• S&P 500 7,659.44 −1.09%
  • Dow Jones 52,002.41 −0.34%
  • Nasdaq 26,713.03 +0.08%
  • VIX 19.99 +21.45%
  • 10-year Treasury 5.09% −0.01
  • Dollar index 121.40 −0.14%
  • WTI crude $101.91 +1.04%

Pavaki Capital Management, LLC: investment adviser

Pavaki Capital Management, LLC is an investment adviser registered with the SEC (file 801-136179, CRD 316395). 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
$410.1M
Discretionary
100%
Accounts
1
Employees
6
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 typeClientsAssetsShare
Private funds and other pooled vehicles1$410.1M100.0%

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
Ashok Rambhai PatelPersonManaging member / portfolio managerE 75% or moreSep 2020Yes

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.

Pavaki Capital Management, LLC - Firm Brochure, filed Jul 23, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Pavaki Capital Management, LLC ("Pavaki" or the "Firm") is a Colorado limited liability company registered with the U.S. Securities and Exchange Commission as a registered investment adviser (SEC File No. 801-136179). The Firm has been providing investment advisory services since its formation. The Firm is principally owned by Ashok Patel, who serves as the Managing Member. Prior to the formation of Pavaki Capital Management, LLC, the Firm's Managing Member, Ashok Patel, managed a substantially similar investment strategy through Sahdev LLC. The portfolio managed by Sahdev LLC was transferred into Pavaki Capital Partners, LP upon the Fund's formation.

Read the rest of Item 4 (220 more words)

Performance results presented by the Firm may include the historical performance of the predecessor entity, Sahdev LLC, for periods prior to the formation of Pavaki Capital Management, LLC and Pavaki Capital Partners, LP. Such predecessor performance is presented to provide a longer track record for the investment strategy. Predecessor performance is not indicative of future results, and investors should not rely on predecessor performance as a guarantee of future returns. Pavaki provides investment advisory services exclusively to Pavaki Capital Partners, LP (the "Fund"), a Delaware limited partnership. The Firm serves as the General Partner and investment adviser to the Fund. The Fund is a private fund offered under Regulation D, Rule 506(c) of the Securities Act of 1933 to accredited investors and qualified clients. The Firm employs a dynamic multi-assets strategy. Investment decisions are made on a discretionary basis by the Firm in its capacity as General Partner, in accordance with the investment objectives and guidelines set forth in the Fund's Private Offering Memorandum and Limited Partnership Agreement. The Firm does not tailor its advisory services to the individual needs of investors in the Fund. Investors in the Fund cannot impose restrictions on investing in certain securities or types of securities. As of December 31, 2025, Pavaki manages approximately $410,135,655 in regulatory assets under management, all on a discretionary basis.

Item 5. Fees and compensation

Pavaki does not charge a management fee for its advisory services. The Firm's compensation is derived entirely from performance-based fees (incentive allocation).

Performance-Based Fees / Incentive Allocation The General Partner receives an incentive allocation equal to 20% of the net profits generated in each investor's capital account, subject to a high-water mark. Investors retain 80% of the profits. The incentive allocation is calculated and allocated on a quarterly basis. The high-water mark is applied on a per-investor basis and resets quarterly in accordance with the terms of the Fund's Limited Partnership Agreement.

Read the rest of Item 5 (363 more words)

Performance-based fee arrangements may create an incentive for the Firm to make investments that are riskier or more speculative than would be the case in the absence of such arrangements. The high-water mark provision is intended to mitigate this risk by ensuring that the General Partner does not receive an incentive allocation unless the Fund has recovered any prior losses.

Other Expenses The Fund bears its own transaction-related expenses, including brokerage commissions and other costs directly related to the execution of securities transactions. All other operating expenses, including legal fees, accounting and auditing fees, organizational expenses, administration fees, and custodial fees, are borne by the General Partner, as described in the Fund's Private Offering Memorandum. The Firm does not receive compensation for the sale of securities or other investment products.

Lock-Up Period and Early Redemption Fees Each capital contribution made by a Limited Partner is subject to an Initial Lock-Up Period of thirty-six (36) months from the date of the capital contribution. During the Lock-Up Period, a Limited Partner may not request redemption of their investment except with the consent of the General Partner. If a Limited Partner redeems their interest during the Lock-Up Period, the following early redemption fees will apply:

• Redemption within the first 12 months of purchase: 50% redemption fee • Redemption between 12 and 24 months of purchase: 40% redemption fee • Redemption between 24 and 36 months of purchase: 35% redemption fee In the event of an early withdrawal during the Lock-Up Period, there shall be no reconciliation for profits and losses allocated to the Limited Partner's Capital Account. Accordingly, no excess performance fees, if any, shall be refunded. The early redemption fees are designed to protect the Fund and its remaining investors from the costs and disruptions associated with premature withdrawals. After the expiration of the Initial Lock-Up Period, a Limited Partner may withdraw from the Fund entirely by providing sixty (60) days' prior written notice to the General Partner. Distributions of any withdrawal will generally be made within fifteen (15) business days after the withdrawal date. Investors should carefully consider the Lock-Up Period and early redemption fees before investing, as these terms significantly restrict liquidity.

Item 6. Performance-based fees and side-by-side management

and Side-By-Side Management As described in Item 5, the Firm receives performance-based fees in the form of an incentive allocation from the Fund. The incentive allocation is equal to 20% of the net profits in each investor's capital account, subject to a high-water mark. Performance-based fee arrangements create a potential conflict of interest because they may incentivize the Firm to make riskier or more speculative investments than would otherwise be made. The Firm addresses this conflict through the high-water mark provision and through its fiduciary duties to the Fund and its investors. The Firm does not engage in side-by-side management of accounts with different fee structures.

Item 7. Types of clients

Pavaki provides investment advisory services exclusively to one private fund, Pavaki Capital Partners, LP. The Fund is offered to accredited investors as defined in Rule 501(a) of Regulation D under the Securities Act of 1933, and qualified clients as defined in Rule 205-3 under the Investment Advisers Act of 1940. The minimum investment commitment for the Fund is $5,000,000, generally representing 50 Partnership Interests at $100,000 each. The General Partner may, in its sole discretion, accept subscriptions for lesser amounts. Not applicable. Pavaki Capital Management, LLC is a registered investment adviser with the SEC (SEC File No. 801-136179).

Item 8. Methods of analysis, investment strategies and risk of loss

Investment Strategies and Risk of Loss Methods of Analysis The Firm employs a dynamic multi-assets strategy that involves fundamental analysis, quantitative analysis, and macroeconomic analysis. The Firm analyzes a broad range of asset classes, including equities, fixed income, derivatives, and other financial instruments.

Investment Strategies The Firm's investment strategy is dynamic and flexible, adjusting allocations across multiple asset classes based on market conditions, macroeconomic trends, and risk/reward opportunities. The strategy may involve both long and short positions, the use of leverage, and the use of derivative instruments for hedging and speculative purposes.

Read the rest of Item 8 (475 more words)

Risk of Loss Investing involves risk, including the potential loss of principal. The following are some of the material risks associated with the Firm's investment strategies: Market Risk: The value of investments may decline due to changes in general economic and market conditions. Leverage Risk: The use of leverage magnifies both gains and losses, and may result in losses exceeding the original investment. Derivatives Risk: The use of derivatives involves risks different from, and potentially greater than, the risks associated with investing directly in the underlying securities or assets. Concentration Risk: The Fund may concentrate its investments in certain sectors, asset classes, or geographic regions, which may increase volatility and risk.

Liquidity Risk: Some investments may be difficult to sell at favorable prices, particularly during periods of market stress. Short Selling Risk: Short selling involves the risk of theoretically unlimited loss if the price of the security increases. Counterparty Risk: The Fund faces the risk that a counterparty to a transaction may fail to fulfill its obligations. Interest Rate Risk: Changes in interest rates may adversely affect the value of certain investments. Regulatory Risk: Changes in laws and regulations governing the Firm's activities or the markets in which the Fund invests could adversely affect the Fund's operations and returns. The regulatory environment for investment advisers and private funds continues to evolve, and new regulations or changes in enforcement priorities could increase the Firm's compliance costs or restrict its investment activities. Operational Risk: The Fund is subject to risks arising from operational failures, including errors in trade execution, settlement, and valuation. The Firm's reliance on technology systems and third-party service providers also exposes the Fund to potential disruptions. Foreign Market Risk: The Fund may invest in securities traded on markets outside of the United States, which may be subject to different regulatory frameworks, less liquidity, greater volatility, and currency fluctuation risks. United States regulatory authorities may be unable to compel the enforcement of rules of regulatory authorities or markets in non-United States jurisdictions. Tax Risk: Changes in tax laws or their interpretation may adversely affect the Fund and its investors. Tax-exempt investors should be aware of the potential for unrelated business taxable income (UBTI) in connection with their investment in the Fund. Predecessor Performance Risk: The Firm may present performance results that include the track record of a predecessor entity, Sahdev LLC. The predecessor entity operated under different legal, regulatory, and organizational structures, and its historical results may not be

directly comparable to the performance of the Fund. Past performance, including predecessor performance, is not indicative of future results. Additional risk factors are described in greater detail in the Fund's Private Offering Memorandum, which investors should review carefully before investing. There is no guarantee that the Fund will achieve its investment objectives. Investors should be prepared to bear the risk of loss of their entire investment.

Item 9. Disciplinary information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the Firm or the integrity of its management. Pavaki Capital Management, LLC and its management persons have no disciplinary information to report.

Item 10. Other financial industry activities and affiliations

Activities and Affiliations Commodity Pool Operator / Commodity Trading Advisor Pavaki Capital Management, LLC has filed for exemption from registration as a Commodity Pool Operator with the Commodity Futures Trading Commission (CFTC) under CFTC Regulation 4.13(a)(3) and for exemption from registration as a Commodity Trading Advisor under CFTC Regulation 4.14(a)(8) with the National Futures Association (NFA).

Read the rest of Item 10 (103 more words)

Related Entity Pavaki Capital Management, LLC serves as the General Partner of Pavaki Capital Partners, LP. This dual role as both the investment adviser and the General Partner of the Fund creates a potential conflict of interest, as the Firm has an incentive to act in a manner that benefits itself in its capacity as General Partner. The Firm addresses this conflict through its fiduciary duties to the Fund and its investors, and through the terms of the Limited Partnership Agreement, which govern the relationship between the General Partner and the limited partners. The Firm does not have any other financial industry affiliations.

Item 11. Code of ethics, participation in client transactions and personal trading

Participation or Interest in Client Transactions, and Personal Trading Code of Ethics Pavaki Capital Management, LLC has adopted a Code of Ethics that establishes standards of conduct for its supervised persons and addresses conflicts of interest. The Code of Ethics requires supervised persons to act in the best interests of clients, maintain confidentiality of client information, and comply with applicable securities laws. The Code of Ethics includes provisions regarding personal securities transactions by supervised persons. Supervised persons are required to report their personal securities holdings and transactions to the Chief Compliance Officer on a periodic basis. A copy of the Firm's Code of Ethics is available upon request by contacting the Chief Compliance Officer, Nitu Dhanda, at nitu@pavakicapital.com or 719-542-7223.

Read the rest of Item 11 (98 more words)

Participation or Interest in Client Transactions The managing member of the Firm may buy or sell for his own personal account the same securities that the Firm recommends or trades for the Fund. This creates a potential conflict of interest, including the risk of front-running (trading ahead of the Fund) or competing for the same investment opportunities. The Firm's Code of Ethics and personal trading policies are designed to address these conflicts, including pre-clearance requirements and restrictions on personal trading. The Firm does not engage in principal transactions with the Fund and does not act as a broker-dealer.

Item 12. Brokerage practices

The Firm has discretionary authority to select the broker-dealers through which the Fund's transactions are executed. The Fund currently uses Interactive Brokers LLC as its primary broker-dealer and custodian. In selecting brokers, the Firm considers a number of factors, including but not limited to: execution quality, commission rates, financial stability, reputation, and the range of services provided. The Firm seeks to obtain best execution for the Fund's transactions. The Firm's prime broker, Interactive Brokers LLC, offers research services that may be utilized by the Firm. These research services are paid for separately by the Firm and are not bundled into or paid through trading commissions.

Read the rest of Item 12 (42 more words)

The Firm does not participate in traditional soft dollar arrangements where research or other services are obtained in exchange for directing brokerage commissions. The Firm does not aggregate orders across multiple client accounts, as the Fund is the Firm's sole advisory client.

Item 13. Review of accounts

The Fund's portfolio is reviewed on an ongoing basis by Ashok Patel, the Managing Member of the Firm, as part of the Firm's investment management process. Investors in the Fund receive the following reports: • Quarterly unaudited performance reports from NAV Consulting, Inc., the Fund's administrator • Annual audited financial statements prepared in accordance with U.S. GAAP by an independent public accountant, currently Subhajit Guha, CPA • Annual Schedule K-1 tax information Additional reports may be provided as determined by the General Partner.

Item 14. Client referrals and other compensation

Other Compensation The Firm does not compensate any person for client referrals. The Firm does not receive any economic benefit from any person or entity (other than the Fund) for providing investment advice to the Fund.

Item 15. Custody

Pavaki Capital Management, LLC is deemed to have custody of the Fund's assets because the Firm serves as the General Partner of Pavaki Capital Partners, LP. The Fund's assets are held by Interactive Brokers LLC, a qualified custodian. To comply with the SEC's Custody Rule (Rule 206(4)-2), the Fund is subject to an annual audit by an independent public accountant, currently Subhajit Guha, CPA. The audited financial statements are distributed to the Fund's investors within 120 days of the Fund's fiscal year-end (December 31). Investors should carefully review the account statements received from Interactive Brokers LLC and NAV Consulting, Inc.

Item 16. Investment discretion

Pavaki Capital Management, LLC has full discretionary authority over the investment decisions for the Fund, including the selection of securities, the amount of securities to be bought or sold, the broker-dealer to be used, and the commission rates to be paid. This discretionary authority is granted to the Firm through the Limited Partnership Agreement of Pavaki Capital Partners, LP. The Firm does not allow investors in the Fund to impose restrictions on the types of securities or investments that may be held in the Fund's portfolio.

Item 17. Voting client securities

The Firm has the authority to vote proxies on behalf of the Fund. The Firm votes proxies in a manner that it believes is in the best interests of the Fund and its investors. Investors in the Fund may obtain information about how the Firm voted proxies, or obtain a copy of the Firm's proxy voting policies and procedures, by contacting the Chief Compliance Officer, Nitu Dhanda, at nitu@pavakicapital.com or 719-542-7223.

Item 18. Financial information

Registered investment advisers are required to provide certain financial information or disclosures about their financial condition in this Item. The Firm does not require prepayment of fees six months or more in advance, and therefore is not required to include a balance sheet. The Firm is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The Firm has not been the subject of a bankruptcy petition.

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