FIRM DESCRIPTION
9823 Capital, LP (“9823 Capital”), a Texas limited partnership and private investment advisory firm (f/k/a White
Star Capital, LP), was originally formed in 2005. We provide investment management, advisory and other services
to private pooled investment vehicles. We have full discretionary authority with respect to investment decisions, and
our investment advice is made in accordance with the investment objectives and guidelines set forth in the applicable
offering memoranda and governing documents of such vehicles.
We are registered with the SEC as a "large advisory firm" as of January 2024. Precept Management, LLC is
registered with the SEC as a related adviser under common control with 9823 Capital. Please see Item 10 below for
more information.
PRINCIPAL OWNERS
We are ultimately owned and controlled by D. Blair Baker. See Schedules A and B of Part lA of Form ADV for
more information regarding our ownership and officers.
TYPES OF ADVISORY SERVICES
Fund Management
We serve as general partner and investment manager of 9823 Fund, LP and Precept Management Partners, LP.
(collectively, the "Funds"). Our services consist of making, managing, and disposing of investments held by the
Funds. We provide investment advice directly to the Funds and not individually to any investor in the Funds. 9823
Capital also offers investment advisory services to institutional and retail investors in separately managed accounts
(“SMAs”).
We have caused and may from time to time cause a Fund (an "investor fund") to invest all or a portion of its assets
in one or more other Funds or funds managed by one or more of our affiliates (each, an "investee fund"). In such
event, the investor fund generally will not be subject to any additional or duplicative fees, management fees or
incentive allocations in connection with its investment in an investee fund.
We manage investments with respect to the Funds and are responsible for investing and re-investing the assets of
the Funds in accordance with the investment objectives, policies and guidelines set forth in the applicable offering
memoranda and governing documents. See Item 8 below.
Separately Managed Account Services
9823 Capital provides customized investment advisory solutions for some of its Clients through SMAs. This is
achieved through personal contact and interaction while providing discretionary investment advisory and/or
management services, as applicable to each Client’s engagement. Clients must be aware that 9823 Capital does not
provide holistic investment management and/or financial planning services and therefore Clients should only invest
a portion of their total investable assets with 9823 Capital to ensure their personal portfolio is appropriately
diversified, as applicable.
9823 Capital works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. 9823 Capital will then construct the Client’s
portfolio and/or provide discretionary recommendations for the Client to construct and maintain its portfolio. It is
likely that strategies recommended to SMA Clients are similar to (and in some cases may be identical to) or are
subsets of strategies employed by Funds managed by 9823 Capital.
A Client’s portfolio may consist of a variety of investments including, but not limited to: equity securities (both
public and private), fixed income securities, options contracts, ETFs, leveraged ETFs/mutual funds, exchange-
traded notes (ETNs), closed-end funds, real estate investment trusts (REITs), mutual funds, warrants, corporate debt
securities, commercial paper, certificates of deposit, municipal securities, investment company securities, U.S.
Government securities, non-publicly traded REITs, options contracts on securities, special purpose vehicles, and
other alternative investments.
SMA Clients may potentially invest a portion of their account in a 9823 Capital managed Fund. If such an
investment is made from a Client account, the amount invested in the Fund will reduce the Client’s assets under
management and corresponding IA Fee related to the SMA. The Funds are subject to a separate Management Fee
and Performance Fee
structure, as discussed further in Item 5, below.
Clients bear all of their own costs and expenses directly related to investments in SMAs including those related to
custody, trading, margin fees and interest, alternative investments, accounting services, compliance costs, tax
preparation, audit, and other fees and costs, as applicable. Expenses are described in more detail in any relevant
custodial agreement and/or alternative investments offering documents and related documents, as applicable.
Clients should carefully review these documents before investing.
Investing in alternative investments involves a high degree of risk, including liquidity risk, business risk, dilution
risk, and other risks. Such investments may involve significant fees and expenses and be subject to partnership tax
reporting. The receipt of these fees, including performance-based fees, could represent an incentive for 9823 to
recommend alternative investments over investments with lower fees, therefore creating a conflict of interest. These
potential conflicts of interest are discussed in further detail in Item 6 below. Alternative investments are typically
for long-term investors willing and able to bear the increased risk and tax reporting burden commonly associated
with these types of investments. As applicable, Clients should carefully review the private placement memorandum
provided by the issuer of an alternative investment to further understand the risks of investing prior to making any
investment.
9823 Capital’s SMA strategy is primarily long-term focused, but 9823 Capital may recommend to buy, sell, or re-
allocate positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. 9823 Capital will construct, implement, monitor, and/or recommend action on a discretionary basis
regarding the portfolio to strive to meet the goals, objectives, circumstances, and risk tolerance agreed to by the
Client.
9823 Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. 9823 Capital may recommend, on occasion, redistributing investment allocations to diversify or
rebalance the portfolios of its Clients. 9823 Capital may also recommend specific positions to increase sector or
asset class weightings, may recommend employing cash positions as a possible hedge against market movement,
and may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position(s) in the portfolio, change in risk tolerance of a Client, generating cash to meet a Client’s needs, or
any risk deemed unacceptable due to the Client’s risk tolerance.
9823 Capital will not act as the custodian of any SMA Client’s funds or securities. All SMA Client assets will be
managed within their designated account at a qualified custodian selected by the Client, pursuant to the Client
Investment Management Agreement (“IMA”). 9823 Capital may, however, recommend unaffiliated third-party
custodians to Clients for their consideration, but does not have the authority to select the custodian on the Client’s
behalf. Please see “Item 12 – Brokerage Practices” below for more information.
INVESTMENT RESTRICTIONS
We generally provide investment advice to the Funds in accordance with the investment objectives, policies and
guidelines set forth in the offering and governing documents, and not in accordance with the individual needs or
objectives of any particular investor in the Funds. Investors generally are not permitted to impose restrictions or
limitations on the management of the Funds.
Private Funds are managed in accordance with their respective Offering Documents as described above. 9823
Capital seeks to tailor and offer individualized advice to our SMA Clients within reason as described above. Each
SMA Client may impose reasonable restrictions, in writing, on 9823 Capital's services and recommendations.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, we had approximately $117.3 million regulatory assets under management, all of which
were managed on a discretionary basis.