Galaxy Digital Capital Management LP

• A percentage of assets under your management
• Fixed fees (other than subscription fees)
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated March 31, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$1,722,962,538 as of October 2026, filing dated July 1, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for investment companies (and business development companies)
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Other

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2019 (7 years)

Employees

Total: 61. Performing investment advisory functions: 22.

Wrap fee program participation

No.

States registered or notice-filed

1 state or jurisdiction

NY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

2 Reports 2 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(1) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $312,079,597 in the October 2021 data and $1,722,962,538 in the October 2026 data, up 452%.

Total employees: 25 in October 2021 and 61 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Employees performing advisory functions went from 29 to 22.
   • Regulatory assets under management went from $2,452,058,739 to $1,722,962,538 (-30%).
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.