# Polpo Capital Management LLC

> 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.

- CRD: 323907
- Filed as: POLPO CAPITAL MANAGEMENT LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: March 23, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/323907
- AdvisorCensus page: https://advisorcensus.com/firm/polpo-capital-management-llc-323907

## Quick answers

**How is Polpo Capital Management LLC compensated?**
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.

**How much does Polpo Capital Management LLC charge?**
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.

**Is Polpo Capital Management LLC registered with the SEC or a state?**
Polpo Capital Management LLC is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 323907.

**How much does Polpo Capital Management LLC manage?**
Polpo Capital Management LLC reports $299,468,093 in regulatory assets under management in its Form ADV filing dated March 23, 2026 (100% discretionary).

**How have Polpo Capital Management LLC's assets and staff changed since 2023?**
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.

**What types of clients does Polpo Capital Management LLC serve?**
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).

**Which custodians does Polpo Capital Management LLC use?**
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.

**Does Polpo Capital Management LLC report any disciplinary disclosures?**
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

**Does Polpo Capital Management LLC state an account minimum?**
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."

**What changed in Polpo Capital Management LLC's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $229,271,331 to $299,468,093 (+31%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated March 23, 2026)

- Asset-based fee: up to 2% of assets a year (the maximum the brochure states)

> 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.

- Account minimum: $100,000 (the brochure says it may be waived or negotiated)

> The minimum initial investment in the Fund is generally $100,000, subject to the Firm’s discretion to accept lesser amounts.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Clearing OTC Trades and Holding Assets at Bank As Custodian

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.

### Regulatory assets under management (Item 5.F)
- Total: $299,468,093
- Discretionary: $299,468,093
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $209,480,182 |
| Insurance companies | 2 | $89,987,911 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2023 (3 years)
- Employees: 5 total, 2 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- New York, NY

### Websites listed on Form ADV (Item 1.I)
- polpocapital.com
- LinkedIn @polpo-capital

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | $45,392,522 | 5 | January 3, 2023 |
| October 2024 | $193,207,107 | 5 | August 13, 2024 |
| October 2025 | $229,271,331 | 5 | March 21, 2025 |
| October 2026 | $299,468,093 | 5 | March 23, 2026 |

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.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $229,271,331 to $299,468,093 (+31%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Polpo Capital Management LLC (CRD 323907): Form ADV filing data as of October 2026.