Advisory Business
A. RRCM, a Delaware limited partnership, is an investment adviser located in New York, NY, founded in
2003. RRCM serves as the sole investment adviser to eight (8) pooled investment vehicles (each a
“Fund” and collectively the “Funds”), which include Riva Ridge Capital Partners, LP (the “Domestic
Fund”), Riva Ridge Overseas Fund, Ltd. (the “Overseas Fund”), Riva Ridge Master Fund, Ltd. (the
“Master Fund”), Riva Pronto Master Fund, LP (the “Pronto Master Fund”), Riva Pronto Overseas Fund,
Ltd. (the “Pronto Overseas Fund”), Hornsilver LLC (the “Hornsilver Fund”) and Highline, Ltd. (the
“Highline Fund”); Gandy Capital LP (the “Gandy Capital Fund”) and two (2) separately managed
accounts for an unaffiliated investment manager (“Other Accounts,” and together with the Funds are
referred to as “Clients”). The Other Accounts are co-investments by a third party in two holdings of
the fund. Riva Ridge Advisors LLC, a Delaware limited liability company and an affiliate of RRCM serves
as the general partner of the Domestic Fund and the Hornsilver Fund (the “Riva Ridge and Hornsilver
General Partner”) and may be entitled to receive an incentive allocation from such Funds as discussed
below. Riva Pronto Advisors LLC, a Delaware limited liability company and an affiliate of RRCM serves
as the general partner of the Pronto Master Fund (the “Pronto General Partner,” and together with
the Riva Ridge and Hornsilver General Partner, the “General Partners”) and may be entitled to receive
an incentive allocation from such Funds as discussed below.
The interests in the Domestic Fund are offered on a private placement basis, and in reliance on Section
3(c)(7) of the Investment Company Act of 1940, as amended (the “Company Act”), to persons who
are “accredited investors” as defined in Regulation D promulgated under the Securities Act of 1933,
as amended (the “Securities Act”), and “qualified purchasers” as defined under the Company Act,
and
who are subject to certain other conditions, which are set forth in the offering documents for the
Domestic Fund.
Shares in the Overseas Fund are generally offered to persons who are not “U.S. Persons,” as defined
under Regulation S of the Securities Act, or who are tax-exempt U.S. Persons that are “qualified
purchasers” (or entities substantially comprised of such tax-exempt U.S. Persons) on a private
placement basis, and who are subject to certain other conditions, which are fully set forth in the
offering documents for the Overseas Fund.
Stephen Golden and Peter Finelli are the Firm’s portfolio managers. Currently, RRCM has 9 employees,
approximately 7 of whom perform investment advisory functions and none of whom are registered
representatives of a broker-dealer.
B. RRCM provides discretionary investment advisory services. With respect to the Funds, those services
are provided to entities that are pooled investment vehicles through a master-feeder structure. The
Funds’ investment objective is to provide investors with positive absolute returns primarily by
capitalizing on a wide range of opportunities in the universe of distressed and highly leveraged
companies. Preservation of capital is a primary objective of the Funds. The Funds may engage in the
purchase and sale of a broad range of investment interests and securities. RRCM also acts as its own
administrative agent for one of the Other Accounts since it is the sole lender with regard to such Other
Account.
C. Through its employment of a master-feeder structure, RRCM utilizes the same strategy for all of the
Funds, but maintains discretion to tailor its advisory services to the specific needs of a Fund when
deemed necessary.
D. RRCM does not participate in wrap fee programs.
E. As of December 31, 2023, the “regulatory assets under management” that RRCM managed on a
discretionary basis was $606,753,056 and no assets on a non-discretionary basis.