{
  "crd_number": 323907,
  "slug": "polpo-capital-management-llc-323907",
  "primary_business_name": "POLPO CAPITAL MANAGEMENT LLC",
  "legal_name": "POLPO CAPITAL MANAGEMENT LLC",
  "dbas": [],
  "city": null,
  "state": null,
  "country": null,
  "cbsa_code": null,
  "metro": null,
  "registration_type": "sec",
  "registration_status": "Approved",
  "registration_date": "2023-02-02",
  "years_registered": 3,
  "period": "2026-10-01",
  "filing_date": "2026-03-23",
  "carried_forward": false,
  "raum_total": 299468093.0,
  "raum_discretionary": 299468093.0,
  "raum_non_discretionary": 0.0,
  "raum_band": "100m_500m",
  "raum_band_label": "$100 million to $500 million",
  "total_employees": 5,
  "advisory_employees": 2,
  "client_count_bucket": "fewer_than_5_in_some_types",
  "clients_by_type": {
    "insurance_companies": {
      "raum": 89987911.0,
      "count": 2,
      "fewer_than_5": true
    },
    "pooled_investment_vehicles": {
      "raum": 209480182.0,
      "count": 2
    }
  },
  "compensation_types": [
    "percentage_of_aum",
    "performance_based"
  ],
  "advisory_activities": [
    "portfolio_management_pooled_vehicles"
  ],
  "wrap_fee_participant": false,
  "disclosure_yes_count": 0,
  "states_registered": [],
  "websites": [
    "https://linkedin.com/company/polpo-capital",
    "https://polpocapital.com"
  ],
  "iapd_url": "https://adviserinfo.sec.gov/firm/summary/323907",
  "city_as_filed": null,
  "url": "https://advisorcensus.com/firm/polpo-capital-management-llc-323907",
  "display_name": "Polpo Capital Management LLC",
  "summary": "Polpo Capital Management LLC is an SEC-registered investment advisory firm, registered since 2023, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 23, 2026.",
  "citation": "AdvisorCensus. Polpo Capital Management LLC (CRD 323907): Form ADV filing data as of October 2026.",
  "registration_type_label": "SEC-registered investment adviser",
  "compensation_labels": [
    "A percentage of assets under your management",
    "Performance-based fees"
  ],
  "advisory_activity_labels": [
    "Portfolio management for pooled investment vehicles (other than investment companies)"
  ],
  "quick_answers": [
    {
      "q": "How is Polpo Capital Management LLC compensated?",
      "a": "On its Form ADV (Item 5.E, October 2026), Polpo Capital Management LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees."
    },
    {
      "q": "How much does Polpo Capital Management LLC charge?",
      "a": "Its Form ADV Part 2A brochure dated March 23, 2026 states: Asset-based fee: up to 2% of assets a year (the maximum the brochure states). Fees can differ by service and may be negotiable; the brochure is the complete statement."
    },
    {
      "q": "Is Polpo Capital Management LLC registered with the SEC or a state?",
      "a": "Polpo Capital Management LLC is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 323907."
    },
    {
      "q": "How much does Polpo Capital Management LLC manage?",
      "a": "Polpo Capital Management LLC reports $299,468,093 in regulatory assets under management in its Form ADV filing dated March 23, 2026 (100% discretionary)."
    },
    {
      "q": "How have Polpo Capital Management LLC's assets and staff changed since 2023?",
      "a": "In the Form ADV data for Polpo Capital Management LLC: Regulatory assets under management: $45,392,522 in the October 2023 data and $299,468,093 in the October 2026 data, up 560%. Total employees: 5 in October 2023 and 5 in October 2026. Assets under management move with markets as well as with clients coming and going."
    },
    {
      "q": "What types of clients does Polpo Capital Management LLC serve?",
      "a": "By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (2); insurance companies (2)."
    },
    {
      "q": "Which custodians does Polpo Capital Management LLC use?",
      "a": "Polpo Capital Management LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Clearing OTC Trades and Holding Assets at Bank As Custodian as a custodian holding 10% or more of its separately managed account assets."
    },
    {
      "q": "Does Polpo Capital Management LLC report any disciplinary disclosures?",
      "a": "Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/323907"
    },
    {
      "q": "Does Polpo Capital Management LLC state an account minimum?",
      "a": "Its Form ADV Part 2A brochure dated March 23, 2026 says: \"The minimum initial investment in the Fund is generally $100,000, subject to the Firm’s discretion to accept lesser amounts.\""
    },
    {
      "q": "What changed in Polpo Capital Management LLC's recent Form ADV filings?",
      "a": "In the April 2026 filing data: Regulatory assets under management went from $229,271,331 to $299,468,093 (+31%)."
    }
  ],
  "filing_history": [
    {
      "period": "2023-10-01",
      "regulatory_assets_under_management": 45392522.0,
      "total_employees": 5,
      "filing_date": "2023-01-03"
    },
    {
      "period": "2024-10-01",
      "regulatory_assets_under_management": 193207107.0,
      "total_employees": 5,
      "filing_date": "2024-08-13"
    },
    {
      "period": "2025-10-01",
      "regulatory_assets_under_management": 229271331.0,
      "total_employees": 5,
      "filing_date": "2025-03-21"
    },
    {
      "period": "2026-10-01",
      "regulatory_assets_under_management": 299468093.0,
      "total_employees": 5,
      "filing_date": "2026-03-23"
    }
  ],
  "recent_changes": [
    {
      "period": "2026-04-01",
      "period_label": "April 2026",
      "notes": [
        "Regulatory assets under management went from $229,271,331 to $299,468,093 (+31%)."
      ]
    }
  ],
  "fees_from_brochure": {
    "source": "Form ADV Part 2A brochure dated March 23, 2026",
    "provided_by_the_firm": false,
    "tiers": [],
    "flat_rate": null,
    "stated_range": null,
    "stated_maximum": "2% of assets a year",
    "account_minimum": "$100,000",
    "account_minimum_may_be_waived": true,
    "minimum_annual_fee": null,
    "planning_fees": [],
    "figures": [
      {
        "label": "Asset-based fee",
        "statements": [
          "Asset-based fee: up to 2% of assets a year (the maximum the brochure states)"
        ],
        "quotes": [
          "Pursuant to the Offering Documents, Polpo receives a management fee during the investment period payable at the maximum rate of 2% per annum on the balance of each limited partner’s capital account, pro-rated for partial quarters."
        ]
      },
      {
        "label": "Account minimum",
        "statements": [
          "Account minimum: $100,000 (the brochure says it may be waived or negotiated)"
        ],
        "quotes": [
          "The minimum initial investment in the Fund is generally $100,000, subject to the Firm’s discretion to accept lesser amounts."
        ]
      }
    ],
    "values": {
      "tiers": [],
      "range_pct": null,
      "max_pct": 2.0,
      "account_minimum": 100000.0,
      "minimum_annual_fee": null,
      "planning": []
    },
    "quotes": [
      "Pursuant to the Offering Documents, Polpo receives a management fee during the investment period payable at the maximum rate of 2% per annum on the balance of each limited partner’s capital account, pro-rated for partial quarters.",
      "The minimum initial investment in the Fund is generally $100,000, subject to the Firm’s discretion to accept lesser amounts."
    ],
    "note": "As stated in the firm's brochure; fees can differ by service and may be negotiable."
  },
  "custodians": [
    {
      "name": "Clearing OTC Trades and Holding Assets at Bank As Custodian",
      "name_as_filed": "CLEARING OTC TRADES AND HOLDING ASSETS AT BANK AS CUSTODIAN",
      "affiliated": false
    }
  ],
  "custodians_note": "Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.",
  "markdown_url": "https://advisorcensus.com/firm/polpo-capital-management-llc-323907.md",
  "clients": [
    {
      "type": "pooled_investment_vehicles",
      "label": "Pooled investment vehicles (other than investment companies and business development companies)",
      "count": 2,
      "fewer_than_5": false,
      "raum": 209480182.0
    },
    {
      "type": "insurance_companies",
      "label": "Insurance companies",
      "count": 2,
      "fewer_than_5": true,
      "raum": 89987911.0
    }
  ],
  "disclosure_line": "Reports no disclosure items on Form ADV Item 11.",
  "disclosure_items": [],
  "indexable": true,
  "suppressed": false,
  "claimed": false,
  "enhanced": false,
  "provided_by_the_firm": null,
  "source": {
    "name": "Form ADV",
    "as_of": "2026-10-01",
    "iapd_url": "https://adviserinfo.sec.gov/firm/summary/323907",
    "operator": "BH Monitor Services, LLC",
    "license": "https://creativecommons.org/licenses/by/4.0/",
    "credit": "AdvisorCensus (advisorcensus.com), from SEC Form ADV data"
  }
}