This Brochure applies to KSCM and its relying advisers: King Street (Europe) LLP (“King Street
Europe”); King Street (Japan) Limited (“King Street Japan”); King Street (Singapore) Pte. Ltd.
(“King Street Singapore”); and Rockford Tower Capital Management, L.L.C. (“RTCM”)
(collectively, the “Relying Advisers”). KSCM was co-founded in 1995 by Brian J. Higgins, the
Managing Member of KSCM’s general partner, King Street Capital Management GP, L.L.C. (the
“Investment Manager GP”). KSCM is owned by the members of the Investment Manager GP.
King Street provides services to private investment funds, which include open-ended hedge funds that focus
on distressed debt, special situations, long/short credit and event driven strategies (the “Hedge Funds”),
closed-ended real estate funds that focus on global opportunistic investments (the “Real Estate
Funds”), and drawdown funds that focus on opportunistic or special situations investments (the
“Drawdown Funds”) (each of the foregoing, a “Fund” and collectively, the “Funds”). A related
person of KSCM generally acts as general partner or special shareholder of each Fund, and King
Street acts as investment manager to each Fund.
RTCM acts as the collateral manager to collateralized loan obligation vehicles that invest primarily
in broadly syndicated loans and collateralized bond obligation vehicles that invest in bonds and
broadly syndicated loans (collectively, the “Rockford Tower CDOs”). If required, RTCM also acts
as “risk retention provider” (as described below) with respect to the Rockford Tower CDOs. In
its role as risk retention provider, RTCM holds Rockford Tower CDO securities to the extent
required by applicable risk retention rules (“Risk Retention Interests”) and, through their
investment in RTCM, certain Funds will be indirectly exposed to the Risk Retention Interests.
King Street provides certain services to RTCM relating to management of the Rockford Tower
CDOs.
The Funds and Rockford Tower CDOs are collectively referred to herein as “Advisory Clients.”
References to King Street in this Brochure include, as the context requires, affiliates through which
King Street provides investment advisory services or that act in any capacity. Each general partner,
manager and special shareholder that are related persons of KSCM are subject to the Investment
Advisers Act of 1940, as amended (the “Advisers Act”) pursuant to King Street’s registration in
accordance with SEC guidance and operate as a single advisory business.
King Street’s management of each Advisory Client is subject to, and the terms of any investor’s
investment in an Advisory Client and all other terms of each Advisory Client, are governed
exclusively by, the terms of that Advisory Client’s organizational documents, offering
memorandum, limited partnership agreement (if any), memorandum and articles of association
(if
any), investment management agreement (if any), and subscription agreement (if any), each as
amended, supplemented or modified from time to time (collectively, the “Governing Documents”).
All discussions in this Brochure regarding the Advisory Clients, including their investments, the
strategies King Street pursues in managing them, the fees and expenses borne by their investors,
and all other terms of each Advisory Client, are qualified in their entirety by reference to the
relevant Governing Documents and are further described below under “Methods of Analysis,
Investment Strategies and Risk of Loss.”
Investors in the Advisory Clients participate in the overall investment program for the applicable
Advisory Client, but in certain circumstances are excused from a particular investment due to legal,
regulatory or other agreed-upon circumstances pursuant to the Governing Documents and/or Side
Letters (as defined below); for the avoidance of doubt, such arrangements generally do not and
will not create an adviser-client relationship between King Street and any investor. The Advisory
Clients or King Street have entered into, and expect in the future to enter into, side letters or other
similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights
under, or altering or supplementing the terms (including economic or other terms) of, the
Governing Documents with respect to such investors. As King Street manages each Advisory
Client pursuant to its investment objectives and restrictions as set forth in the applicable Governing
Documents, investors should review the relevant Governing Documents to determine whether such
an investment is appropriate for their individual circumstances.
From time to time, where investments of the Funds consist of portfolio companies or include
intermediate holding vehicles through which the Funds invest, the senior principals or other
personnel of King Street or its affiliates serve on such portfolio companies’ or holding vehicles’
respective boards of directors or otherwise act to influence control over such entities.
As of January 1, 2023, KSCM had approximately $19,179,900,0001 in net client assets under
management, all managed on a discretionary basis. (Note that the method for computing “net client
assets under management” is different than the method for computing “regulatory assets under
management” required for Item 5.F. in Form ADV Part 1A.)
King Street currently does not provide investment advisory services to clients apart from its
management of the Advisory Clients, although it may do so in the future. Investors in the Advisory
Clients have no opportunity to select or evaluate any investments or strategies. King Street selects
each Advisory Client’s investments and determines its investment strategies.