Private company

Whitefort Capital Management, LP

Limited partnership registered in the United States, active since 2016. Summary from the record

Last updated Oct 21, 2026.

Overview

  • HeadquartersNew York, United States2
  • Legal formLimited Partnership2
  • Kind of organizationLimited partnership2
  • LEI549300ZQM8PQN8GOTL372
  • StatusActive2
  • LEI statusIssued and current2
  • Registered addressCORPORATION TRUST CENTER 1209 ORANGE ST, 19801 Wilmington, United States2
  • Registered withDivision of Corporations, Department of State, 63154092

Corporate structure

Whitefort Capital Management, LP is part of a group headed by Safida LLC. 9 entities, 3 countries on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of Whitefort Capital Management, LP

  • Jk Advisors LLC Owns 25% to 50% of Whitefort Capital Management, LP, since 03/2017 (Form ADV)
  • David Lorin Salanic Owns 75% or more of Safida LLC, since 03/2017 (Form ADV)
  • Joseph Meyer Kaplan Owns 75% or more of Jk Advisors LLC, since 04/2015 (Form ADV)

Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (7 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

Whitefort Capital Management, LP 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$1.1B3 3 accounts, all with discretion
  • Employees11 6 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 3 ($1.1B)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-116942, CRD 288534 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).

  • SAFIDA LLCowns 50% to 75%, since 03/2017
  • JK ADVISORS LLCowns 25% to 50%, since 03/2017
  • Joseph Meyer Kaplanowns 75% or more of JK ADVISORS LLC, since 04/2015
  • David Lorin Salanicowns 75% or more of SAFIDA LLC, since 03/2017

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/27/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Whitefort is a Delaware limited partnership that was formed in February 2017. The Firm provides investment management services to the private investment funds described below (each a “Fund” and together the “Funds”): Whitefort Capital Fund, LP (the “Onshore Feeder Fund”) and Whitefort Capital Offshore Fund, Ltd. (the “Offshore Feeder Fund”) are feeder funds for Whitefort Capital Master Fund, LP (the “Master Fund”, and together with the Onshore Feeder Fund and Offshore Feeder Fund, the “Whitefort Fund”). Whitefort Capital Management GP, LLC is the General Partner of the Firm and David Salanic and Joseph Kaplan are its Managing Members. Whitefort Capital GP, LLC is the General Partner of the Onshore Feeder Fund and the Master Fund (the “Whitefort Fund General Partner”). Mr. Salanic and Mr. Kaplan are also the Managing Members of the Whitefort Fund General Partner. In managing the Funds, the Firm pursues a value-oriented event-driven strategy across the capital structure, including stressed/distressed credit and legal/process oriented special situations. Whitefort does not tailor advisory services to the individual or particular needs of investors in the Funds. Such investors will accept the terms of advisory services as set forth in the Funds’ respective governing documents. The Firm has broad investment authority with respect to the Funds and, as such, investors should consider whether the investment objectives of a Fund are in line with their individual objectives and risk tolerance prior to investment. The principal owners of Whitefort are David Salanic and Joseph Kaplan. As of December 31, 2025, Whitefort managed U.S. $1,051,097,751 of regulatory assets under management, all of which is managed on a discretionary basis.

Item 5: Fees and compensation Fees

Fees and compensation are described in the advisory agreements Whitefort entered into with each Fund. All of the investors in the Funds are “qualified purchasers” (as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “1940 Act”)). For the Whitefort Fund, Whitefort receives management fees based on a percentage of the assets under management, as well as a performance allocation based on a percentage of the aggregate net gains (including current income and realized and unrealized gains and losses, determined after all Fund expenses and management fees). Whitefort has the right to reduce, waive, assign, participate or otherwise share the management fee, as applicable. Once paid, the management fee will not be refundable. An investor admitted into or withdrawing, either partially or in whole, from the Whitefort Fund other than on the first day of a calendar quarter is subject to a prorated management fee. The General Partners receive a performance-based allocation derived from the net appreciation of each investor’s capital account as described fully in the Funds’ governing documents. Management fees and performance allocations are deducted from the Funds’ accounts by the Funds’ administrator. Management fees are paid quarterly in advance on the first day of each

calendar quarter, whereas performance-based allocations are made at the end of each fiscal year and upon a limited partner’s withdrawal of all or any portion of its capital account. Under its respective governing documents, each Fund will bear or reimburse the Firm and/or the General Partners for advancing, the Fund’s operating and other expenses. The Firm and/or the General Partners may, in their discretion, waive their right to be reimbursed for any of the following expenses for any period of time. Expenses borne by the Funds, or reimbursed to the Firm and/or the General Partners, shall include, but not be limited to: (1) expenses related to investment transactions and positions for the Funds’ account, including brokerage commissions and custody charges, clearing and settlement charges, interest and commitment fees on loans and debit balances, costs of borrowing securities to be sold short; (2) third party operations, accounting and portfolio and trading-related software and system costs; (3) research and market data fees, expenses and materials (including Bloomberg services and terminal, Debtwire service, Reorg Research service, Covenant Review service and other subscriptions to news and quotation services and print publications, computer hardware, data feed for portfolio securities, data and software used for research (and any exchange fees related thereto), and travel expenses (including transportation and lodging) relating to investment research and monitoring, due diligence and execution); (4) trustees’ fees; (5) proxy solicitation firm fees; (6) public relations firm fees related to the Funds’ investment activities; (7) fees and expenses incurred in connection with the Funds’ risk management systems and processes (including software); (8) costs of any outside appraisers, sub-advisors, accountants, auditors, attorneys, independent pricing services or other experts or consultants engaged by the Firm, the General Partners and/or the Funds to serve the needs of the Funds; (9) the fees, costs and expenses of the Funds’ governance committees; (10) fees and expenses of any Fund’s board of directors (including, without limitation, expenses related to the organization and conduct of directors’ and shareholders’ meetings (including, without limitation, travel, lodging and meal expenses) and director registration fees); (11) fees and expenses of the Funds’ administrator (such as portfolio and investor accounting, middle office, tax and financial reporting and investor servicing costs); (12) costs and expenses in connection with communications to investors, including preparation and distribution to investors of reporting materials; (13) bank charges; (14) costs of insurance, including, without limitation, directors and officers liability insurance, errors and omission insurance, and cybersecurity insurance and liability insurance covering the Funds, the General Partners, the Firm and the members, partners, officers, employees and agents of any of them, and each member of the governance committee (in each case, even if such insurance covers conduct for which indemnity would not be available from the Funds); (15) organizational expenses and expenses incurred in connection with the offering and sale of shares and interests, including, without limitation, the preparation of the Funds’ governing documents, subscription agreement, registered office fees, fees and expenses of the Firm incurred in connection with “world sky” matters and private placement regimes, including the European Alternative Investment Fund Managers Directive, and Form D and blue sky and similar fees and expenses, and expenses incurred in connection with negotiating and complying with provisions of the Income Sharing Agreement and any other side letter agreement with investors; (16) all legal fees and costs, including legal expenses arising in connection with the Funds’ investing activities (whether or not materialized), legal expenses relating to the formation and organization of the Funds and legal expenses and costs (including settlement costs) arising in connection with any litigation or regulatory investigation instituted against the Funds, the Firm and/or the General Partners regarding the affairs of the Funds; (17) the Funds’, the General Partners’ and the Firm’s costs and expenses relating to regulatory and statutory filings (such as Cayman Islands regulatory fees, charges and expenses with respect to the Funds, the Funds’ directors, the General Partners and the Firm’s, filings for the Foreign Account Tax Compliance Act (“FATCA”) provisions of the United States Hiring Incentives to Restore Employment Act of 2010 (the “U.S. HIRE Act”), filings pursuant to Automatic Exchange of Information (“AEOI”) and Form PF); (18) fees and expenses incurred in connection with the compliance

by the Funds (or by the Firm and/or the General Partners in relation to advising the Funds) with applicable laws, rules, regulations and procedures (including the cost of any outside compliance consultants, but excluding the preparation of the Firm’s Form ADV and updates thereto); (19) any taxes applicable to the Funds on account of their operations and/or investments (including the cost of professional advice relating thereto), including any withholding or transfer taxes; external administrative costs, including portfolio and investor accounting, tax and investor servicing costs; valuation costs and the costs of the audit of the Funds’ financial statements; (22) other expenses related to the offering of the Funds’ securities (but not including the Firm’s travel, food and lodging expenses relating to marketing the Funds’ securities); and other similar fees and expenses which are substantially of the nature already enumerated above. The Funds will also bear other organizational and launch fees and expenses per the applicable Fund’s governing documents. In addition, the Funds will bear the expenses of any blocker corporation formed by a Fund. The Funds purchase and maintain (or reimburse the Firm and/or the General Partners for purchasing or maintaining) directors’ and officers’ and errors and omissions insurance on behalf of the Funds, the General Partners, the Firm, their principals, officers, employees, partners, directors, members, affiliates or agents of any of the foregoing. Please see “Item 12: Brokerage Practices” of this Brochure for more information about the Firm’s brokerage arrangements for its Funds. Please refer to each Fund’s governing documents for further information regarding the fees and expenses applicable to the Funds. Whitefort and its employees do not accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

The Firm’s investment objective is to generate superior risk-adjusted returns over time. Whitefort pursues a value-oriented event-driven strategy across the capital structure, including stressed/distressed credit and legal/process oriented special situations. The Firm favors investments that it believes can be profitable through the validation of either a financial, legal, or process/activist investment thesis. Whitefort has an absolute-return orientation, focused on seeking downside protection and asymmetric risk/return opportunities with low correlation to both markets and the economy. CERTAIN RISK FACTORS An investment in the Funds involves a high degree of risk, including the risk that the entire amount invested may be lost. Investors should consider the following factors before investing in the Funds. The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Funds. See the Funds’ management agreements for a more exhaustive list of risk factors. Prospective investors are urged to consult their professional advisers and to thoroughly review the relevant governing documents for each particular Fund before deciding to make an investment in any of Whitefort’s Funds. Investment Risks. All securities investments risk the loss of capital. The Firm believes that the Funds’ investment program and the Firm’s research process will moderate this risk through a careful selection of securities and other financial instruments. However, no guarantee or representation is made that the Funds’ investment program will be successful or that the Funds will not incur losses. The Funds’ investment program may utilize investment and trading techniques including, but not limited to, trading in put and call options and other derivatives, the use of leverage, short sales, and the investment in illiquid securities, which in practice can, in certain circumstances, increase the adverse impact to which the Funds may be subject. In certain transactions, the Funds may not be “hedged” against market fluctuations or, in reorganization or liquidation situations, may not accurately value the assets of the subject company or the degree of legal and regulatory risk associated with investments in the securities of companies in such situations. This can result in losses, even if the proposed transaction is consummated. The Firm will attempt to assess the foregoing risk factors, and others, in determining the extent of the position it will take in the relevant securities and the price it is willing to pay for such securities. However, such risks cannot be eliminated. Changes and Uncertainty in U.S. and International Regulation. The Funds may be adversely affected by uncertainties such as international and domestic political developments, changes in government policies, taxation, currency fluctuations and other developments in the laws and regulations of the countries to which the Funds are exposed through their investments or investor base. The tax and regulatory environment for private investment funds is evolving,

and changes in the regulation or tax treatment of private investment funds and their investments may adversely affect the value of investments held by the Funds and may impair their ability to pursue their trading strategies. During this period of uncertainty, market participants may react quickly to unconfirmed reports or information and as a result there may be increased market volatility. This unpredictability could cause the Firm to alter investment and trading plans, including the holding period of positions and the nature of instruments used to achieve the Funds’ investment objectives. In the United States the Funds, the Firm and the General Partners may be adversely affected as a result of new or revised legislation or regulations imposed by the SEC, the Financial Stability Oversight Council, and other U.S. governmental regulatory authorities or self-regulatory organizations that supervise the financial markets. In addition, the securities and futures markets are subject to comprehensive statutes and regulations, including margin requirements. Regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. Actions in the future of one or more governments could have a significant effect on the various economies and/or the issuers in which the Funds have invested, which could affect market conditions, prices and yields of securities in the Funds’ portfolios as well as any trading strategies that rely on historical pricing relationships. Further, some currency prices may be volatile, and there is the possibility of government controls on currency exchange or government intervention in currency markets, which could adversely affect the Funds. Political and economic instability in any of the countries in which the Funds invest could adversely affect the Funds’ investments. Concentration of Investments. The Funds are not restricted in the amount of their capital that may be committed to any sector, industry or geographic region, and at times the Funds may hold a relatively large concentration in a particular sector, industry and/or geographic region. Losses incurred in connection with those investments could have a material adverse effect on the Funds’ overall financial condition. The value of the Funds’ investment portfolio will be more susceptible to any single occurrence affecting one or more of those sectors, industries or geographic regions than would be the case with a more diversified investment portfolio. Distressed Investments. The Funds will invest in “distressed investments” – securities, trade claims, litigation claims, warrants and other derivatives, real estate interests, bank debt and other obligations of entities which are experiencing significant financial or business difficulties. Distressed investments may result in significant returns but involve a substantial degree of risk. The Funds may lose a substantial portion or all of their investment in a distressed investment or may be required to accept cash or securities with a value much less than the Funds’ investment. In addition, it frequently may be difficult to obtain information as to the true condition of such issuers. Distressed investments are often significantly less liquid than marketable securities or other assets with readily ascertainable market value. Such investments also may be adversely affected by laws relating to, among other things, fraudulent conveyances, voidable preferences, lender liability, litigation risks and a bankruptcy court’s discretionary power to disallow, subordinate or disenfranchise claims. The market price of such investments is subject to abrupt and erratic market movements and above average price volatility, and the spread between the bid and asked prices of such instruments may be greater than normally expected. In investing in distressed investments, litigation is sometimes required, which can be time-consuming and expensive, and can lead to unpredicted delays or losses. Trade claims are purchased on an individual basis from trade creditors of the insolvent entity. As a result, it may be difficult for the Firm to identify claimholders and to acquire a sufficient quantity of claims to make an investment worthwhile. Trade claims are subject to individual defenses which may be asserted by the debtor as well as possible deficiencies in the seller’s title to the claim. As a result, the Funds will have a greater risk of loss than would apply to a

more generic debt instrument and the Funds may be forced to incur substantial legal fees in enforcing their rights. Any investment that the Funds may make in real estate will be subject to the risk’s incident to the ownership and operation of residential, commercial and industrial real estate. In addition, the value of any loans and bonds secured by real estate assets may be detrimentally affected if the real estate collateral declines in value. To the extent that the Funds invest, directly or indirectly, in real property, the Funds will be subject to the following risks that may affect the value of such real property: risks associated with both the domestic and international general economic climate, local real estate conditions, community conditions, population trends, local employment conditions, changes in supply of, or demand for, competing properties in an area (as a result, for instance, of over-building), energy and supply shortages, various uninsured or uninsurable risks, terrorism, war, natural disasters, the ability of the Funds and third parties to manage the real properties, changes in applicable laws and government regulations (including tax laws), potential environmental and other legal liabilities, general availability of financing and changes in interest rate levels, changes in interest rates and ordinary market fluctuations in the value of property or equity taken as collateral for any loans made. Certain of these risks cannot be predicted with certainty or controlled by the Firm. If the Funds purchase real property or forecloses on loans or bonds secured by real property, the Funds will incur the burdens of ownership of real property, which include the paying of expenses and taxes maintaining such property and any improvements thereon and ultimately disposing of such property. The Funds may purchase creditor claims after the commencement of a bankruptcy case. Under judicial decisions, it is possible that such purchase may be disallowed by the bankruptcy court if the court determines that the purchaser has taken unfair advantage of an unsophisticated seller, which may result in the rescission of the transaction (presumably at the original purchase price) or forfeiture by the purchaser. The Dodd-Frank Act established the Orderly Liquidation Authority (the “OLA”), an insolvency regime for large, interconnected financial companies, including broker-dealers, whose failure poses a significant risk to the financial stability of the United States. The Funds may invest in, or transact with, such large, interconnected financial companies and therefore may face losses if such financial companies are put into receivership and then liquidated or reorganized upon a determination by the U.S. Federal Deposit Insurance Corporation (the “FDIC”) and the Board of Governors of the U.S. Federal Reserve. If a financial company becomes liquidated or reorganized by the OLA, the Funds’ investments in such a financial company could be adversely affected. Compared to bankruptcy proceedings, creditors, shareholders and contract counterparties will have less input into and/or advance notice about the liquidation or reorganization of the financial company. While the FDIC has outlined certain aspects of its strategy and promulgated certain rules and regulations with respect to the OLA, it is unclear how financial companies that become subject to liquidation proceedings or reorganizations by the OLA will ultimately be affected. Equity Securities. The Funds will invest in equity and equity-related securities. Equity securities fluctuate in value in response to many factors, including the activities, results of operations and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic environments. In addition, events such as political instability, terrorism and natural disasters may be unforeseeable and contribute to market volatility in ways that may adversely affect investments made by the Funds. Significant Positions; Shareholder Activism. At times, the Funds may engage in proxy contests, takeover bids, shareholder class actions or other litigation, or other activity which may place the Funds in a high-profile position which is adverse to issuer management and/or other security holders. The Funds may, as a result of such techniques or otherwise, obtain a

Read the rest in the brochure

Item 7: Types of clients

Whitefort provides advisory services to the Funds, which are private investment funds. Investors in the Funds are generally high net worth individuals and institutional investors that qualify as “accredited investors” (as defined in Rule 501 under the Securities Act of 1933, as

amended) and “qualified purchasers” (as defined under the 1940 Act). The subscription minimums for each Fund are disclosed in their respective governing documents which are provided to investors or prospective investors for each Fund. The Firm, the Managing Members, and certain related parties have entered into an agreement with a certain investor (the "Strategic Investor"), whereby the Strategic Investor has made a significant investment in the Whitefort Fund. The Strategic Investor contributed a significant sum of capital to the Whitefort Fund, on certain terms not offered to other investors. The Strategic Investor has no rights with respect to the operation of the Firm, the Funds or the General Partners.

Item 6: Performance-based fees and side-by-side management Conflicts of interest

As discussed above, the General Partners of the Funds receive a performance-based allocation from the Funds derived from the net appreciation of each investor’s capital account as described fully in the Funds’ respective governing documents. All investors in the Funds who are charged a performance allocation meet the “Qualified Client” standard as set forth in Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). For the Whitefort Fund, the Whitefort Fund General Partner receives a performance-based allocation as a percentage of the annual net appreciation of each investor’s capital account as described fully in the Whitefort Fund’s governing documents. Net appreciation includes net realized and unrealized profits and losses, fund expenses and is calculated net of management fees, but before the performance-based allocation. Performance-based allocation arrangements create an incentive for the Firm to recommend investments which could be riskier or more speculative than those which would be recommended under a different arrangement. Such arrangements also create an incentive to favor higher paying accounts over other accounts in the allocation of investment opportunities. Whitefort has procedures designed and implemented to ensure that all Funds are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among Funds. Please refer to Item 8 below and each Fund’s governing documents for further information regarding risk factors and conflicts of interest.

Item 10: Other financial industry activities and affiliations Conflicts of interest

The management and employees of Whitefort plan to dedicate substantially all of their professional efforts to the Firm and affiliates and currently have no material outside business interests.

Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

Trading Code of Ethics Pursuant to Rule 204A-1 of the Advisers Act The Firm has adopted a Code of Ethics pursuant to Rule 204A-1 of the Advisers Act that establishes various procedures with respect to investment transactions in accounts in which Whitefort’s employees or related persons have a beneficial interest or accounts over which an employee has investment discretion. The foundation of the Code of Ethics is based on the underlying principles that:   

Employees must at all times place the interests of the Funds first; Employees must make sure that all personal securities transactions are conducted in a manner consistent with the Code of Ethics; and Employees should not take inappropriate advantage of their position at Whitefort.

All Firm employees are deemed to be “Supervised Persons” and are required to adhere to the Code of Ethics which covers among other topics, fiduciary duty and duty of confidentiality, personal trading, prevention and detection of insider trading, outside business activities, gifts and entertainment and political contributions. All employees are required to certify their adherence to the Code of Ethics upon commencement of employment and annually thereafter. In general, employees (and members of their immediate households) are not permitted to invest in equities, options or futures except for the purpose of liquidating any such holdings after the commencement of employment at the Firm. All such liquidating trades require pre-approval from the Chief Compliance Officer (“CCO”).

This policy does not apply to transactions involving government securities or open-end mutual funds, ETFs or other instruments which afford the investor no discretion over individual securities transactions. All Firm employees must direct their brokers to send duplicate copies of trade confirmations and brokerage statements to the CCO. These records are used to monitor compliance with the foregoing policies. Employees must also obtain pre-approval from the CCO before engaging in any outside business activities. Insider Trading Policies and Procedures The Firm through its Code of Ethics maintains Insider Trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information. Among other things, such policies seek to control and monitor the flow of inside information to and within Whitefort, as well as prevent trading based on inside information. On a periodic basis, employees are required to certify to their compliance with the Compliance Manual and Code of Ethics, including the Insider Trading Policies. A copy of the Firm’s Code of Ethics is available to any client or prospective client upon request. Privacy Policy Whitefort is committed to maintaining the confidentiality, integrity and security of our investor’s personal information. It is our policy to collect only information necessary or relevant to our management business and use only legitimate means to collect such information. Whitefort does not disclose any non-public personal information about its investors or former investors to anyone except for servicing and processing transactions and as required by law. Whitefort restricts access to non-public personal information about investors to those employees with a legitimate business need for the information. Whitefort follows security practices and maintains physical, electronic, and procedural safeguards aimed at protecting investor non-public personal information. Additionally, we provide a copy of our privacy policy to our investors on an annual basis. Upon request, Whitefort will provide you with a copy of our privacy policy.

Item 12: Brokerage practices Conflicts of interest

Whitefort has full discretionary authority to manage the Funds, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. Our authority is in accordance with our internal policies and procedures and each Fund’s investment guidelines. In selecting brokers to effect portfolio transactions for the Funds, the Firm considers factors such as price, the ability of the brokers to effect the transactions, the brokers’ facilities, reliability and financial responsibility and the provision or payment (or the rebate to the Fund for payment) of the costs of property or services (e.g., short-term custodial services, research services, news and quotation services, publications, and other services). Accordingly, if the Firm determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, the Fund may pay commissions to such broker in an amount greater than the amount another broker might charge. Aggregation

In general, the Firm aggregates trade orders for the Funds to achieve more efficient execution or to provide for equitable treatment among accounts. The Funds participating in aggregated trades will be allocated securities based on the average price achieved for such trades. Whitefort reserves the right, in its sole discretion, to change brokerage and custodial arrangements for the purpose of trading on behalf of the Funds without further notice to investors. Best Execution As an investment adviser, the Firm has a fiduciary duty to seek best execution for Fund transactions. As a matter of policy and practice, the Firm seeks to obtain best execution for Fund transactions, i.e., seeking to obtain not necessarily the lowest commission but the best overall qualitative execution in the particular circumstances. Allocation Policy Whitefort maintains a written policy for the allocation of investment opportunities among its clients. This policy is designed to implement a fair and equitable allocation process based on pre‑set parameters. Principal Transactions Neither Whitefort nor any of its affiliates may, directly or indirectly, while acting as principal for its own account or any account of which Whitefort or its affiliates own 25% or more, knowingly sell any security to, or purchase any security from, an advisory client without disclosing to such client in writing, prior to the completion of such transaction, the capacity in which Whitefort is acting, and obtaining the consent of the advisory client to the transaction. Soft Dollars The Firm may choose to engage in formal soft dollar arrangements with respect to securities transactions for the Fund at any time. If and/or when the Firm chooses to engage in such arrangements, it will do so in accordance with the safe harbor for soft dollars created by the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Trade Errors Whitefort on occasion experiences errors with respect to trades made on behalf of the Funds. Trade errors can result from a variety of situations, including for example, when the wrong security is purchased or sold, when the correct security is purchased or sold but for the wrong account, when the wrong amount is purchased or sold (e.g., 1,000 shares instead of 10,000 shares are traded), or when a misallocation among the Funds occurs. Whitefort endeavours to detect trade errors prior to settlement and correct them in an expeditious manner. Whitefort will analyze any trade error on a case-by-case basis to determine whether it will reimburse any losses suffered by a Fund as a result of a trade error. In addition, Whitefort will not correct a trade error made for one Fund by causing the other Fund to buy or sell the securities. Whitefort also will not directly or indirectly use soft dollars to correct trade errors.

Item 14: Client referrals and other compensation Conflicts of interest

Whitefort does not receive economic benefits as a result of investment advice or investment advisory services provided by Whitefort to the Funds, other than from the Funds. Whitefort does not currently utilize any third-party marketers or solicitors.

Item 9: Disciplinary information

The Firm has not been subject to any disciplinary action, whether criminal, civil or administrative (including regulatory) in any jurisdiction. Likewise, no persons involved in the management of the Firm have been subject to such action.

Item 13: Review of accounts

The Funds are reviewed on a continual basis by the co-portfolio managers and our operations group to assure conformity with investment objectives and guidelines.

Whitefort engages in active management for the Funds and, accordingly, reviews transactions, positions and cash balances on a daily basis. Whitefort has also engaged an independent administrator to prepare monthly unaudited reports reviewing each Funds’ performance for the month. Audited financial statements are prepared by an independent auditor and are distributed on an annual basis. The fiscal year of the Funds ends on December 31. As soon as is practicable but not later than 120 days after the end of each fiscal year following the commencement of the Funds’ investment operations, annual audited financial statements of the Fund for such year will be sent to investors. In addition, unaudited statements of net asset value will be sent to the Whitefort Fund investors no less frequently than monthly.

Item 15: Custody

The Firm will comply with the requirements of the Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) with regard to the Firm’s custody of the Funds’ assets by meeting the conditions of the pooled vehicle annual audit provision. Whitefort will provide all investors with audited financial statements for the Funds in which they are invested within 120 days of such Fund’s fiscal year end. In addition, the audited financial statements will be prepared by an independent accounting firm that is registered with, and subject to, review by the Public Company Account Oversight Board, in accordance with U.S. Generally Accepted Accounting Principles. Investors should carefully review the audited financial statements of the Funds.

Item 16: Investment discretion

Whitefort has full discretionary authority to manage the Funds, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. These terms are set out in the relevant governing documents for each Fund.

Item 17: Voting client securities

As per Whitefort’s policy, adopted pursuant to Rule 206(4)-6 of the Advisers Act, the Firm votes proxies on a case-by-case basis. Prior to voting a proxy, the relevant employees of Whitefort will make a determination, in their opinion, as to what vote if any, is in the best interest of the Funds. Whitefort maintains written records of the proxy vote on each occasion a proxy is voted. Investors may request a copy of our proxy voting policy, as well as the records of any proxy votes for the respective Fund in which they have an investment. To request a copy, please contact 212-259-4370.

Item 18: Financial information

Registered investment advisers are required in this Item to provide certain financial information or disclosures about the registered investment adviser’s financial condition. The Firm has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to the Funds and has not been the subject of a bankruptcy proceeding.

Timeline

  1. Dec 31, 2016Founded Whitefort Capital Management, LP is founded2

Filings

24 filings to the SEC since October 2021: 24 other. The latest 20:

  1. Aug 28, 2026N-PX EDGAR
  2. Aug 14, 202613F-HR EDGAR
  3. May 15, 202613F-HR EDGAR
  4. Feb 17, 202613F-HR EDGAR
  5. Nov 14, 202513F-HR EDGAR
  6. Nov 12, 202513F-HR/A EDGAR
  7. Aug 29, 2025N-PX EDGAR
  8. Aug 14, 202513F-HR EDGAR
  9. May 15, 202513F-HR EDGAR
  10. Feb 14, 202513F-HR EDGAR
  11. Nov 14, 202413F-HR EDGAR
  12. Aug 30, 2024N-PX/A EDGAR
  13. Aug 30, 2024N-PX EDGAR
  14. Aug 14, 202413F-HR EDGAR
  15. May 15, 202413F-HR EDGAR
  16. Feb 14, 202413F-HR EDGAR
  17. Nov 14, 202313F-HR EDGAR
  18. Aug 14, 202313F-HR EDGAR
  19. May 12, 202313F-HR EDGAR
  20. Feb 14, 202313F-HR EDGAR

The 24 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

Whitefort Capital Management, LP has told the SEC it owns more than 5% of 7 companies, latest first (Schedules 13D and 13G).