General
Marble Point Credit Management LLC (“Marble Point” or the “Firm”) has been registered with the SEC
as an investment adviser since August 2016. Marble Point provides investment advisory and/or collateral
management services to (1) a closed-ended collective investment scheme listed on an international
securities exchange outside of the United States, (2) other forms of investment vehicles, including loan
accumulation facilities and collateralized loan obligation vehicles (“CLOs”, along with the investment
vehicles referenced in clauses (1) and (2) hereof, collectively, “Pooled Accounts”), and (3) separately
managed accounts (collectively with the Pooled Accounts, the “Accounts”). Marble Point may from time
to time provide both discretionary and non-discretionary investment advisory services to Accounts.
The Accounts to which Marble Point provides investment advisory services invest primarily in U.S. senior
secured, non-investment grade bank loans (e.g., in the case of a loan accumulation facility or CLO) or
securities issued by CLOs managed by Marble Point, or a combination of the two. Generally, CLOs are
securitization vehicles that pool portfolios of primarily below investment grade U.S. senior secured bank
loans. Loan accumulation facilities are short to medium-term facilities often provided by the bank that will
serve as the placement agent or arranger on a future CLO transaction. Loan accumulation facilities and
CLOs are vehicles structured to use leverage, although Marble Point as the manager does not employ other
leverage in connection with the management of such Accounts. While Marble Point does not currently do
so, depending on an Account’s particular investment mandate, Marble Point may also from time to time
provide investment advisory services with respect to other types of investments. Marble Point’s investment
strategies are described further under “Item 8 – Methods of Analysis, Investment Strategies and Risk of
Loss”.
The documentation governing Accounts include offering circulars, private placement memoranda,
management agreements, indentures, subscription agreements, and other agreements with Accounts, side
letters or similar arrangements with investors, and certain other documents (collectively, “Account
Documents”). Account Documents generally contain, among other things, investment guidelines,
restrictions and tests regarding the type of investments and overall composition of an Account’s investment
portfolio (such as diversity, ratings, concentration, etc.) and the Firm’s role and authority. Except in the
case of a separately managed account, investment guidelines for Accounts are not tailored to the individual
needs of any particular Account or investor. Nevertheless, certain investors and stakeholders can be
expected to influence Account investment criteria or portfolio guidelines.
Marble Point was founded by Eagle Point Credit Management LLC (“Eagle Point”) and Thomas
Shandell, the Firm’s Chief Executive Officer and Chief Investment Officer, in March 2016 as an indirect,
wholly-owned subsidiary of Eagle Point. On January 12, 2023, Investcorp acquired Marble Point,
resulting in Marble Point becoming a member of the Investcorp group of companies with Marble Point
now being 100% directly owned by Investcorp International Holdings Inc. ("IIHI"), which is part of the
Investcorp Group of companies. The Investcorp Group effectively operates as a management-controlled
group, substantially all whose assets and operations are owned and controlled by Investcorp S.A., a
company domiciled in the Cayman Islands. Certain of the Investcorp Group’s directors and senior
executive officers have the ability to indirectly control Investcorp S.A.
Marble Point and its personnel carry out the Firm’s advisory business either directly or indirectly through
one or more subsidiaries of the Firm. As of the date of this Brochure, Marble Point has two such indirect
subsidiaries which act as collateral managers to CLOs—MP CLO Management LLC and Marble Point
CLO Management LLC (together, the “Relying Advisers”, and where the context so requires, the terms
“Marble Point” and the “Firm” refer to Marble Point Credit Management LLC and the Relying Advisers
collectively). Marble Point provides personnel and services to the Relying Advisors pursuant to a staffing
and services arrangement. Each of the Relying Advisers is registered as an investment adviser with the
Securities and Exchange Commission as a “relying adviser” of Marble Point and, as such, is each listed on
a Schedule R to Marble Point’s Form ADV Part 1A. Each Relying Adviser is a wholly owned subsidiary
of MP CLOM Holdings LLC, a Delaware limited liability company of which Marble Point serves as the
managing member. MP CLOM Holdings LLC’s other member is MPLF Retention I Ltd., a Cayman Islands
exempted company that is a wholly owned subsidiary of Marble Point Loan Financing Limited, a Guernsey
domiciled closed-end investment company listed on the Specialist Fund Segment of the London Stock
Exchange.
About this Brochure
Investors and other recipients should be aware that while the Brochure includes information about Pooled
Accounts
advised by Marble Point, as necessary or appropriate, the Brochure should not be considered to
represent a complete discussion of the features, risks or conflicts associated with any Pooled Account. More
complete information about a Pooled Account will be included in such Pooled Account’s Account
Documents. To the extent that there is a conflict between disclosure herein and similar or related disclosures
in Account Documents, the terms of the Account Documents shall govern and control.
In no event should this Brochure be considered to be an offer of securities or interests in any
Pooled Account or relied upon in determining to invest in any Pooled Account. It is also not an offer
of, or agreement to provide, advisory services directly to any recipient.
Rather, this Brochure is designed to provide information about Marble Point for the purpose of compliance
with Marble Point’s obligations under the U.S. Investment Advisers Act of 1940, as amended (the
“Advisers Act”). Accordingly, the Brochure responds to relevant regulatory requirements under the
Advisers Act, which may differ from the information provided in an Account’s Account Documents. To
the extent that there is any conflict between discussions herein and similar or related discussions in any
Account Document, the Account Document shall govern.
Advisory Agreements and Pooled Accounts
Marble Point generally enters into a separate investment advisory agreement (or similar agreement, such as
a collateral management agreement) with each Account that it manages and each such Account is managed
in accordance with the investment objectives, strategies, restrictions and guidelines communicated to
Marble Point by the applicable client, as such terms are set forth in the applicable agreement or other
Account Document. In this respect, each Pooled Account is managed by Marble Point in accordance with
the investment objectives, strategies, restrictions and guidelines set forth in the Pooled Account’s Account
Documents. Because Marble Point only provides investment advice to a Pooled Account in accordance
with the Pooled Account’s Account Documents, Marble Point does not provide individualized advice to
the investors in such Pooled Account (and an investment in a Pooled Account does not, in and of itself,
create an advisory relationship between the investor and Marble Point). Each investor must consider for
itself whether a Pooled Account meets the investor’s investment objectives and risk tolerance before
investing.
Marble Point (or an affiliate) is not restricted from entering into separate agreements, commonly referred
to as “side letters,” or other similar agreements or arrangements with one or more different investors in a
Pooled Account in connection with such persons’ investment in the Pooled Account (or otherwise) without
the approval of any other investor therein. These agreements generally have the effect of establishing rights
under, or supplementing the terms of, a Pooled Account’s Account Documents with respect to that investor
in a manner more favorable than those applicable to other investors. The rights or terms in any such side
letter or other similar agreement may include, without limitation (1) reporting obligations relating to
information concerning the applicable Pooled Account, (2) waiver of certain confidentiality obligations, (3)
reduction of fees applicable to such investor, (4) waiver of certain restrictions on the ability of the investor
to withdraw or transfer all or part of its investment, (5) rights or terms necessary in light of particular legal,
regulatory or public policy characteristics of an investor, or (6) the ability to co-invest alongside an Account
in certain underlying investments. Certain investors that have the benefits of a “most favored nation”
provision are given the opportunity to elect the rights and terms in any side letter or other similar agreement
that are applicable to other investors in the same Pooled Account. As a result, some investors are expected
to have more favorable investment terms, including those relating to fees, information and liquidity, than
others. If Marble Point were to grant increased liquidity to an investor, particularly where such an
agreement is accompanied by enhanced information about a Pooled Account’s operations or investments
(often referred to as “transparency rights”), other investors could be disadvantaged.
Marble Point, in its sole discretion, may offer more favorable terms (e.g., lower investment minimums, or
reduced or eliminated fees) to its personnel, related persons or others, including with respect to dedicated
vehicles that invest in or alongside a Pooled Account. Similarly, one or more Accounts managed by Marble
Point that pursue the same or a substantially similar strategy as a Pooled Account may have different terms,
including different fee arrangements and/or terms similar to those described above, than the relevant Pooled
Account.
Management of Client Assets
Marble Point had approximately $7.8 billion in discretionary regulatory assets under management and no
non-discretionary regulatory assets under management as of December 31, 2022.