes of each Mutual Fund listed above may be subject to 12b-1 fees of up to 0.25%.
Standard Fee Schedule for RIM Separately Managed Accounts in Available Strategies RIM Strategy
Annual Management Fee First $25mm
Next $25mm
$50-100mm
RIM Small Cap Strategy
100 Basis Points (1.0%)
Eighty Basis Points (0.80%)
Seventy Basis Points (0.70%)
RIM Micro Cap Strategy
110 Basis Points (1.10%)
Ninety-Five Basis Points (0.95%)
Eighty Basis Points (0.80%)
Above $100 mm Negotiable Negotiable
Fees for RIM Model Accounts The Firm anticipates that the range of services provided with respect to Model Accounts will significantly differ on a Client-by-Client basis. As such, the Firm does not maintain a standard fee schedule with respect to Model Accounts. However, advisory or management fees with respect to Model Accounts generally fall below equivalent fees charged for full service, discretionary accounts based on the same investment strategy. Management Fees and Other Expenses Management Fees are negotiable, depending on the size of the investment and other factors. Management Fees are exclusive to expenses associated with investments in Separate Accounts, Mutual Funds, the Private Funds and/or Model Accounts. Although the Firm is responsible for its overhead expenses, Clients generally bear the cost attributable to their investment activities and operations, which can include, without limitation, expenses associated with a portfolio’s investment program, trading, administration, custody and/or operations. Separate Account Expenses Separate Account agreements are highly negotiated in terms and may differ materially on a Separate Account Client by Client basis. However, on a general basis Separate Accounts directly bear their own costs with respect to the service providers they engage directly, including, without limitation, qualified custodians, accountants, and administrators. Pursuant to the terms of their Separate Account agreements, a Separate Account Client directly or indirectly bears the costs attributable to such Separate Account’s investment activities, including without limitation, costs charged by third party and unaffiliated broker-dealers attributable to trading shares within their portfolios. Additionally, Separate Accounts may be subject to certain indemnification requirements, as set forth within their applicable Separate Account Agreement. Separate Accounts are not charged any expenses attributable to any accounting, operational, legal or compliance services performed by the Firm in connection with such Separate Account.
Private Funds & Mutual Funds The prospectus of each Mutual Fund advised by the Firm and the offering memorandum, subscription agreement and/or other governing document of each Private Fund sets forth the applicable expenses to which a shareholder or limited partner may be subject; and any descriptions of fees and expenses set forth above and below should be deemed examples and/or summaries of the types of expenses a Private Fund or Mutual Fund investor may be subject to, are not intended to be all inclusive, vary on a fund to fund basis, and are qualified in their entirety by the prospectuses and memorandums of the applicable Private Fund or Mutual Fund. Private Funds and Mutual Funds bear the cost attributable to their investment activities and operations, which could include, without limitation, expenses associated with a portfolio’s investment program, trading, administration, custody and/or operations. Such expenses may include, depending on terms set forth within a Private Fund or Mutual Fund’s applicable prospectus or memorandum, and without limitation: (i) expenses incurred in connection with the evaluation, acquisition or disposition of investments, including private placement fees, sales commissions, appraisal fees, due diligence expense, travel costs, expenses associated with tender offers, proxy or consent solicitations, brokerage fees, underwriting commissions and discounts, and legal, accounting, investment banking, consulting, information services and professional fees, (ii) withholding or transfer taxes; (iii) legal fees and costs (including settlement or award costs) arising in connection with any litigation or regulatory investigation instituted against a Fund, or in certain circumstances, the Firm; (iv) specific expenses incurred in obtaining systems, research and other information utilized for portfolio management purposes that facilitate valuations and accounting, including the costs of statistics and pricing services, service contracts for quotation equipment and related hardware and software; (v) the allocated costs of any liability insurance obtained on behalf of a Private Fund or Mutual Fund or, in certain circumstances, the Firm; (vi) expenses incurred in connection with the carrying or management of investments, including, with respect to the Mutual Fund, custodial, trustee, transfer agent, and administrator fees; (vii) the cost of the audit of a Private Fund’s or Mutual Fund’s financial statements and the preparation of such fund’s tax returns; (viii) the fees and expenses of the accountants servicing the Client (including with respect to the Private Fund, reasonable compensation for the Firm’s in-house accountants, which is currently set at an amount equal to five basis points (0.05%) of assets under management) in connection with accounting advice relating to the Client’s day-to-day affairs and all costs related to the keeping of the books and records of a Private Fund or Mutual Fund; (ix) legal fees for services provided to the Private Fund or Mutual Fund by such Fund’s counsel; (x) the costs and expenses of holding any meetings of partners or shareholders which are required to be held under the terms of any agreement or by law; and (xi) all costs and expenses associated with reporting and providing information to existing and prospective investors in the Funds. In addition, NonInstitutional Classes of the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund may be subject to distribution and/or service (12b-1) fees of up to 0.25%. Notwithstanding the above, (i) the Firm may, in its sole discretion, choose to absorb any such expenses incurred on behalf of a Client, and (ii) certain Private Funds or Classes of the Ranger Investment Master Fund, LP (the “Master Fund”) may require the Firm to pay administrative
expenses of such applicable Private Fund or Class, as set forth in greater detail with the Private Placement Memorandum or Limited Partnership Agreement of the Master Fund or such applicable Class. Expense Cap Limitation Agreements The Firm has entered into an expense limitation agreement with the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund to reduce the Firm’s fees and to reimburse expenses, at least until November 30, 2026, such that total annual Fund operating expenses after fee waiver and/or reimbursement (exclusive of any Rule 12b-1 distribution or shareholder servicing fees, taxes, interest, brokerage commissions, acquired fund fees and expenses, or extraordinary expenses such as litigation) will not exceed (i) 1.10% of the Ranger Small Cap Mutual Fund's average daily net assets, and (ii) 1.25% of the Ranger Micro Cap Mutual Fund's average daily net assets, subject to possible recoupment from the appropriate Fund in future years on a rolling three year basis (within the three years after the fees have been waived or reimbursed) if such recoupment can be achieved within the foregoing expense limits. Broker–Dealers The Firm is not affiliated with any broker-dealer. For information describing the factors that the Firm considers in selecting or recommending broker-dealers for Client transactions and determining the reasonableness of their compensation, please see Item 12 – Brokerage Practices. Performance Fees Performance fees are advisory fees which are charged as a percentage of the appreciation of the net asset value of a Client’s account. The Firm, in limited situations and generally at a Client’s request, will consider the application of performance fees as a full or partial alternative to Management Fees. Please refer to Item 6 – Performance Based Fees and Side by Side Management. Compensation to Promoters The Firm may enter into agreements with an affiliated or unaffiliated marketing group or individuals to act as a Promoter of the Firm to Separate Accounts or investors for the Private Funds or Mutual Funds. For their services, such Promoter may receive cash compensation based on a negotiated percentage of the Firm’s Management Fee directly related to the services the Firm may provide to the relevant account or investor. The cash compensation paid by the Firm to t h e Promoter is borne exclusively by the Firm and is not charged back to the Clients who have been solicited by such Promoters. However, because the Firm pays such compensation out of the Management Fees it collects from a Client, such Client may be indirectly impacted pursuant to the level of Management Fees it is able to negotiate with the Firm.
The Firm’s arrangements with an affiliated or unaffiliated marketing group or Promoter may result in a potential conflict of interest by creating an incentive for the Promoter to recommend RIM investment advisory products and services based on compensation received rather than the investor’s needs. The Firm has implemented procedures to ensure compensation arrangements with an affiliated or unaffiliated third-party who act as a Promoter will comply with the new Marketing Rule under the Adviser’s Act. Additional Information •
Additional information regarding the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund can be found in such mutual fund’s prospectus and SAI, a copy of which can be obtained by accessing www.spendlifewiselyfunds.com , www.rangerinvestmentsfunds.com or by contacting RIM at (214) 871-5260 or crteam@rangerinvestments.com.
•
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
RIM’s investment team seeks to uncover quality growth-oriented companies by implementing a bottom-up, fundamental research driven security selection process. The investment team’s focus is to identify U.S. exchange traded equity securities of primarily micro, and small capitalization companies characterized by accelerating revenue and earnings growth, high recurring revenues, strong balance sheets and strong free cash flow generation. In addition to quantitative analysis, the investment team considers qualitative issues such as, quality of the management team, accounting practices, governance, and the company's competitive advantage. Following the analysis of these quantitative and qualitative characteristics, the investment team then determines whether a company it believes is undervalued and has sufficient upside to the stock price to warrant an investment. The investment team performs independent, bottom-up, fundamental research on potential portfolio companies and their underlying securities prior to making investment decisions which includes a variety of sources of publicly available information and data. Examples include information produced by publicly traded companies such as audited financial statements and other financial reports. The investment team also considers information obtained through its industry contacts, Wall Street firms, financial news feeds, third party research companies and other publicly available sources. Discussions with company management are also an important source of information. The Firm integrates ESG factors into its investment selection process and philosophy for all strategies. With a focus on financial materiality informed by the Sustainability Accounting Board’s (SASB) industry-specific approach, The Investment Team evaluates a company’s ESG strengths and weaknesses based on original research and management engagement. Research is collected from public company documents, websites, SEC filings, and third-party ratings. Engagement allows the Investment Team to learn first-hand the most important sustainability issues affecting each company and how management is addressing them.
The Firm’s investment team takes a comprehensive and collaborative approach to risk management. This approach starts with security selection and analysis. The research process includes a deep fundamental analysis of each company’s financial profile, growth prospects, and current valuation. It also includes a comprehensive analysis of each company's management team, business model, and competitive landscape. Once a company is purchased, the investment team considers several factors to ensure that each company continues to warrant continued inclusion in the portfolio. The investment team will regularly review each company’s investment thesis, checking for changes in the competitive landscape or diminished growth opportunities. The investment team watches for significant changes, such as transformational acquisitions or management changes, which may signal operational challenges. The Firm’s investment team also takes a competitive approach to capital allocation within the portfolio, ensuring the best ideas receive capital, weaker positions are exited, and stocks trading at less compelling valuations are trimmed or sold. We believe this comprehensive risk mitigation approach helps optimize portfolio construction and improves overall portfolio quality. RISK FACTORS AN INVESTMENT IN ONE OF THE FIRM’S PRIVATE FUNDS, MUTUAL FUNDS OR SEPARATELY MANAGED ACCOUNTS OR PARTICIPATION IN A FIRM ADVISED MODEL ACCOUNT (TOGETHER, A “RIM ACCOUNT”) ENTAILS A HIGH DEGREE OF RISK, INCLUDING THE POTENTIAL FOR LOSS OF ALL OR PART OF AN INVESTMENT. THEREFORE, AN INVESTMENT SHOULD BE UNDERTAKEN ONLY BY INVESTORS CAPABLE OF EVALUATING AND BEARING THE RISKS OF SUCH AN INVESTMENT. THERE CAN BE NO ASSURANCE THAT THE FIRM WILL BE ABLE TO AVOID LOSS, ACHIEVE ITS INVESTMENT OBJECTIVE OR RECEIVE A POSITIVE RETURN ON INVESTMENT CAPITAL. PROSPECTIVE INVESTORS SHOULD CAREFULLY CONSIDER THE FOLLOWING FACTORS IN CONNECTION WITH AN INVESTMENT. PLEASE NOTE THAT THE FOLLOWING LIST IS NOT A COMPLETE LIST OF ALL RISKS INVOLVED IN CONNECTION WITH AN INVESTMENT IN A SEPARATE ACCOUNT OR MODEL ACCOUNT. WITH RESPECT TO A PRIVATE FUND OR RANGER MUTUAL FUND, ADDITIONAL RISK DISCLOSURES CAN BE FOUND IN THE PRIVATE PLACEMENT MEMORANDUM, PROSPECTUS AND/OR SAI OF SUCH APPLICABLE FUND. REFERENCES AND DISCLOSURES RELATING TO ANY PUBLIC OR PRIVATE FUND PRESENTED HEREIN, INCLUDING BUT NOT LIMITED TO: (I) THE INVESTMENT OBJECTIVE, STRATEGIES, RESTRICTIONS AND MANAGEMENT OF FUND, (II) RISKS AND CONFLICTS OF INTEREST ASSOCIATED WITH AN INVESTMENT IN A FUND, (III) DESCRIPTIONS OF SECURITIES PERMISSIBLE FOR INVESTMENT BY A FUND, AND (IV) TERMS FOR INVESTMENT WITHIN A FUND ARE QUALIFIED IN THEIR ENTIRETY BY AND SHOULD BE READ IN CONJUNCTION WITH SUCH FUND’S OFFERING DOCUMENTS AND OPERATING AGREEMENTS, INCLUDING WITHOUT
LIMITATION, ANY PRIVATE PLACEMENT MEMORANDUM, PROSPECTUS, STATEMENT OF ADDITIONAL INFORMATION, LIMITED PARTNERSHIP AGREEMENT, INVESTMENT MANAGEMENT AGREEMENT OR SUBSCRIPTION AGREEMENT. PROSPECTIVE INVESTORS ARE STRONGLY ENCOURAGED TO REVIEW OFFERING DOCUMENTS AND OPERATING AGREEMENTS CAREFULLY, AND CONSULT THEIR INDIVIDUAL FINANCIAL, LEGAL OR TAX ADVISORS PRIOR TO MAKING AN INVESTMENT. INFORMATION ABOUT WHAT OFFERING DOCUMENTS AND OPERATING AGREEMENTS ARE AVAILABLE FOR REVIEW BY A PROSPECTIVE INVESTOR, ALONG WITH APPLICABLE COPIES OF SUCH DOCUMENTS, IS AVAILABLE BY CONTACTING THE FIRM AT (214) 871-5260 OR CRTEAM@RANGERINVESTMENTS.COM Security Selection and Market Risk Security selection risk is defined as the risk that the Firm may not select and size positions appropriately within the Portfolio. An associated market risk arises from the influence of the movements of the overall market, or the value of the individual securities in the Portfolio. The profitability of a significant portion of the Firm’s investment program depends largely upon correctly assessing the future course of price movements and/or the general value of securities and other investments. There can be no assurance that RIM will be able to accurately predict these price movements or future valuation; nor can assurance be given that the Firm’s investment Portfolios will generate income or appreciate in value. With respect to RIM’s investment strategies, there is also a degree of market risk. For these reasons, the Portfolio may also incur losses. Equity Securities RIM Accounts invest in long positions in equity securities. Equity securities fluctuate in value, often based on factors unrelated to the value of the issuer of the securities. The market price of equity securities may be affected by general economic and market conditions, such as a broad decline in stock market prices or in the prices of issuers in a particular market, geographic or industry sector, or by conditions affecting specific issuers, such as changes in earnings forecasts. Micro, and Small Capitalization Companies Micro and Small Cap stocks often involve higher risks in some respects than investments in stocks of larger companies. For example, prices of micro, and small capitalization stocks are often more volatile than prices of large capitalization stocks, and the risk of bankruptcy or insolvency of many smaller companies is higher than for larger, “blue-chip” companies. In addition, due to thin trading in some small capitalization stocks, an investment in those stocks may become illiquid. Micro and small cap companies may be newly formed or have limited product lines, distribution channels and financial and managerial resources. The risks associated with those investments are generally greater than those associated with investments in the securities of
larger, more established companies. This may cause such account’s net asset value to be more volatile when compared to investment strategies that focus only on large capitalization companies. Generally, securities of micro and smaller capitalization companies are more likely to experience sharper swings in market value, less liquid markets in which it may be more difficult for the Firm to sell at times and at prices that the Firm believes appropriate and generally are more volatile than those of larger companies. Compared to large companies, micro and smaller capitalization companies are more likely to have (i) less information publicly available, (ii) more limited product lines or markets and less mature businesses, (iii) fewer capital resources, (iv) more limited management depth and (v) shorter operating histories. Limited Liquidity The investments made by the Micro Cap and Small Cap portfolios may be less liquid than in portfolios that invest in larger companies. Consequently, Micro Cap and Small Cap portfolios may not be able to sell such investments at prices that reflect the Firm’s assessment of their value, or the amount paid for such investments by Micro Cap and Small Cap portfolios. Illiquidity may result from limited daily trading volumes in any particular equity investment or the absence of an established market for the investments as well as legal, contractual or other restrictions on their resale by the Micro Cap and Small Cap portfolio and/or other factors. Furthermore, the nature of the Micro Cap and Small Cap portfolio’s investments may require a long holding period prior to profitability. The operative documents of a Client account may authorize the Firm to make distributions in-kind of securities in lieu of or in addition to cash. In the event the Firm makes distributions of securities in-kind, such securities could be illiquid or subject to legal, contractual, and other restrictions upon transfer. Concentration Risk Generally, the Firm’s investment strategies invest in significantly fewer holdings than that represented by the index benchmarks the Firm uses for comparison purposes. Accordingly, the Firm’s investment strategies may therefore be subject to more rapid changes in value than would be the case if these strategies maintained wide diversification among companies, securities, and types of securities. Potential Loss of Investment There is a risk that an investment in a RIM Account will be lost entirely or in part. An investment in a RIM Account is not a complete investment program and should represent only a small portion of an investor’s portfolio management strategy. Each prospective investor must have enough knowledge and experience in financial and business matters to be capable of evaluating the merits and risks of an investment in a potentially risky investment like a RIM Account, whose performance may be highly volatile. No guarantee or representation is made that the investment strategy of a RIM Account will be successful, that the targeted return or risk will be achieved or maintained, or that the various investment strategies utilized, or investments made through a RIM Account will have low correlation with each other or with the markets.
Overall Investment Risk All securities investments risk the loss of capital. The nature of the securities purchased and traded by the Firm, and the investment techniques and strategies employed to increase returns may increase this risk. While the Firm will devote its best efforts to the management of investment portfolios, many unforeseeable events, including but not limited to actions by various government agencies, the Federal Reserve Board, and/or domestic and international political events, may cause sharp market fluctuations which may negatively impact the investment strategies managed by the Firm. The prior investment performance of a Fund, Separate Account, Model Account, or composite may not be indicative of the future results. Sustainability and Environmental, Social and Governance (“ESG”) Considerations The Firm integrates ESG analysis throughout the investment process. Applying sustainability and/or ESG factors as part of the fund’s security selection process may impact the sub-adviser’s investment decisions. Sustainability and ESG factors are not uniformly defined and applying such factors involves subjective assessments. Sustainability and ESG ratings and assessments of issuers can vary across investment advisers (including subadvisers) and third-party data providers and may change over time. Sustainability and ESG factors can be difficult to apply consistently across issuers, regions, countries, industries, or sectors. The application of these factors could negatively impact the fund’s performance. Sustainability and ESG information from issuers and from third party data providers may be incomplete, inaccurate, or unavailable, which could lead to an incorrect assessment of a company’s sustainability or ESG characteristics. Portfolio Turnover Private Funds, Mutual Funds and Separate Accounts that the Firm advises will not be restricted in effecting transactions by any specific limitations with regard to the Portfolio turnover rate. Market conditions or other unforeseen events may result in substantial Portfolio turnover, which may result in an increase in expense for the investors and/or enhanced volatility. Securities Lending RIM does not participate or manage a securities lending program; however, Clients may participate in a securities lending program through their respective qualified custodian in the ordinary course of its business. Parties that borrow securities from RIM Accounts may not be able to return these securities on demand and may also default on the payment obligations owed to the RIM Accounts in connection with such securities loans. In addition, assets pledged by the borrower as collateral for the borrowed securities may decline in value. The RIM Accounts may be subject to loss with respect to the value of the securities they lend to defaulting borrowers. The Firm does not have authority to lend securities on behalf of Separate Account Clients. Cybersecurity Risks
Item 7: Types of clients
RIM provides direct investment advisory services to institutional investors such as, but not limited to, mutual funds, private pooled investment vehicles, public and private pension plans, insurance companies, foundations, endowments, sovereign wealth funds, and high net worth
individuals (which invest through Private Funds or the Ranger Small Cap and/or Micro Cap Mutual Funds). In addition, RIM provides indirect investment advisory services to both institutional and non-institutional investors, through shares and interests in registered and unregistered pooled investment vehicles, with each of such vehicles deemed Clients of the Firm. Generally, the minimum investment thresholds to open an account are: (i) five million dollars ($5,000,000.00) for a Separate Account, (ii) one million dollars ($1,000,000.00) for a limited partnership interest in a Private Fund, and (iii) between twenty-five thousand dollars ($25,000.00 Investor Class) and two hundred fifty thousand dollars ($250,000.00 Institutional Class), for shares of the Ranger Small Cap Fund and the Ranger Micro Cap Fund, depending on the class of shares (select broker dealers may offer a lower minimum investment). However, the Firm, in its discretion, can waive these minimum investment thresholds.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
In limited situations and at a Client’s request the Firm may accept accounts which include the application of performance-based fees as a full or partial alternative to the standard Management Fee. Performance based fee arrangements are available only to qualified Clients and could create an incentive for the Firm to invest in securities which may be riskier or more speculative than the securities it would invest in under a different fee arrangement. In addition, performance fee arrangements could create an incentive for the Firm to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. The Firm employs procedures designed and implemented to treat all Clients fairly and equally, to mitigate potential conflicts of interest attributable to performance-based fee arrangements from influencing the allocation of investment opportunities among Clients. For example, the Firm has implemented a policy whereby all Client orders for a particular security are aggregated and allocated on a pro rata basis electronically prior to making a trade. The Firm’s traders review and monitor Client orders on a real-time basis and the Operations Manager confirms these orders once they are complete. In addition, all accounts with similar investment guidelines are managed pari passu.
Item 10: Other financial industry activities and affiliations Conflicts of interest
As disclosed in Item 4 above, effective December 31, 2020, Kudu became a Preferred Limited Partner of the Firm. The Firm does not have any financial industry affiliations.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Trading As a fiduciary, the Firm has an affirmative duty to act in the best interests of its Clients and to make full and fair disclosure of all material facts, particularly where the Firm’s interests may conflict with those of its Clients. The Firm’s Code of Conduct and Code of Ethics (the “Code”) serve as behavioral benchmarks from which the Firm establishes its compliance program. Briefly, the Code requires each RIM employee to act with integrity, competence, diligence, respect, and in an ethical manner when dealing with current and prospective Clients, the Firm, other employees and colleagues in the investment profession, and other participants in the global capital markets. RIM expects employees to place the interests of Clients and the Firm above their own personal interest and to avoid any actual or potential conflicts of interest. Among other things, the Firm’s Code of Ethics requires that all employees comply with applicable provisions of the federal securities laws and report in a timely manner any violations or potential violations of the Firm’s compliance policies and procedures to the Chief Compliance Officer. Personal Trading Policy All employees or Access Persons are prohibited from front running Client accounts and/or acting upon inside information. Under no circumstance may an Employee, or family member living in the Employee’s household, or any account over which an Employee has control, benefit at the expense of investors or the Firm. Personal securities transactions are to be conducted consistent with Firm policy and in such a manner as to avoid any actual or potential conflict of interest or any abuse of an individual’s responsibility and position of trust. The Firm has instituted a Personal Securities Trading Policy whereby Access Persons may trade for their own account(s) or any account where the Access Person has a beneficial interest in securities which may have been recommended to and/or purchased for the Firm’s Clients at some time in the past, is currently owned by Firm Clients, or may be under consideration for purchase or sale for Firm Clients. Under certain circumstances the Firm may recommend to Clients that they purchase securities in which its employees have a financial interest. Access Persons must complete a pre-clearance request via the web-based compliance platform. Permitted investments include, but may not be limited to, equity securities including options, warrants or other derivative, fixed income (corporate and municipal), treasury securities, certificates of deposit, commercial paper, open- and closed-end mutual funds, ETFs, and private placements. Depending on the market cap of the security, transactions can receive automatic approval. Trade requests outside of the market cap minimums will require CCO and Portfolio Manager approval. There is a 30-day holding period for individual securities. The Firm will maintain the pre‐clearance forms and/or periodic e‐mail approvals in conjunction with the record‐ keeping rule.
Notwithstanding the above, the Firm’s consultants, and or service providers may have personal trading policies which differ from the Firm. The Firm’s compliance department may review the personal trading policies of consultants and/or service providers in cases where such persons or entities have access to the Firm’s portfolio information. Based on the activity of the individual(s), they may be required to attest to the Firm’s compliance policies and procedures. In addition to personal trading activities, other policies and procedures found in the Code of Ethics provide guidelines the Firm and/or employees follow with respect to: • Insider Trading
• Political Contributions
• Outside Business Activities
• Gifts and Entertainment
A copy of the Firm’s Code of Ethics is available to current and prospective Clients upon written request to crteam@rangerinvestments.com or rimcompliance@rangerinvestments.com.
Item 12: Brokerage practices Conflicts of interest
The Firm has complete investment and brokerage discretion over the majority of its Client accounts. Broker Selection and Transactions The Firm selects brokers for its securities transactions based on a number of factors, including, but not limited to, the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of an order and the difficulty of execution; the financial strength, integrity and stability of the broker; the broker’s risk in positioning a block of securities; the quality, comprehensiveness and frequency of available research products or other services the Firm considers to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying the Firm’s other selection criteria. With respect to research and brokerage products or services provided by broker-dealers, the Firm seeks to maintain a soft dollar policy that falls within the safe harbor established by Section 28(e) of the Securities Exchange Act of 1934 (“1934 Act”). Research and brokerage services, as that term is used in Section 28(e), may include both services generated internally by a broker’s own research staff and services obtained by the broker from a third-party research firm. The research and brokerage services obtained may include a broad variety of financial related information and services, including written or oral research and information relating to the economy, industries or industry segments, a specific company or group of companies, software or written financial data, electronic or other quotations or market information systems, financial or economic programs or seminars, or other similar services or information believed to assist the Firm and its advisory functions and services. The Firm believes that its ability to obtain
such products and services is an integral factor in the level of the advisory fees charged to Clients. The Firm will attempt to place portfolio transactions with broker-dealers who, in its opinion, provide the best combination of price and execution (including brokerage commissions). However, the Firm may pay a broker-dealer a commission for effecting a transaction in excess of a commission charged by another broker or dealer as long as the Firm makes a good faith determination that the amount of commission is reasonable in relation to the value of the brokerage and research services provided by the broker-dealer. The Firm maintains formal and informal internal allocation procedures to identify those brokers who provided it with research and execution services that the Firm considers useful to its investment decision-making process. The amount of commission allocated to any broker will be based, in part, on the cost of such research to the broker, and the amount allocated may be higher than that which the Firm would pay for the research were it to pay for it in cash using its own funds. Clients should consider that there is a potential conflict of interest between their interests in obtaining best execution and the Firm’s receipt of and payment for research through brokerage allocations as described above. To the extent the Firm obtains brokerage and research services that it otherwise would acquire at its own expense, the Firm may have incentive to place a greater volume of transactions or pay higher commissions than would otherwise be the case. The soft dollar research and brokerage services the Firm obtains normally benefits many accounts rather than just the one(s) for which the order is being executed, and not all research may be used by the Firm in connection with the account(s) which paid commissions to the broker providing the research. For example, the Firm may use the commissions paid by its Clients who invest in mid cap securities to obtain small cap securities research services. In this situation, the small cap securities research may benefit only a select group of the Firm’s Clients which is different from the group whose commissions generated the soft dollar credits. Best Execution Reviews On at least a quarterly basis, the Firm holds the Best Execution Committee Review Meeting to determine the quantitative and qualitative value ach broker dealer brought to the Firm over the previous three (3) month period. In attendance at the meeting are members of the Firm’s investment team, traders, and a compliance officer. At the meeting, the participants address issues such as, but not limited to, execution quality, research quality, broker responsiveness, and access to analysts and company management. The meeting participants discuss issues with respect to the active broker-dealers on the approved list to determine whether the commissions earned are commensurate with the value received from the broker-dealers. Following the review, the Firm’s head trader makes appropriate revisions and, together with the compliance department, documents the results of the best execution review.
Periodically, as part of the best execution review, members of the investment team, traders and a compliance officer will discuss general soft dollar activities and possible changes, if any, to the list of all soft dollar services. Examples of soft dollar issues discussed during the best execution review may include: •
Changes to the current level of service
•
Prospective products and services being considered
•
Services that are not being fully utilized are obsolete or redundant and should be eliminated
•
Whether the soft-dollar budget targeted for the current quarter or year is in line with the budgeted amounts
•
Mixed-use allocation determinations
The Firm’s compliance department documents and maintains information discussed during the best execution review. Order Aggregation and Allocation The Firm aggregates trades for the same security in the same strategy and allocates Client orders on a pro rata basis electronically prior to making a trade using RIM’s order management system, Advent Moxy. The traders review and monitor Client orders on a real-time basis. Once a trade is complete, the Operations Manager confirms Client orders. All accounts with similar investment guidelines are managed pari passu. Trading is not segmented across product platforms. The trading desk centrally manages all trades. RIM aggregates trade orders to seek best execution. However, in any case in which the Firm believes that aggregation is not consistent with its duty to seek best execution for its Clients, it will not affect the transaction on an aggregated basis. On such occasions, the Firm’s trading desk will report such exception along with the basis for such exception to the compliance department to appropriately document such exception within an exception report. Directed Brokerage A Separate Account may instruct the Firm to affect securities transactions from said Separate Account through a specific broker-dealer. The Firm considers this instruction to be a “directed brokerage arrangement.” In such circumstances, the Separate Account is responsible for negotiating the terms and arrangements for their account with that broker-dealer. The Firm will not seek better execution services or prices from other broker dealers and may not be able to aggregate the Separate Account’s transactions for execution through other broker-dealers with orders for other accounts advised or managed by the Firm. As a result, the Firm may place a directed trade following aggregated trading activity for a particular security. In addition, the Firm may not obtain best execution on behalf of the Separate Account, who may pay materially
disparate commissions, greater spreads, or other transaction costs, or receive less favorable net prices on transactions for the account than would otherwise be the case. To accommodate certain directed brokerage arrangements, the broker-dealer to whom the trades are directed may not meet the Firm’s standards with respect to institutional quality execution capabilities. In such cases, the Firm may resort to “step out” trades to meet the directed brokerage objectives while continuing to maintain the Firm’s best execution objectives. For example, the Firm places an aggregated trade for a particular security with an institutionally oriented broker-dealer which includes instructions to “step out” the portion of the commission to the broker-dealer designated in the directed brokerage arrangement. Essentially, the brokerdealer the Firm selected executes the trade and sends a check for the portion of the commission amount specified in the instructions to the broker-dealer designated in the directed brokerage arrangement. Soft Dollar Reviews In addition to initial reviews, the Firm conducts quarterly periodic evaluations of its soft dollar products and services to, (1) ensure the products and services continue to provide the value to the investment manager which was originally established upon the initial evaluation; and (2) prepare an annual soft dollar program which it believes is in the best interest of the Firm’s Clients. The Firm reviews the annual soft dollar items to ensure the products and services meet Section 28(e) requirements. Each month, a member of the accounting department reviews and verifies all invoices for soft dollar products and services and then submits them to the Firm’s head trader for verification before forwarding them to the relevant soft dollar broker for payment. The soft dollar broker submits a monthly summary of all payments made for research, as well as a detailed listing of commissions generated with the executing soft dollar brokers. A member of the accounting department reviews all research payments and the Firm’s head trader reviews commissions to ensure payments between the commission list submitted by the soft dollar broker(s) and a commission report generated by the Firm’s portfolio management system has been properly reconciled. The soft dollar broker(s) resolves any issues, and any unresolved disputes will be promptly brought to the attention of the compliance department and the Chief Financial Officer. Mixed-Use Soft Dollar Products and Services In some instances, brokerage and research products or services the Firm receives may also be used by the Firm for functions that are not entirely brokerage or research related (i.e., not related to the investment decision-making process). Where a research or brokerage product or service has a mixed-use, the Firm will make a reasonable allocation according to its use and will pay for the non-research or non-brokerage portion in cash using its own funds. The Firm bases its mixed-use allocation decisions on a reasonable combination of factors such as, but not limited to:
•
The percentage of time devoted to the Firm’s use of the product for research or brokerage in relation to non-research or non-brokerage applications.
•
The relative value of the product for each use as the compliance department determines to be reasonable and appropriate; and,
•
The availability and value of comparable products and services.
The compliance department, in consultation with the investment and trading teams, oversees the evaluation of all mixed-use soft dollar items upon initial receipt of the product or service, and then again on a periodic basis. This evaluation concludes in the establishment of final mixed-use allocation decisions.
Item 14: Client referrals and other compensation Conflicts of interest
Promoter - Testimonials and Endorsements for Compensation The Firm may enter into agreements with a marketing group or individual(s) to act as a Promoter of the Firm to Separate Accounts or investors for the Private Funds or Mutual Funds. For their services, such Promoter may receive cash compensation based on a negotiated percentage of the Firm’s Management Fee directly related to the services the Firm may provide to the relevant account or investor. The cash compensation paid by the Firm to Promoter is borne exclusively by the Firm and is not charged back to the Clients who have been solicited by such Promoters. However, because the Firm pays such compensation out of the Management
Fees it collects from a Client, such Client may be indirectly impacted pursuant to the level of Management Fees it is able to negotiate with the Firm. The Firm’s arrangements with a marketing group or Promoter may result in a potential conflict of interest by creating an incentive for the Promoter to recommend RIM investment advisory products and services based on compensation received rather than the investor’s needs. The Firm has implemented procedures to ensure compensation arrangements with an affiliated or unaffiliated third-party who act as a Promoter will comply with the new Marketing Rule under the Adviser’s Act. From time to time the Firm may include the name and/or logo of current separate account clients in marketing materials. Approval by the client is required prior to the use of this information. There is no direct cash compensation from the Firm; as disclosed in Item 5, separate account fees are negotiable. Use of a client name and/or logo is not dependent on any preferential filter or sorting and does not imply that the client is promoting a certain level of skill of the Firm.
Item 9: Disciplinary information
This section requires registered investment advisers and management personnel to disclose all material facts regarding any legal or disciplinary events that would be material to an investors’ evaluation of the Firm or the integrity of its management. The Firm and management personnel have no legal or disciplinary events to disclose.
Item 13: Review of accounts
Each account is reviewed and valued daily or intra-day if triggered by market or economic conditions. Members of the investment staff review each account in a manner consistent with the investment goals of each account. Under the supervision of the Chief Financial Officer, members of the Firm’s accounting and operations staff review the accounts’ valuation, including net asset value calculations, securities positions and pricing information, interest accrual calculations, and cash balance reports generated by the Firm’s accounting system, relevant custodian, prime broker, and brokerage firms on a monthly basis. An independent public accounting firm performs an annual audit of the books and records of the Firm and the Firm’s Private Funds. The Firm typically remits monthly written reports to its Clients, which set forth various financial data and information. Quarterly and annual reports are also provided on a Client-by-Client basis as directed in the Investment Advisory Agreement. RIM’s operations staff reviews the accounts’ valuation, including net asset value calculations, securities positions and pricing information, interest accrual calculations, and cash balance reports generated by the Firm’s accounting system, custodian, prime broker and/or brokerage firms. Investors in a Private Fund or a Mutual Fund receive an audited annual financial report and the information necessary for the investor to complete annual federal income tax returns.
Item 15: Custody
The Firm does not take possession of investor funds or securities for Separate Accounts; nor does the Firm accept authority to deduct fees from Separate Accounts. However, the Firm serves as a General Partner and/or attorney in fact with full discretion over the portfolios of the Private Funds it advises. As a result, the Firm has indirect access to the funds and securities of limited partners in its Private Fund. Pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940, the Firm is considered to have custody of these assets. Accordingly, the Firm implements certain policies and procedures which seek to safeguard investor assets on behalf of its Private Fund(s). The Firm must also comply with additional bookkeeping, auditing, and disclosure requirements, which includes providing investors in the Firm’s Private Fund(s) with audited financial statements on an annual basis. RIM strongly encourages investors and their advisors to closely monitor their account statements, audited financial statements and any other important investment-related materials they receive from the Firm. Any potential discrepancies should be promptly brought to the Firm’s attention by contacting (214) 871-5260.
Item 16: Investment discretion
The Firm has complete discretion (with exceptions) over the selection and amount of securities to be bought or sold without obtaining consent or approval from investors (within the parameters established by the private placement memorandum of each Private Fund, the prospectus and SAI of each Mutual Funds or investment management agreements applicable to each Separate Accounts). Exceptions to investment discretion may include, but not limited to,
Client directed restrictions, Client directed “no trading days,” pre-notification of a capital loss, or if a Model Account (the Firm has no discretion over Model Account assets). Discretionary authority only occurs upon full disclosure to the Client and authorization by such Client pursuant to the operative documents and subscription agreement of each Private Fund, the prospectus for a Mutual Fund or an investment management agreement for a Separate Account. Trades made by RIM on behalf of Client accounts for which it has discretion will be in accordance with that portfolio’s investment objectives and goals.
Item 17: Voting client securities
Proxy Voting Separate Accounts it advises. The Firm seeks to vote such proxies in the interest of maximizing shareholder value. To that end, the Firm votes proxies in a way that it believes is consistent with its fiduciary duty. It is the Firm’s policy to review each proxy statement on an individual basis and consider both the short and long-term implications of each proposal in which it votes. The Firm’s portfolio managers and senior analysts are responsible for identifying the proxies upon which the Firm will vote, voting the proxies in the best interest of Clients, and submitting the proxies promptly and properly. The option to direct the way the Firm votes particular proxy related topics is limited to Separate Account investors only, pursuant to guidelines established in the applicable Separate Account agreement. The Firm has engaged the services of a third-party proxy voting service (the “Proxy Service”) to assist it with administration of the proxy voting process. In addition to general administration assistance, the Proxy Service also includes proxy voting recommendations based upon research and guidelines it publishes. However, the Firm’s proxy voting policies and case-by-case evaluation of each issue may result in proxy votes on certain issues that differ from Proxy Service recommendations. The Firm votes proxies on behalf of the Private Funds, Mutual Funds, and a majority of the Separately Managed Accounts. In connection with any security which is the subject of a proxy vote, the Firm will determine whether any conflict of interest exists between the Firm on the one hand, and the beneficial owners of the securities, on the other hand. If a conflict of interest is identified, the Firm’s portfolio managers, Chief Compliance Officer, and internal or external legal counsel will consult with each other relating to the best method to resolve any actual or apparent conflict between the interest of the Firm and its Clients, in a manner that seeks to vote the best interest of the Client without regard to the conflict. As such, the Firm will determine whether it is appropriate to disclose the conflict to the affected Clients, to give the Clients an opportunity to vote the proxies themselves, or to address the voting issue through other objective means such as voting in a manner consistent with the voting guidelines set forth by the Proxy Service or receiving another independent third-party recommendation. The Firm will maintain a record of the voting resolution of any conflict of interest.
The Firm complies with the SEC N-PX reporting requirement for 13F filers which became effective August 1, 2024. The Firm’s written proxy voting policies and procedures are available for review by investors in each Private Fund, Mutual Fund or Separate Account advised by the Firm. In addition, the Firm maintains a record of all proxy votes cast on behalf of the Private Funds, Mutual Funds, and many of the Separate Accounts it advises; such records are available for review by the Client upon written request to crteam@rangerinvestments.com. Class Action Lawsuits From time to time, the Firm may receive notices regarding class action lawsuits involving securities that are or were held by the portfolios of a Private Fund, a Mutual Fund or upon request, certain Separate Accounts it advises. As a matter of policy, the Firm refrains from serving as the lead plaintiff in class action matters and refrains from submitting proofs of claim where the Firm believes, in its sole discretion, which either the recovery amounts are likely to be negligible, or such participation is not in the interest of the applicable account. As a result, the Firm may on behalf of Clients forgo participation in class action lawsuits.
Item 18: Financial information
The Firm has no known financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients. In addition, the Firm has never been the subject of a bankruptcy petition.
Timeline
- May 21, 2008Founded Ranger Investment Management, L.P. is founded2
Filings
23 filings to the SEC since October 2021: 23 other. The latest 20:
- Aug 13, 202613F-HR EDGAR
- Jul 28, 2026N-PX EDGAR
- May 15, 202613F-HR EDGAR
- Feb 13, 202613F-HR EDGAR
- Nov 5, 202513F-HR EDGAR
- Aug 19, 202513F-HR EDGAR
- Aug 1, 2025N-PX EDGAR
- May 15, 202513F-HR EDGAR
- Feb 13, 202513F-HR EDGAR
- Nov 4, 202413F-HR EDGAR
- Aug 28, 2024N-PX EDGAR
- Aug 14, 202413F-HR EDGAR
- May 15, 202413F-HR EDGAR
- Feb 14, 202413F-HR EDGAR
- Nov 14, 202313F-HR EDGAR
- Aug 14, 202313F-HR EDGAR
- May 5, 202313F-HR EDGAR
- Feb 14, 202313F-HR EDGAR
- Nov 14, 202213F-HR EDGAR
- Aug 15, 202213F-HR EDGAR
The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
Ranger Investment Management, L.P. has told the SEC it owns more than 5% of 2 companies, latest first (Schedules 13D and 13G).
- Excelerate Energy, Inc.SCHEDULE 13G/A May 17, 2023 to Dec 29, 20255
- Aris Water Solutions, Inc.SCHEDULE 13G/A Mar 9, 2023 to May 6, 20256
Sources
The numbers on this page point here. Each one links to the record it came from.
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