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Apogem Capital LLC: investment adviser
Apogem Capital LLC is an investment adviser registered with the SEC (file 801-118844, CRD 309234). 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
- $43.8B
- Discretionary
- 94%
- Accounts
- 144
- Employees
- 259
- In advisory roles
- 127
- Disclosures
- 8
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 |
|---|---|---|---|
| High net worth individuals | 1 | $13.4M | 0.0% |
| Registered funds | 1 | – | – |
| Private funds and other pooled vehicles | 137 | $23.5B | 53.6% |
| Charities | 1 | $174.9M | 0.4% |
| Insurance companies | 3 | $8.2B | 18.7% |
| Corporations | 1 | $12.0B | 27.3% |
How it is paid
- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees
Services
- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940)
- 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)
- Selection of other advisers (including private fund managers)
- Other: PROVIDE INVESTMENT SUPERVISORY SERVICES
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 |
|---|---|---|---|---|---|---|
| New York Life Investment | Company (U.S.) | Sole member/direct & | E 75% or more | May 2020 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| New York Life Insurance | New York Life Holdings LLC | Company (U.S.) | E 75% or more | 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
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 made a false statement or omission?
- 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?
- Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
- Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
- (1) Has any domestic or foreign court: ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
Actions about affiliates (7)
- Feb 25, 2026Regulatory Action: SEC FinalAbout an affiliate: Madison Capital FundingSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist censure · Fine: $900,000 · Begun Feb 25, 2026 · Resolved Feb 25, 2026 · Order · Docket 3-22599
The SEC found that between March 2020 and May 2020, when the coronavirus pandemic disrupted the U.S. financial markets, Madison Capital Funding LLC ("Madison capital"), a predecessor firm to Apogem Capital, did not price principal trades made with funds it advised at fair market value, contrary to its representations to investors. Without admitting or denying the SEC's findings, Madison capital agreed to pay a civil money penalty in the amount of $900,000 and consented to a cease and desist order that included a censure.
Madison capital was ordered to pay a civil money penalty in the amount of $900,000, which will be paid by March 11, 2026.
On February 25, 2026, Madison capital, without admitting or denying the SEC's findings, consented to the entry of an administrative order by the SEC finding that Madison capital violated sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-8 thereunder.
- Aug 7, 2025Regulatory Action: State of Connecticut Insurance Department FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $14,000 · Begun Aug 7, 2025 · Resolved Aug 7, 2025 · Stipulation and Consent · Docket MC 25-65; MC 25-82
New York Life Insurance company ("NYLIC") paid a $2,000 fine for failing to pay claims and interest on claims in a timely manner, in violation of Connecticut statutory requirements. New York Life Insurance and annuity corporation ("NYLIAC") paid a $12,000 fine for permitting eight (8) producers to act as agents in Connecticut without the required appointment. Both matters were resolved via stipulation and consent orders dated August 7, 2025, and no formal hearings were held.
On 8/7/2025 nylic paid a $2,000 fine; nyliac paid a $12,000 fine.
Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance company was found to have violated section 38A-816 of the Connecticut general statutes and New York Life Insurance and annuity corporation was found to have violated section 38A-702M of the Connecticut general statutes.
- Dec 16, 2023Regulatory Action: Louisiana Department of Insurance FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $100,000 · Begun Dec 16, 2023 · Resolved Dec 16, 2023 · Order
Nylic failed to use policy forms that were reviewed and approved by the state. In addition, certain forms did not comply with state regulations.
Nylic agreed to a consent order from the state and paid a fine of $100,000 related to use of forms in the state which were not approved by or did not comply with state regulations. In addition to paying the fine of $100,000 on 12/22/2023, nylic is also amending forms and agreement and resubmitting them to the state to comply with the appropriate regulations.
- Oct 20, 2021Regulatory Action: Kentucky Department of Insurance FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $112,000 · Begun Oct 4, 2021 · Resolved Oct 20, 2021 · Order · Docket 2021SCM066
On October 4, 2021 New York Life Insurance company ("NYLIC") received an order of civil penalty and adoption of a corrective action plan from the Kentucky Department of Insurance alleging that NYLIC incorrectly implemented premium rate increases on 112 individual long term care contracts in violation of Kentucky insurance law.
Nylic paid a $56,000 fine on October 20, 2021 in accordance with the order which stipulates 50% of the penalty to be held in abeyance and subject to dismissal following (1) execution and satisfaction of the corrective action plan, and (2) correct implementation of the rate increase.
Monetary fine: $112,000
- Mar 23, 2021Regulatory Action: Office of the Montana State Auditor, Commission of Securities and Finance FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10,000 · Begun Mar 23, 2021 · Resolved Mar 23, 2021 · Stipulation and Consent · Docket INS 2018-275
The office of the Montana state auditor, commission of securities and insurance ("CSI") found that since 2015 New York Life Insurance company and New York Life Insurance and annuity corporation (collectively, "nyl") used group life insurance and group annuity forms that had not been approved by the CSI, provided coverage under such forms to Montana residents and did not submit the forms for approval as required under Montana law.
On March 30, 2021, nyl paid the administrative penalty of $10,000 in full.
The March 23, 2021 consent agreement resolves the allegations against nyl and was entered without adjudication of any issue, law or fact.
- Jan 24, 2018Regulatory Action: State of Connecticut Insurance Department FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,000 · Begun Jan 24, 2018 · Resolved Jan 24, 2018 · Consent · Docket MC 17-47
During the course of a routine market conduct exam, the State of Connecticut Insurance Department (the state) found New York Life Insurance company did not timely pay long term care claims in four instances.
New York life insurnace company paid a monetary penalty of $1,000.00 to the State of Connecticut Insurance Department for failure to pay timely long term care claims in four instances.
In December 2017 New York life insurnace company paid a monetary penalty of $1,000.00 to the State of Connecticut Insurance Department.
- Oct 31, 2016Regulatory Action: State of New York Department of Financial Services FinalAbout an affiliate: New York Life InsuranceSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $732,067 · Begun Oct 31, 2016 · Resolved Oct 31, 2016 · Consent · Docket 2016-0001-A
As the result of a routine market conduct examination of the affairs of New York Life Insurance company for the period from January 1, 2005 through December 3, 2009, the New York state department of financial services found that nylic violated sections 53-3.5(a), 53- 3.2(a)2 and 53-3.6(b) of the department regulation no. 74 as well as New York insurance law section 3201(b)(1)
In October 2016, New York life paid a civil penalty of $ 732,067.00.
The findings by the New York state department of financial services have been resolved through a consent order.
Disclosures filed elsewhere
The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.
- 1 civil judicial action disclosure about New York Life Investment
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.