Desert Rose Capital Management, Inc. (“we”, “us”, “our”, the “Firm” or “DRCM”) is registered with the U.S. Securities
and Exchange Commission as an investment advisor. DRCM was established July 19, 2010, by Kirk Alan Stafford, the
founder, president. DRCM is organized as a corporation under the laws of Idaho and solely owned by Mr. Stafford.
DRCM is e not a publicly held company.
Investment Advisory Services
We offer investment advice and asset management on both a discretionary and non-discretionary basis inclusive of
services for public and non-publicly traded securities. Our core competency is the utilization of exchange traded
options in conjunction with conservative income producing assets designed to produce lower overall portfolio risk
while participating in potential market appreciation. While not a primary focus, we may also provide advice on non-
security related financial products and services such as life insurance, mortgages, estate planning, retirement plans,
and savings, budgeting, debt reduction, tax planning, and preparation (in conjunction with a CPA), and savings plans
for college and mission funds.
We customize our advisory services for you based on your time horizon, risk tolerance, current financial situations,
goals, and comfort levels. You may impose reasonable restrictions on investing in certain securities or types of
securities through written communication to us. We also act as a third-party adviser or sub-advisor on accounts held
by other registered investment advisers (and their qualified custodians), giving us the ability to implement our
portfolio strategies on behalf of the respective registered investment advisers. We typically manage client accounts
under our discretion. Discretionary portfolio management means we will make investment decisions and place buy
or sell orders in those accounts without contacting the adviser or client. DRCM also serves as the investment
manager and provides discretionary advisory services to one pooled investment vehicle, the “Cash Value Fund, LP,
(the “Fund”), organized as a limited partnership and available to accredited investors.
The Cash Value Fund, LP, was launched on March 15, 2019. The Fund is managed by a general partner, Cash Value
Fund GP, LLC, which is also the fiduciary of the fund. DRCM is the investment manager of the Fund, performing the
selection and management of individual investments, insurance policies,
and investment managers within the Fund.
The Fund’s investment objective is to provide a highly liquid, principal-protected return to investors with a very
competitive yield compared to other short-term liquid investment vehicles. The primary investment focus of the
Fund will be to purchase permanent life insurance policies and to issue loans fully collateralized by the cash values
of life insurance policies. It is important to note that the Cash Value Fund, LP is not a “private fund” within the
meaning of the Form ADV. The Form ADV limits the definition of “private fund” to issuers that would be an
“investment company” under the Investment Company Act but for an exemption under Section 3(c)(1) or 3(c)(7).
The Cash Value Fund, LP is primarily investing in permanent life insurance policies, which the SEC generally does not
consider to be “securities” within the meaning of the Investment Company Act. As such, it has been determined
that the Cash Value Fund is not an “investment company” under the Investment Company Act and therefore did not
need to qualify for an exemption from registration under Section 3(c)(1) or 3(c)(7) of the 1940 Act (thus taking it out
of the definition of “private fund” for Form ADV purposes).
Kirk Stafford, President of DRCM, is the principal owner and manager of Cash Value Fund GP, LLC, the General Partner
to the Fund. Mr. Stafford is involved in the day-to-day management of the Fund and its General Partner. He and
other persons associated with DRCM who are responsible for providing advisory services to clients of DRCM have a
financial incentive to recommend investments in the Fund. Investors to whom the Fund is offered will receive a
private placement memorandum and other offering documents. Investors in the fund are urged to carefully review
the offering documents for a complete description of the fees, conflicts of interest, investment objectives, risks, and
other important information associated with investing in the Fund.
Wrap Fee Programs
We do not manage, sponsor, or participate in any wrap-fee programs.
Assets Under Management
As of December 31, 2023, DRCM managed approximately $117,194,781 in total regulatory assets under
management (“RAUM”), including approximately $71,168,744 in discretionary managed assets and approximately
$46,026,037 in non-discretionary managed assets.
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