9AT: TWIN LAKES CAPITAL

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL MANAGEMENT, LLC

Adviser Profile

As of Date	03/25/2026
Registration	SEC, Approved, 05/18/2018
Other registrations (1)	California, Terminated, 07/08/2018
ADV Location	REDWOOD SHORES, CA, United States
Contact Info	(65 xxxxxxx

AUM^*	314,676,938 20%
of that, discretionary	314,676,938 24%
Number of Employees	5 -17%
of those in investment advisory functions	2
Private Fund GAV^*	0
Avg Account Size	784,731 29%
% High Net Worth	52.13% -17%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses
- Selection of other advisers

Compensation Arrangments

- A percentage of assets under your management

Reported AUM

315M 270M 225M 180M 135M 90M 45M

2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

Who we are Twin Lakes Capital Management, LLC dba Twin Lakes Capital (referred to as “we,” “our,” “us,” or “Twin Lakes”), has been registered as an investment advisor since January 2007. Our principal officer is Mark G. Kim, Managing Member.
Services we offer We offer general investment advisory services which includes investments in stocks, bonds, cash products, etc. Our advice is tailored to the needs of the client based on risk tolerance and investment experience. We customize personal asset allocation plans.
For “qualified clients,” we may recommend investing in private investments (i.e., private equity funds, venture capital funds). In order to be considered for this type of an investment, a client must first meet the definition of a “qualified client.” Typically, our clients who are “qualified clients” have $1,000,000 or more of assets under management with us or have a net worth of $2,100,000 (excluding the value of his or

her primary residence).
Once this is determined, we will identify those clients who are seeking to diversify their portfolio and who do not mind having their assets be illiquid for a period of up to 10 years (a potential term life of a private investment fund). When a client is identified as meeting this criteria, we may recommend a specific private investment at which point all documents associated with the investment (i.e., Offering Memorandum, Subscription Booklet) are forwarded to the client directly from the General Partner of the recommended investment for their review and consideration.
Clients may impose restrictions on investments made in specific securities or types of securities.
We do not provide portfolio management services to a wrap fee program.
Assets under management As of December 31, 2023, we manage assets of $254.0 million on a discretionary basis and $8.2 million on a non-discretionary basis.

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL MANAGEMENT, LLC

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Brochure Summary

Overview

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TWIN LAKES CAPITAL TWIN LAKES CAPITAL TWIN LAKES CAPITAL MANAGEMENT, LLC

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Brochure Summary

Overview

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL

TWIN LAKES CAPITAL MANAGEMENT, LLC