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Kudu Investment Holdings, LLC: investment adviser

Kudu Investment Holdings, LLC is an investment adviser registered with the SEC (file 801-80974, CRD 174350). 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
$1.4B
Discretionary
0%
Accounts
1
Employees
18
In advisory roles
7
Disclosures
1

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 typeClientsAssetsShare
Private funds and other pooled vehicles1$1.4B100.0%

How it is paid

  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)

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)

OwnerTypeRoleStakeSinceControlPublic company
Kudu Investment Management LLCCompany (U.S.)Parent companyE 75% or moreDec 2019Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
White Mountains InsuranceWM HinsonCompany (outside the U.S.)E 75% or moreYesYes
WM Hinson (Bermuda) Ltd.WMCompany (outside the U.S.)E 75% or moreYes
WM International Holdings Ltd.WM Regent Ltd.Company (outside the U.S.)E 75% or moreYes

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

What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?

Actions about the firm (1)

  1. Dec 13, 2024
    Regulatory Action: SEC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist censure · Fine: $125,000 · Begun Dec 13, 2024 · Resolved Dec 13, 2024 · Order · Docket FILE NO. 3-22351

    This matter involves Kudu Investment Holdings, LLC's ("KIH") violations of the reporting provisions of rule 204(b)-1 under the Investment Advisers Act of 1940 (the "Advisers Act"), which requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on form PF to provide information about the private funds they manage. Pursuant to an order entered by the U.S. Securities and Exchange Commission (the "commission") on December 13, 2024 against KIH, the commission found that, from 2019 through 2023, KIH was subject to the reporting requirements of rule 204(b)-1, but failed to file or update a report on form PF.

    Kih was ordered to pay a civil money penalty of $125,000, which was paid on December 13, 2024.

    On December 13, 2024, the commission entered an order instituting administrative and cease-and-desist proceedings against kih. Pursuant to the order, the commission found that, from 2019 through 2023, kih was subject to the reporting requirements of rule 204(b)-1 under the Advisers Act, but failed to file or update a report on form PF. The order recognized the cooperation afforded the commission staff by kih. Kih submitted an offer of settlement without admitting or denying the findings in the order and agreed to: (I) cease and desist from committing or causing any violations and any future violations of rule 204(b)-1 under the Advisers Act, (II) a censure and (III) pay a civil money penalty of $125,000. No information Filed

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.

The brochure

No brochure text was read for this firm.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.