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Kore Advisors LP: investment adviser
Kore Advisors LP is an investment adviser registered with the SEC (file 801-73097, CRD 159663). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $1.2B
- Discretionary
- 99%
- Accounts
- 9
- Employees
- 15
- In advisory roles
- 6
- Disclosures
- 0
Company page · SEC adviser record · Full Form ADV (PDF)
The firm reports that it or a related person has custody of client cash and securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| Private funds and other pooled vehicles | 6 | $888.0M | 71.7% |
How it is paid
- A percentage of assets under your management
- Performance-based fees
Services
- 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: PORTFOLIO MANAGEMENT FOR SEPARATELY MANAGED ACCOUNT
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Koz LLLP | Company (U.S.) | Limited partner | E 75% or more | Jun 1997 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| Koz LLLP | Kore Management Member LLC | Company (U.S.) | E 75% or more | Yes | |
| J. Gary Kosinski, Jr. Irrevocable Trust DTD | Koz LLLP | Company (U.S.) | C 25% to 50% | Yes | |
| J. Gary Kosinski, Jr. Revocable Trust DTD | Koz LLLP | Company (U.S.) | C 25% to 50% | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
Kore Advisors LP - Part 2A, filed Aug 28, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
Kore Advisors LP (“Kore” or the “Firm”) is a Delaware limited partnership formed in 2002 and has its principal place of business in Florida. Kore Management LLC (“Kore Management”), a Delaware limited liability company, is the General Partner of Kore. Kore is beneficially owned and controlled by Koz LLLP (“Koz”), a Florida limited liability limited partnership, which is beneficially owned by J. Gary Kosinski, Kore’s Co-Chief Investment Officer and Chief Risk Officer. Alec Mallinger is the Chief Compliance Officer of the Firm. Kore has been registered with the SEC as an investment adviser since January 2012. Kore is a member of the National Futures Association (“NFA”) and registered as a commodity pool operator with the CFTC. For CFTC purposes, J.
Read the rest of Item 4 (382 more words)
Gary Kosinski, Kore Management, and Koz are listed as Principals of the Firm and J. Gary Kosinski is registered as an Associated Person of the Firm. Kore currently provides discretionary and non-discretionary investment management services to private funds (“Funds”) and certain separately managed accounts (“Managed Accounts”). Kore’s current private fund clients include: (1) Kore Fund Ltd. (“Kore Fund”), a Cayman Islands exempted company; (2) Kore Onshore Fund LP (“Kore Onshore Fund”), a Delaware limited partnership; (3) Kore Offshore Fund Ltd., a Cayman Islands exempted company (“Kore Offshore Fund”); (4) Kore Partners Series 2, a Series of Kore Partners LP (“KPS2”), a Delaware Series Limited Partnership; and (5) Kore Partners Series 4, a Series of Kore Partners LP (“KPS4”), a Delaware Series Limited Partnership. Each of Kore Onshore Fund and Kore Offshore Fund invests substantially all of its respective capital in Kore Fund (i.e., each of Kore Onshore Fund and Kore Offshore Fund is a “feeder fund” and Kore Fund is a “master fund” in what is commonly known as a “master-feeder” structure). Kore also acts as sub-adviser to Kore Insurance Fund, a Series of SALI Multi-Fund V, LP (“Kore IDF”), which invests a majority of its assets in the Kore Onshore Fund. Kore Fund, Kore Onshore Fund, Kore Offshore Fund, KPS2, and KPS4 are collectively referred to as the “Funds,” and together with the Managed Accounts, are sometimes collectively referred to herein as “Clients” or “Client Accounts.” All discussions regarding the Funds in this Brochure, including but not limited to investments and strategies used in managing the Funds, the fees and other costs associated with an investment in the Funds, and conflicts of interest faced by the Firm and its affiliates in connection with management of the Funds, are qualified in their entirety by reference to each Fund’s respective confidential offering memorandum and governing documents. Kore IDF is governed by a sub-adviser agreement which sets forth certain investment guidelines and restrictions regarding Kore’s investment management activities with respect to Kore IDF and may be modified from time-to-time in consultation with SALI Fund Services, the investment manager to Kore IDF. As of December 31, 2025, Kore managed approximately $1,239,000,000 in regulatory assets under management (“RAUM”), of which approximately $1,223,000,000 was managed on a discretionary basis and $16,000,000 was managed on a non-discretionary basis.
Item 5. Fees and compensation
Generally, Client Accounts are charged (i) an annual management fee, which is calculated based upon net asset value, and (ii) a performance allocation, which is calculated based upon a percentage of the net capital appreciation of the respective Client Account at the end of each fiscal year.
Kore’s fee schedule is generally as follows: Management Fee: 1.25% annually (0.1042% monthly) Performance Allocation: 15% annually (subject to a hurdle rate and high-water mark for certain Funds) The Management Fee is accrued monthly and paid quarterly in arrears and is prorated for partial periods. The Management Fee is exclusive of brokerage commissions, transaction fees, custodial fees, and other administrative costs and expenses which shall be incurred directly by the respective Client.
Read the rest of Item 5 (106 more words)
Fees received by Kore are generally deducted directly from the respective Fund by the Fund Administrator, which then pays Kore. Please see Item 12, “Brokerage Practices” for a discussion of Kore’s brokerage arrangements. Both the Management Fee and Performance Allocation may be subject to fee waivers with respect to certain Funds and Client Accounts. Management Fees and Performance Allocations are generally not subject to negotiation; however, Kore reserves the right to waive or impose different fees or otherwise modify fee arrangements for an existing investor in any Fund with the consent of such investor. KPS2, KPS4, and certain affiliated Managed Accounts do not pay Management Fees.
Item 6. Performance-based fees and side-by-side management
As discussed above, Kore may be entitled to a Performance Allocation based on a share of appreciation of a Fund’s assets. Any investor that pays a performance fee must be a “Qualified Client” as set forth in Rule 205-3 of the Investment Advisers Act of 1940 (the “Advisers Act”). In calculating the Performance Allocation for a Fund, Kore includes realized and unrealized capital gains and losses.
Read the rest of Item 6 (231 more words)
Generally, at the end of each year, Kore charges an aggregate amount equal to 15% of the new net profits, subject to the “high-water mark” and “hurdle rate.” The “high-water mark” feature prevents Kore from receiving a performance allocation for profits that simply restore previous losses and is intended to ensure that such performance allocation is based on the long-term performance of an investment in a Fund. In addition, if the rate of return of new profit (after all fees and expenses) earned by the Fund is less than the hurdle rate (which is the average U.S. Federal Funds rate for such year as reported in the Wall Street Journal) for such year, then Kore will not receive a performance allocation from such Client Account. Performance allocation arrangements create an incentive for Kore to recommend investments that may be riskier or more speculative than those which would be recommended under a different fee arrangement and favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. To mitigate these conflicts, the Firm’s policies and procedures seek to provide that investment decisions are based on the best interests of Client Accounts, without consideration of the Firm’s pecuniary interests. Kore has adopted a Trade Allocation Policy which is designed to allocate investments in a fair and equitable manner. KPS2, KPS4, and certain affiliated Managed Accounts do not pay a Performance Allocation.
Item 7. Types of clients
Kore provides discretionary and non-discretionary investment advice to the Funds and Managed Accounts. Interests in the Funds, and the Funds themselves, are not registered under the Securities Act of 1933, as amended (the “Securities Act”), and are exempt from the definition of an “investment company” under Section 3(c)(7) of the Investment Company Act of 1940, as amended (the “Investment Company Act”). Accordingly, interests in the Funds are
offered exclusively to investors who meet the requirements of an “accredited investor” under Regulation D of the Securities Act and a “qualified purchaser” under the Investment Company Act.
Item 8. Methods of analysis, investment strategies and risk of loss
Methods of Analysis and Investment Strategies Kore employs multiple strategies and methods in managing assets for Client Accounts and may implement additional strategies or variations of existing strategies without prior notice to investors. These descriptions are illustrative and do not limit Kore’s investment activities. All strategies carry a risk of loss, including the possible loss of all invested capital. Certain risks are inherent in, or more likely to affect, particular strategies or transactions, while other risks relate to the markets in which Kore trades or the instruments that are traded. Market risk is inherent in all securities investments, and additional or modified strategies may involve greater risk.
Read the rest of Item 8 (5,985 more words)
There can be no assurance that the investment objective of any Client Account will be achieved. There is no guarantee or representation that Kore’s investment strategy, including, without limitation, its investment objectives, diversification, or risk monitoring process, will be successful over time. Investments in the Funds are speculative and involve a high degree of risk. Certain risks are difficult to predict, monitor, or control, particularly during periods of market stress. Kore cannot guarantee that any assumptions relied upon herein will prove true in future events or that all relevant assumptions have been considered or stated. Kore’s proprietary investment strategy seeks to achieve capital appreciation with minimum volatility and preservation of capital. Kore may invest and trade in a broad and essentially unrestricted range of financial instruments, including, but not limited to, U.S. and non-U.S. government, agency, and corporate debt securities (public and private); U.S. and non-U.S. equity securities (including publicly and privately offered common stock, preferred stock, and convertible securities); mortgage and asset-backed securities; foreign currencies; commodities; futures; repurchase and reverse repurchase agreements; interest rate, bond, currency, equity, credit default, and commodity swaps, floors, and caps; digital assets (as defined below); collateralized debt and loan obligations; loans, including loans originated by Kore affiliates; leases, including leases originated by the Funds; derivatives, rights, and options on any of the foregoing and other investments, assets, property, or ventures selected by Kore. Kore may also target undervalued and distressed investments, such as: (i) out-of-favor sectors in which Kore can acquire investments at a significant discount to the fundamental value of their underlying cash flow or assets; (ii) companies undergoing, or considered likely to undergo, reorganizations under U.S. or non-U.S. bankruptcy laws; (iii) companies initiating debt restructurings, reorganizations, or liquidations outside of bankruptcy; and (iv) companies facing a broad range of liquidity issues. In certain circumstances, Kore may take “outright” directional market positions based on fundamental, quantitative, and statistical analysis. Valuation models may be useful in identifying or exploiting directional investment opportunities. Kore may utilize considerable leverage in making certain investments and may do so to a considerable extent. Leverage is obtained through borrowings from banks and other lenders, futures, forwards, swaps, and other derivatives, repurchase and reverse repurchase agreements, total return swaps, options, and margin trading in securities and derivatives. The amount of leverage used in any particular trade will vary based on the strategy employed and the availability of financing, and Kore does not maintain an internal limit on the amount of leverage it may employ.
Kore employs a proprietary risk metric, the “Kore Adverse Move Methodology,” incorporating qualitative and quantitative analysis, including fundamental and statistical inputs, to monitor risk. This framework evaluates risk exposures but does not limit potential losses or guarantee risk levels will remain within any specified range. General Risks The following summarizes certain material risks associated with Kore’s investment strategies and the types of securities in which Kore typically invests. The information below does not include every potential risk associated with each investment strategy or security. Investors and prospective investors are urged to ask questions regarding risk factors applicable to a particular investment strategy or security, read all the comprehensive risk disclosures set forth in the relevant Fund documentation, and determine whether a particular strategy or type of security is suitable in light of their investment objectives, financial circumstances, and risk tolerance. Risks Relating to Investment Strategies and Methods of Analysis General Trading Risks The Funds may trade a wide range of financial instruments including U.S. and non-U.S. government securities, corporate debt and equity securities, mortgage- and asset-backed securities, commodity and financial futures, options, rate caps, rate swaps; collateralized debt and loan obligations; and loans, including loans originated by affiliates of the Firm. Trading these instruments involves substantial risk. There are also substantial risks involved in borrowing and lending against such investments. The prices of these investments are volatile, market movements are difficult to predict, and financing sources and related interest and exchange rates are subject to rapid change. Adverse movements in any market in which the Funds hold positions can result in substantial losses. Government actions, regulatory changes, political developments, and other unforeseeable events can also produce sudden and significant market disruptions. Market Disruptions; Governmental Intervention The global financial markets have in recent years gone through pervasive and fundamental disruptions that have led to extensive and unprecedented governmental intervention. Such intervention has in certain cases been implemented on an “emergency” basis, suddenly and substantially eliminating market participants’ abilities to continue to implement certain strategies or manage the risk of their outstanding positions. In addition, these interventions have typically been unclear in scope and application, resulting in confusion and uncertainty which in itself has been materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. Major losses may be incurred during disrupted markets and other extraordinary events in which historical pricing relationships become materially distorted. The risk of loss from pricing distortions is compounded by the fact that, in disrupted markets, many positions become illiquid, making it difficult or impossible to close out positions against which the markets are moving. The financing available to the Firm from banks, dealers, and other counterparties is typically reduced in disrupted markets. Such reductions may result in substantial losses. Market disruptions can from time to time cause dramatic losses and can cause otherwise historically low-risk strategies to experience unprecedented volatility and risk. Financing Arrangements Certain investment strategies utilized by the Firm may involve substantial leverage. As a general matter, the banks and dealers that provide financing typically apply essentially
discretionary margin, haircut, financing, and security and collateral valuation policies. Changes in those policies may result in large margin calls, loss of financing, and forced liquidations at disadvantageous prices. In addition, dealers generally have broad discretion to close out credit lines. There can be no assurance that the Firm will be able to maintain adequate financing, particularly in adverse market conditions, such as those that occurred during 2008-2009. If the Firm is unable to do so, forced portfolio liquidations and significant losses could result. Diminished Liquidity in Certain Positions Adverse market conditions can lead to a “liquidity crisis,” i.e., the inability to sell most fixedincome securities (other than U.S. Treasuries) at expected prices. In both 1998 and 2008-2009, this inability to sell (which occurred generally in the market) led, in certain cases, to the inability of hedge fund managers to meet margin calls and fund redemptions that, in turn, led to the collapse of certain portfolios as dealers cut credit lines and investors withdrew capital, further reducing the creditworthiness of the owner of the portfolio. There can be no assurance that future market conditions will not result in similar liquidity crises. Substantial Leverage Certain futures contracts and over-the-counter derivatives are traded on margin, which typically ranges from less than 1% to 10% of contract notional and averages less than 5%. Furthermore, through repurchase arrangements, swaps, direct bank borrowings, margin trading, financing conduits, and government programs, and subject to the availability of financing, the Firm may be able to achieve a moderate degree of leverage on its cash securities positions. There is no internal limit on the amount of leverage that may be utilized by the Funds. The greater the leverage utilized, the more likely it is that a substantial change, whether upward or downward, will occur in the value of the interests. The Funds may incur major losses if market events disrupt the structured nature of their positions or if positions must be liquidated at a disadvantageous time. In addition, the credit extended to the Funds by dealers to maintain leveraged positions can be terminated largely in the dealers’ discretion, forcing liquidation at potentially material losses. Concentration The Funds are not subject to any concentration or diversification restrictions and may hold a limited number of investment positions. The undiversified nature of the Funds’ trading may result in increased risk of loss. No Limitation of Trading Strategies The Firm has broad discretion to utilize trading strategies it deems appropriate to pursue market opportunities. Given the broad range of strategies available to the Firm, it is not possible to precisely describe the risks associated with all such strategies. Volatility Instruments traded by the Firm have experienced periods of volatility in the past and are likely to experience them again. Price movements are affected by many unpredictable factors, including market sentiment, inflation, interest rate movements, and general economic and political conditions. While volatility can create profit opportunities for the Funds, it can also disrupt historical or theoretical pricing relationships, causing positions that otherwise appear comparatively low risk to incur losses. Conversely, a lack of volatility can also result in losses for certain strategies that seek to profit from price movements.
Interest Rate Risk The Funds are subject to interest rate risk. Generally, the value of fixed-income securities changes inversely with changes in interest rates. As interest rates rise, the market value of fixed-income securities tends to fall. Conversely, as interest rates fall, the market value of fixed-income securities tends to rise. This risk is generally greater for long-term securities than for short-term securities. Illiquid Securities A portion of the Funds’ portfolio may consist of securities and other financial instruments that are not actively and widely traded. As a result, it may be relatively difficult for the Funds to dispose of such investments rapidly and at favorable prices in response to withdrawal requests, adverse market developments, or other factors. Illiquid securities are often more difficult to value. Spread Trading Risks The Funds’ trading operations may involve spreads between two or more positions. To the extent the price relationships between such positions remain constant, no gain or loss on the positions will occur. Such positions do, however, entail a substantial risk that the price differential could change unfavorably, causing a loss to the spread position. In periods of trendless, stagnant markets or deflation, many alternative investment strategies have materially diminished prospects for profitability. Arbitrage Trading Kore’s trading operations may involve arbitrage between the cash and derivatives markets in financial instruments. This means that the Funds purchase (or sell) financial instruments in cash markets (i.e., on a current basis) and take offsetting positions in the futures or other derivatives markets in the same or related financial instruments. These offsetting positions are subject to the same risk of adverse price differentials outlined under “Spread Trading Risks” above. In addition, because many cash market contracts are not traded on exchanges, but rather through a network of banks and dealers, such contracts may be less liquid. No limitations on price movement are imposed upon such banks and dealers, which means that an otherwise balanced position might suffer significant short-term losses since price movements on the cash leg of the arbitrage position are not limited. Furthermore, an increase in value in one leg of a trade may not be available to the trader at the same time as a margin or collateral payment is due with respect to a decrease in value in the other leg of the trade. This imbalance in cash utilization (even where the arbitrage as a whole may be profitable) may require premature termination of the position unless the trader has sufficient cash reserves to maintain the combined position. Dealers may also require margin on arbitrage positions at levels that make it impracticable for the Funds to maintain those positions, forcing liquidation at potentially disadvantageous prices. Model Risk Certain Firm strategies rely on quantitative valuation models. Changes in market dynamics, market conditions, or market participants can cause a model that previously performed well to become outdated or inaccurate, potentially before the Firm detects the issue and before substantial losses occur. There can be no assurance that the Firm will successfully develop and maintain effective quantitative models. Operational Risk
Kore’s strategies are highly dependent on information systems and technology. Any failure or deterioration of these systems or technology due to human error, data transmission failures, or other causes could materially disrupt Kore’s operations. A disaster or disruption in the infrastructure supporting the Firm’s business, including a disruption involving electronic communications or other services used by the Firm or its counterparties and service providers, may impair Kore’s ability to continue operating without interruption. Although the Firm and its affiliates maintain backup facilities, technology safeguards, and business continuity programs, there can be no assurance that these measures will be sufficient to mitigate the harm that may result from such a disaster or infrastructure disruption. Holding Period of Investment Positions The Funds’ transactions involve acquiring related positions in a variety of different instruments or markets at or about the same time. Frequently, optimizing the probability of being able to exploit the pricing anomalies among these positions requires holding periods of significant length, often many months to a year or more. Actual holding periods depend on numerous market factors which can both expedite and disrupt price convergences. There can be no assurance that the Fund will be able to maintain any particular position, or group of related positions, for the duration required to realize the expected gains, or avoid losses, from such positions. Non-U.S. Securities A substantial portion of the Funds’ trading may involve the purchase of non-U.S. securities. Securities of some non-U.S. issuers are less liquid and more volatile than comparable U.S. securities. Similarly, trading volume and liquidity in many non-U.S. securities markets are lower than in the United States and, at times, price volatility is greater. Because stock certificates and other evidences of ownership of such securities may be held outside the United States, the Funds may be subject to additional risks, including adverse political and economic developments, seizure or nationalization of non-U.S. deposits, and the adoption of governmental restrictions that could adversely affect the payment of principal and interest on such securities or restrict those payments to investors located outside the issuer’s country, whether due to currency blockage or otherwise. The value of foreign securities may also be affected by changes in currency rates. High-Yield Securities In connection with structured transactions in which the Funds seek to hedge issuer credit risk, the Funds may invest in high yield bonds and preferred securities rated in the lower rating categories by the major credit rating agencies, as well as comparable non-rated securities. Securities in the lower rating categories are subject to greater risk of loss of principal and interest than higher-rated securities and generally are considered predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal. They are also generally subject to greater risk than higher-rated securities during periods of deteriorating economic conditions. Because investors generally perceive greater risks in lower-rated securities, the yields and prices of those securities tend to fluctuate more than those of higher-rated securities. The market for lower-rated securities is thinner and less active than the market for higher-rated securities, which can adversely affect the prices at which those securities can be sold. In addition, adverse publicity and investor perceptions regarding lower-rated securities, whether or not based on fundamental analysis, may contribute to declines in the value and liquidity of those securities. Loans
The Funds may engage in primary and secondary market trading in loans. Many of these loans may be privately negotiated transactions with individualized terms and may be illiquid and difficult to value. In the course of this trading, the Firm may come into possession of material non-public information relating to a borrower, which can restrict the Funds from trading in securities of that issuer. Loans may be subject to price volatility due to changes in interest rates, market perceptions of the borrower’s creditworthiness, and overall market liquidity. The Funds may invest in loans to distressed borrowers, which typically involve greater market fluctuations and heightened risks of loss of income and principal. Loans also involve fundamental credit risk based on the borrower’s ability to make principal and interest payments. The Funds may also invest in loan participations, which exposes them to additional risk because they generally have no direct contractual relationship with the underlying borrower. In those cases, the Funds depend on the lender to enforce rights and obligations under the loan documentation in the event of a borrower default and generally do not have voting rights with respect to the issuer. They are also exposed to the credit risk of the lender (as well as the borrower) because payment depends upon the lender’s forwarding principal and interest payments received on the underlying loan. If the lender defaults on its obligations under such arrangements, the Funds can incur substantial losses. Currency Risks and Hedging Since certain securities in which the Funds invest are valued in non-U.S. currencies, the Funds are subject to the risk of fluctuations in the exchange rate between the local currency and U.S. Dollars. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term investment and capital appreciation opportunities, and political developments. Accordingly, the Funds may, in part, seek to offset these risks through non-U.S. exchange transactions. The markets in which non-U.S. exchange transactions are effected are highly volatile, specialized, and technical. Significant changes, including changes in liquidity and prices, can occur in these markets within very short periods of time, often within minutes. NonU.S. exchange trading risks include, but are not limited to, exchange rate risk, interest rate risk, and potential interference by non-U.S. governments through regulation of local exchange markets, non-U.S. investment, or particular transactions in a non-U.S. currency. Any currency hedge used to protect against currency losses will also limit gains from favorable currency movements. There can be no assurance that a currency hedge will be successful at accomplishing this purpose or will not itself generate significant losses. Furthermore, to the extent that any currency hedging strategy involves over-the-counter derivatives transactions entered into in the U.S. (and, in certain circumstances, outside the U.S.), such a strategy would be affected by implementation of the various regulations adopted pursuant to Dodd-Frank.
Custody and Counterparty Risk Institutions such as brokerage firms, banks, and broker-dealers generally have custody of the Funds’ portfolio assets and may hold such assets in street name. The Funds are subject to the risk that these firms and other brokers, counterparties, clearinghouses, and exchanges with which the Funds transact may default on their obligations to the Funds. Any such default could result in material losses to the Funds. Bankruptcy or fraud at one of these institutions can also impair the Funds’ operational capabilities or capital position. In addition, securities and other assets deposited with custodians or brokers may not be clearly identified as assets of the Funds, which can expose the Funds to credit risk with regard to those parties. The Funds generally will be unsecured creditors of their trading counterparties in the event of a bankruptcy or
administration involving those counterparties. In some jurisdictions, the Funds may also only be unsecured creditors of their brokers in the event of bankruptcy or administration involving those brokers. The Firm seeks to limit brokerage and custody relationships to well capitalized and established banks and brokerage firms in an effort to mitigate these risks, but this approach does not eliminate the risk of counterparty loss. The Funds may effect transactions in over-the-counter or interdealer markets. The participants in these markets typically are not subject to the same level of credit evaluation and regulatory oversight as participants in exchange-based markets. This exposes the Funds to the risk that a counterparty will fail to settle a transaction in accordance with its terms and conditions, whether because of a dispute over the terms of the contract (whether bona fide or not) or because of a credit or liquidity problem, thus causing the Funds to suffer a loss. Such counterparty risk is accentuated for contracts with longer maturities where intervening events may prevent settlement, or where the Funds have concentrated its transactions with a single or small group of counterparties. The Funds are not restricted from dealing with any particular counterparty or in the size of the exposure with which the Funds may provide to a given counterparty. The inability to make complete and “foolproof” evaluations of the financial capabilities of the Funds’ counterparties and the absence of a regulated market to facilitate settlement increases the risk to the Funds. Although Dodd-Frank was intended to bring more stability and reduce counterparty risk in the derivatives markets through mandatory clearing requirements, not all Fund transactions are subject to clearing requirements, including grandfathered trades and bespoke transactions. Furthermore, it is yet to be seen whether these requirements will be effective in reducing counterparty risk in all cases or if such risk may actually increase as a result of market uncertainty, mutualized loss-sharing among clearinghouse members, or other factors. General Economic Conditions The Funds’ trading investment strategies are subject to market risk and general economic conditions, including directional price movements, deviations from historical pricing relationships, changes in the regulatory environment, changes in market volatility, flights to quality, and credit squeezes. The Firm’s style of alternative investing may be no less speculative than traditional investment strategies. In addition, due in part to the degree of leverage the Funds may employ and the leverage embedded in the derivative instruments in which the Funds may invest, the Funds may from time to time incur sudden and dramatic losses. The particular or general types of market conditions in which the Funds may incur losses or experience unexpected performance volatility cannot be predicted, and the Funds may materially underperform other investment funds with substantially similar investment objectives and approaches.
Risks Associated with Cybersecurity The Firm’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, user error by its personnel, power outages, and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although the Firm has implemented various measures to manage these risks, if these systems are compromised, become inoperable for extended periods of time, or otherwise fail to function properly, the Firm may have to make significant investments to repair or replace them. The failure of these systems, or of disaster recovery plans, can cause significant operational
disruptions and can result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to clients, investors, and beneficial owners. Such a failure could harm the Firm’s reputation, subject the Firm or its affiliates to legal claims, and otherwise adversely affect their business and financial performance. Additionally, any failure of the Firm’s information, technology, or security systems can adversely affect its ability to manage the private investment funds referred to herein. Epidemic Risk An epidemic outbreak, and reactions to such an outbreak, could cause uncertainty in markets and businesses, including the Firm’s business, and may adversely affect the global economy, including by causing market volatility, market and business disruptions or closures, supplychain and travel interruptions, the need for employees and vendors to work remotely or from alternate locations, and widespread medical absences. Although the Firm has policies and procedures designed to address known situations, a large-scale epidemic can create significant market and business uncertainties and disruptions, and not all events affecting Kore’s business or the markets can be identified and addressed in advance. Force Majeure Portfolio investments may be affected by force majeure events, meaning events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of infectious disease, pandemics or other serious public health concerns, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, technology failures, defective design or construction, accidents, demographic changes, government macroeconomic policies, and social instability. Some force majeure events may impair a party’s ability to perform its obligations until the event is remedied. These risks could, among other effects, adversely affect the cash flows of companies in which the Firm invests, cause personal injury or loss of life, damage property, or disrupt service. In addition, the cost of repairing or replacing damaged assets resulting from a force majeure event could be considerable. Force majeure events that cannot be cured, or that are too costly to cure, may have a permanent adverse effect on investments held by Client Accounts. Certain force majeure events (such as war or an outbreak of infectious disease) could have a broader negative effect on the global economy and international business activity generally, including in countries in which the Firm invests. Risks Related to Specific Types of Investments Futures Trading; Speculative Position Limits Futures prices are highly volatile, and price movements are influenced by a multitude of factors such as supply and demand relationships, government trade, fiscal, monetary and exchange control policies, political and economic events, and emotions in the marketplace. Futures trading can also be highly leveraged. Further, futures trading may be illiquid because of daily limits on movements of prices. Finally, the Firm’s futures trading could be adversely affected by speculative position limits. Forward Contracts The Funds may trade deliverable forward contracts in the interbank currency market. Such contracts are not traded on exchanges; instead, banks and dealers act as principals in these markets. Changes in the regulation of forward and other foreign exchange markets may increase costs and impose additional reporting and compliance obligations. In addition, there is no limit on daily price movements in forward contracts. Participants in the forward markets have no obligation to continue making markets in the contracts traded by the Funds.
Governmental credit controls or other regulatory developments could limit forward trading below the level the Firm would otherwise recommend, which could adversely affect the Funds. Swaps and Other Derivatives The Funds may enter into swap and similar derivative transactions involving or relating to interest rates, credit risk, non-U.S. currencies, commodities, securities, investment fund interests, indices, prices, or other items. A swap transaction is an individually negotiated, nonstandardized agreement between two parties to exchange cash flows (and sometimes principal amounts) measured by reference to different interest rates, commodity prices, exchange rates, indices, or prices, with payments generally calculated by reference to a principal, or “notional,” amount or quantity. Swap contracts and similar derivative contracts are not traded on exchanges in significant volume; instead, banks and dealers act as principals in these markets. As a result, the Funds are subject to the risk that counterparties with which they transact will be unable or unwilling to perform their obligations under these contracts. Participants in the swap markets are not required to make continuous markets in the swap contracts they trade. Furthermore, regulations implemented pursuant to Dodd-Frank may increase costs and impose reporting requirements, position limits, and other regulatory burdens. These requirements can adversely affect the Funds’ ability to enter into swap contracts or make certain strategies impracticable or uneconomical to implement. Asset-Backed Securities The Funds may invest in asset-backed securities (“ABS”). ABS entitle holders to receive payments that depend primarily on the cash flow from a specified pool of financial assets, either fixed or revolving, that by their terms convert into cash within a finite time period if paid in accordance with their tenor, together with rights or other assets designed to ensure the servicing of the ABS or the timely distribution of proceeds to holders. Holders of ABS bear various risks, including credit risk, liquidity risk, interest-rate risk, market risk, operations risk, structural risk, and legal risk. Credit risk is a particularly important consideration because of the significant credit risks inherent in the underlying collateral and because issuers are primarily private entities. The structure of an ABS and the terms of the investors’ interest in the collateral can vary widely depending on the type of collateral, investor preferences, and the use of credit enhancements. Although the basic elements of ABS are similar, individual transactions can differ markedly in both structure and execution. Important determinants of the risks associated with issuing or holding ABS include the process by which principal and interest payments are allocated and distributed to investors, how credit losses affect the issuing vehicle and investor returns, whether the collateral consists of a fixed pool of specific assets or accounts, whether the underlying collateral is revolving or closed-end, the terms under which any remaining account balance may revert to the issuing entity, including the maturity of the ABS, and the extent to which the source of the collateral is obligated to support the issuing vehicle or investors.
Residential and Commercial Mortgage-Backed Securities Investments in residential and commercial mortgage-backed securities involve the risks typically associated with traditional fixed-income securities (including interest rate and credit risk) as well as prepayment risk and exposure to real estate. The rate of prepayments on underlying mortgages affects the price and volatility of a mortgage-backed security and may shorten or extend its effective maturity. Different types of mortgage-backed securities are subject to different degrees of prepayment risk. Residential mortgage-backed securities generally permit prepayment of principal at any time for various reasons, including prepayments on the underlying mortgage loans. As a result, the Funds may be required to
reinvest assets at an inopportune time and at a lower rate of return. The risks of investing in such instruments reflect the risks of the underlying obligors, as well as the real estate that secures the instruments. If the Funds purchase mortgage-backed or asset-backed securities that are subordinated to other interests in the same mortgage pool, the Funds generally, as a holder of those securities, may only receive payments after the pool’s obligations to more senior investors have been satisfied. An unexpectedly high rate of defaults on the mortgages in a mortgage pool may substantially limit the pool’s ability to make principal or interest payments on subordinated securities, reducing their value and, in some cases, rendering them worthless. This default risk is generally higher for mortgage pools that include sub-prime mortgages. An unexpectedly high or low rate of prepayments on a pool’s underlying mortgages may have a similar effect on subordinated securities. A mortgage pool may issue securities with multiple levels of subordination, and although nonpayment risk affects each level, that risk is greater for more highly subordinated securities. Short Sales The Funds may engage in short selling. A short sale involves the sale of a security that a Fund does not own in anticipation of purchasing the same security (or a security exchangeable for it) at a later date at a lower price. To make delivery to the buyer, the Fund must borrow the security and later return it to the lender by purchasing the security in the market. A Fund realizes a profit or loss on a short sale depending on whether the price of the security decreases or increases between the date of the short sale and the date on which the Fund covers its short position. A short sale involves theoretically unlimited risk because the market price can rise without limit, resulting in potentially unlimited losses. In addition, the securities necessary to cover a short position might not be available for purchase when needed. Trading on Non-U.S. Markets A significant portion of the Funds’ trading operations may involve trading on markets outside the United States. Trading on those markets is not regulated by any U.S. government agency. Some non-U.S. markets, unlike U.S. exchanges, operate as principals’ markets, in which performance is the responsibility solely of the individual member with whom the trader has entered into a contract, rather than an exchange or clearing corporation. In a number of foreign markets, a substantial volume of trades that, in the United States, could only be executed on a regulated exchange are executed off-exchange in privately negotiated and substantially unregulated transactions. In some cases, the intermediaries through which the Funds transact on foreign markets can take the opposite side of trades made executed for the Funds while also acting as the Funds’ agent, a practice that would be prohibited in the United States. The Funds may not have the same access to certain trades as do various other participants in foreign markets. Furthermore, since the Funds determine their respective net assets in U.S. dollars, they are subject to exchange-risk between local currencies and the U.S. dollar, as well as the risk of exchange controls, in connection with foreign trading. Emerging Market Investing The Funds may invest a portion of their respective assets in government and corporate debt securities and other instruments in emerging markets. The value of emerging market debt instruments may be affected significantly by political developments in the country of issuance. In addition, the existing governments in the relevant countries could take actions that adversely impact the Funds, including nationalization, expropriation, imposition of confiscatory taxation or regulation, or imposition of withholding taxes on interest payments. The economies of many of the emerging market countries are still in the early stages of modern development and are subject to abrupt and unexpected change. In many cases, governments retain a high degree of
direct control over the economy and may take actions that have sudden and widespread effects. Also, many emerging market economies have a high dependence on a small group of markets or even a single market. Emerging market countries tend to have periods of high inflation and high interest rates as well as substantial volatility in interest rates. The value of emerging market debt can be expected to be extremely sensitive to changes in interest rates worldwide and, in particular, the country of the relevant issuer. Emerging market debt issuers and their respective obligations are not generally rated by any credit rating agency, and a significant proportion of such issuers and obligations would likely fall in the lowest rating category if they were rated. In certain cases, the structures used to make trades in emerging market securities may be complex, entail significant counterparty exposure, and involve legal uncertainty under local law. Risks Related to Digital Assets Kore may consider investment opportunities involving digital assets or digital asset–related instruments. “Digital assets” generally refers to assets issued and/or transferred using distributed-ledger or blockchain technology, including virtual currencies (cryptocurrencies), coins, and tokens. The Funds can obtain exposure to digital assets through direct investment in digital coins, tokens, or currencies, or indirectly through vehicles such as exchange traded funds (ETFs), SMAs, structured products, and/or derivatives. Digital assets are relatively new, highly speculative investments that differ from traditional securities, currencies, and commodities. They are not backed by a central bank or other traditional credit support, and their value is largely determined by supply and demand, adoption, market sentiment, and the value ascribed by market participants. Investment in digital assets involves significant risks, including extreme price volatility, limited liquidity, potential market manipulation, regulatory and tax uncertainty, technology and cybersecurity vulnerabilities, and the absence of traditional investor protections. The value of digital assets can fluctuate rapidly and significantly, resulting in substantial losses, and losses resulting from fraud, theft, hacking, or operational failures involving counterparties, custodians, or other third-party service providers may be irreversible or difficult to recover. Digital assets and the systems and networks on which they operate may be subject to technical failures, cyber-attacks, and other operational vulnerabilities, which can adversely affect the Funds’ positions, pricing, liquidity, or ability to transact. In addition, the legal and regulatory landscape for digital assets remains evolving and uncertain across jurisdictions, which could impact the Funds’ ability to invest in, trade, value, or hold digital assets and could adversely affect the value of such investments. To the extent the Funds hold digital assets, those assets will be held with specialized asset custodians, wallet providers, or other service providers. Qualified custodians are not available for all digital assets, and certain service providers are not subject to the same regulatory framework, insurance arrangements, or internal controls as traditional custodians. As a result, the Funds’ digital assets can be subject to an increased risk of loss, theft, inaccessibility, or delay in transfer or recovery in the event of cyber-attacks, loss or compromise of private keys, technology failures, operational errors, insolvency, or other failures of a custodian or service provider.
Item 9. Disciplinary information
Kore 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 any such actions.
Item 10. Other financial industry activities and affiliations
Kore is registered as a commodity pool operator with the CFTC and is a member of the NFA. J. Gary Kosinski, Kore Management, and Koz are listed as Principals and J. Gary Kosinski is registered as an Associated Person of the Firm with the NFA. Kore Capital LLC, an affiliate of the Firm that is under common control with the Firm, acts as general partner to the Kore Onshore Fund and has delegated its commodity pool operator responsibilities with respect to the Kore Onshore Fund to the Firm. As general partner of Kore Onshore Fund, Kore Capital LLC receives a performance allocation as described in Item 5, “Fees and Compensation.” Kore and its employees do not have any relationships or arrangements with other financial services companies that pose material conflicts of interest.
Item 11. Code of ethics, participation in client transactions and personal trading
Trading Code of Ethics and Personal Trading Kore has adopted policies and procedures relating to, among other things, portfolio management and trading practices, personal investment transactions, and insider trading that are designed to prevent, identify, and address conflicts of interest. Kore’s policies and procedures, including its Code of Ethics (“Code”) and Employee Investment Policy (“EIP”), apply to all employees and are intended to mitigate potential conflicts of interest involving Clients. The Code and EIP govern the personal investment activities of all employees and their immediate family members, which generally includes persons sharing the same household as the employee.
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Although the Code permits supervised persons to trade in securities for their own accounts, it includes preclearance procedures, reporting requirements, and other provisions designed to restrict and monitor employee trading. All employees are required to disclose their personal securities accounts upon commencement of employment at Kore and must submit duplicate copies of account statements for all covered investment accounts. Kore also conducts an active monitoring program for personal trading. Any employee who violates the Code or EIP may be subject to remedial actions. Kore’s Code limits the giving and receiving of certain meals, gifts, and entertainment by employees. Kore employees occasionally receive, participate in, or provide entertainment for legitimate business purposes, subject to applicable law and limitations set forth in the Firm’s policies. The Code also contains disclosure and preclearance procedures relating to outside business activities and private securities transactions. Kore’s Code and EIP are available to Clients and qualified prospective investors upon request by contacting Kore’s Chief Compliance Officer. Participation or Interest in Client Transactions Employees and affiliates of the Firm may hold financial interests in the Funds, either directly or through the Funds’ general partner. Additionally, Kore employees may invest personally in securities or other investments that are also held in Client Accounts, or in investments that are later purchased for Client Accounts. Such personal investments are subject to preclearance to assess and address any actual or potential conflicts presented by the employee’s proposed ownership. Kore may or may not receive compensation in connection with employee investments. To the extent employees or affiliates invest in the Funds, they have a direct financial interest in the success of the Funds’ investment strategy. Kore’s Code and EIP contain policies and procedures designed to identify, mitigate, and monitor these actual or potential conflicts.
Item 12. Brokerage practices
Best Execution Kore has a fiduciary duty to use reasonable efforts to obtain best execution of securities transactions for its Client Accounts. This means that in selecting broker-dealers to execute transactions, the Firm must attempt to ensure that the total cost or proceeds of any transaction is the most favorable under the circumstances. However, the Firm does not need to necessarily solicit competitive bids on each transaction and may not have an obligation to seek the lowest possible cost. In selecting brokers for execution, Kore may consider the full range and quality of a broker-dealer’s services.
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The factors to be considered in selecting and approving brokerdealers include, but are not limited to, overall costs of a trade (i.e., net price paid or received); quality of execution; reputation, financial strength, and stability; block trading and block positioning capabilities; willingness and ability to commit capital; access to underwritten offerings and secondary markets; ongoing reliability; fairness in resolving disputes; and confidentiality of trading activity. In addition, a broker may, in certain cases, have greater expertise or greater capability in connection with both accessing the market and executing a transaction. Kore periodically reviews its relationships with broker-dealers and the effectiveness of its efforts to obtain best price and execution. Trade Aggregation Kore will generally execute Client transactions on an aggregated or batch basis when it believes that aggregation will enable it to negotiate more favorable commission rates or other transaction costs. Clients may pay higher commissions or mark-ups as a result if aggregation of trading is not utilized or available in such situations. To obtain best execution, Kore usually makes a single purchase and then allocates the purchased securities among Client Accounts. Modification of Pro Rata Allocations Kore attempts to allocate trades on a pro rata basis but considers the following factors prior to allocating a trade: 1) strategy mandate; 2) availability of capital; 3) Client specific needs; 4) need to bring Client Account to desired exposure level or portfolio rebalancing; 5) trade size; and 6) counterparty considerations. In analyzing these factors, there may be certain situations when trades may not be allocated on a pro rata basis. Trade Errors Kore may on occasion experience errors with respect to Client transactions. Trade errors are an intrinsic risk in any investment process and will occur from time to time. The Firm has trade policies and procedures designed to reduce the possibility of error. The Firm’s general policy is to identify and correct any trade errors promptly and in the best interest of the affected Client. It is the Firm’s general policy that, absent a violation of the applicable standard of care, all benefits and burdens of a trade error will be borne by the Client. Soft Dollars Kore currently does not use “soft dollars.” If the Firm does establish such arrangements in the future, it intends to remain within the safe harbor parameters of Section 28(e) of the Securities Exchange Act of 1934, as amended. Cross Trades
Kore may, from time to time and subject to applicable client investment guidelines and restrictions, direct one client to sell securities to another client (or among the Funds) through an internal cross trade. Cross trades may be executed with the assistance of a broker. Kore does not charge additional fees to its Clients in connection with the completion of a cross trade. In certain cases, cross trades may be viewed as principal trades due to certain ownership interests. Cross trades create conflicts of interest between Clients. For example, one client could be advantaged to the detriment of another if the securities exchanged are not priced at fair value, and an investment adviser could misuse its authority to transfer undesirable securities from one client to another. With respect to cross trades, Kore will comply with the requirements of Section 206(3) of the Advisers Act and its internal policies and procedures. Kore will confirm, among other things: (1) that the trade is permitted by the applicable investment guidelines; (2) that Kore’s valuation procedures are followed when pricing the transaction, including obtaining a third-party valuation when appropriate; and (3) that notice of the specific trade was provided to the affected Clients and that written consent was obtained.
Item 13. Review of accounts
The Firm actively manages Client Accounts. The Firm’s Portfolio Managers review Client Account positions and transactions on a daily basis. In addition, the third-party administrator (“Administrator”) for Kore Fund, Kore Onshore Fund, and Kore Offshore Fund provides daily reviews and reconciliations of cash, positions, and activity to prime brokers to validate that all transactions were executed as initiated and accounted for in a proper manner. Kore Fund, Kore Onshore Fund, and Kore Offshore Fund investors are provided with monthly unaudited capital account statements and investors in each of the Funds receive audited financial statements annually.
Item 14. Client referrals and other compensation
Kore may enter into arrangements pursuant to which it compensates third parties for client referrals. In accordance, third-party solicitors may receive a portion of the fees otherwise payable to Kore. Referral fees are paid out of existing management and performance allocation fees and do not represent an additional cost or expense to clients.
Item 15. Custody
As a result of J. Gary Kosinski’s control of the general partner of the Kore Onshore Fund and his influence over the management of Kore Fund, the Firm is deemed to have custody of the assets in the Funds under Rule 206(4)-2 of the Advisers Act (“Custody Rule”), although the Firm does not physically hold the securities and other assets. To comply with the Custody Rule, the securities and other assets of the Funds are held by qualified custodians and audited financial statements are distributed to each investor within 120 days of the respective Funds’ fiscal year end. Investors should carefully review the audited financial statements of the respective Fund upon receipt. The Firm is also deemed to have custody of the assets in certain Managed Accounts pursuant to the applicable investment management agreement.
Item 16. Investment discretion
Kore has full discretionary authority to manage the Funds, including authority to determine, without obtaining specific client consent, the securities to be bought or sold, the amount of securities to be bought or sold, the broker-dealer to be used, and the commission rates to be paid. This authority is granted under the applicable investment advisory agreement between
Kore and the Funds, and any limitations are set forth in those agreements and the related Fund offering documents. Kore’s authority to manage the Managed Accounts is granted through the applicable investment management agreement and may be either discretionary or non-discretionary. Investors should review the investment management agreement with respect to the particular Managed Account.
Item 17. Voting client securities
While Kore infrequently receives proxies to vote due to the nature of the investment instruments that are traded, the Firm has established proxy voting policies and procedures designed to ensure that proxies are voted in the Client’s best interest. The Firm will analyze proxies on a case-by-case basis. Kore will generally abstain from voting a proxy or a specific proxy item when it is deemed not in the Client’s best interest to vote or if there is a potential conflict of interest. Kore does not solicit or accept voting recommendations from its Clients. Clients and investors may request a copy of Kore’s proxy voting policies, procedures, and prior voting history.
Item 18. Financial information
This section is not applicable to the Firm.
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.