# Varadero Capital, L.P.

> Varadero Capital, L.P. is an SEC-registered investment advisory firm in New York, NY, registered since 2012, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 30, 2026.

- CRD: 159183
- Filed as: VARADERO CAPITAL, L.P.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: March 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/159183
- AdvisorCensus page: https://advisorcensus.com/firm/varadero-capital-l-p-new-york-ny-159183

## Quick answers

**How is Varadero Capital, L.P. compensated?**
On its Form ADV (Item 5.E, October 2026), Varadero Capital, L.P. reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Varadero Capital, L.P. located?**
Varadero Capital, L.P.'s principal office is in New York, NY, according to its Form ADV.

**Is Varadero Capital, L.P. registered with the SEC or a state?**
Varadero Capital, L.P. is an SEC-registered investment advisory firm, registered since 2012. Status as filed: Approved. CRD 159183.

**How much does Varadero Capital, L.P. manage?**
Varadero Capital, L.P. reports $2,292,180,712 in regulatory assets under management in its Form ADV filing dated March 30, 2026 (100% discretionary).

**How have Varadero Capital, L.P.'s assets and staff changed since 2021?**
In the Form ADV data for Varadero Capital, L.P.: Regulatory assets under management: $1,895,367,734 in the October 2021 data and $2,292,180,712 in the October 2026 data, up 21%. Total employees: 24 in October 2021 and 27 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Varadero Capital, L.P. serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (9); insurance companies (6); corporations or other businesses not listed above (2).

**Which custodians does Varadero Capital, L.P. use?**
Varadero Capital, L.P.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Bank of New York Mellon, State Street Global Services and The Northern Trust Company as custodians holding 10% or more of its separately managed account assets.

**Does Varadero Capital, L.P. 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/159183

**What changed in Varadero Capital, L.P.'s recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $2,565,478,697 to $2,292,180,712 (-11%). Employees performing advisory functions went from 13 to 11.

## From the Form ADV filing

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

### Custodians (Schedule D, Section 5.K(3))
- Bank of New York Mellon
- State Street Global Services
- The Northern Trust Company

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: $2,292,180,712
- Discretionary: $2,292,180,712
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 9 | $1,706,942,126 |
| Insurance companies | 6 | $551,521,689 |
| Corporations or other businesses not listed above | 2 | $33,716,897 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2012 (14 years)
- Employees: 27 total, 11 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: WY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [varaderocapital.com](https://varaderocapital.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,895,367,734 | 24 | March 31, 2021 |
| October 2022 | $2,018,782,285 | 28 | September 9, 2022 |
| October 2023 | $2,995,950,013 | 25 | March 31, 2023 |
| October 2024 | $2,864,456,311 | 25 | March 28, 2024 |
| October 2025 | $2,565,478,697 | 25 | March 28, 2025 |
| October 2026 | $2,292,180,712 | 27 | March 30, 2026 |

Regulatory assets under management: $1,895,367,734 in the October 2021 data and $2,292,180,712 in the October 2026 data, up 21%.
Total employees: 24 in October 2021 and 27 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $2,565,478,697 to $2,292,180,712 (-11%).
- Employees performing advisory functions went from 13 to 11.

### February 2026
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Varadero Capital, L.P. (CRD 159183): Form ADV filing data as of October 2026.