A. General Description of Advisory Firm.
Steele Creek Investment Management LLC (“Steele Creek”, “Firm”, or “we/us/our”) is a
registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) based
in Charlotte, North Carolina. Our investment advisory firm was founded in 2013 as a subsidiary
of Moelis & Company Holdings LP. In April 2014, Moelis & Company Holdings LP spun off
from Moelis & Company during its initial public offering and changed its name to Moelis Asset
Management LP.
Steele Creek is owned by Moelis Asset Management LP and is indirectly owned by Kenneth
Moelis.
Steele Creek has advisory affiliates registered with the SEC, Freeport Financial Partners LLC,
P&S Credit Management, L.P. and Moelis Capital Partners LLC and an exempt reporting advisor
affiliate, Moelis Asset Catalyst Partners LLC. Moelis Asset Management LP also has a joint
venture with Veritable LP, Archean Capital Partners II, LLC, which is also SEC registered and a
joint venture with CoVenture Holding Company LLC, Crossbeam Venture Partners LLC.
As used in this brochure:
• “We/us/our/Steele Creek” refers to Steele Creek Investment Management LLC and its
investment advisory business
• the “Moelis BD” refers to Moelis & Company LLC;
• “MAM” refers to Moelis Asset Management LP;
• the “CLO Funds” or “CLO Fund” refers to the CLO funds or warehouses, or one of
them, named: Steele Creek CLO 2014-1R, Ltd, , Ltd, Steele Creek CLO 2016-1, Ltd,
Steele Creek CLO 2017-1, Ltd, Steele Creek CLO 2018-1, Steele Creek CLO 2018-2,
Ltd, Steele Creek CLO 2019-1, Ltd, Steele Creek CLO 2019-2, Ltd, Steele Creek CLO
2022-1, and Steele Creek CLO 2022-2, Ltd each a Cayman Islands corporation, and
their respective co-Issuers, , Steele Creek CLO 2016-1, LLC, Steele Creek CLO 2017-1,
LLC, Steele Creek CLO 2014-1R, LLC, Steele Creek CLO 2018-1, LLC, Steele Creek
CLO 2018-2, Steele Creek CLO 2019-1, LLC, Steele Creek CLO 2019-2, LLC, Steele
Creek CLO 2022-1, LLC and Steele Creek CLO 2022-2, LLC each a Delaware limited
liability company;
• the “BSL Fund” refers to Steele Creek Loan Fund I LP, a private fund and its fully
owned leverage vehicle, Steele Creek Loan Fund I, LLC;
• the “BDC” refers to Steele Creek Capital Corporation, a Maryland business
development company and its fully owned leverage vehicle, Steele Creek Capital
Funding I, LLC;
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• the “Fund” or “Funds” refers to the CLO Funds, the BDC and the BSL Fund
collectively;
• the “Steele Creek clients” and “its clients” refer to the Funds; and
• the “Fund Investors” refer to underlying investors in the CLO Funds.
B. Description of Advisory Services (including any specializations)
Steele Creek provides certain investment advisory services and certain administrative functions
to the Funds, primarily investing in broadly syndicated loans. Our business focuses on
acquisition, execution, management, and redemption of loans. The BDC may also
invest in
certain instruments that are not suitable for the CLO Funds. We intend to launch other CLO
funds in the upcoming year(s). Steele Creek may also provide investment services to additional
private funds.
C. Availability of Tailored Services for Individual Clients
We provide active investment management services for our Funds. Our services include the
following:
• Establish “warehouse” facilities that will be used to seed CLO Funds. A CLO entity will
purchase a portfolio of loans (or acquire the risk of loss on a loan portfolio pursuant to a
derivative contract) before it issues securities; these transactions (and the financing for
them) are known as “warehousing” and the CLO Fund is thus known as the “warehouse”
prior to securities issuance.
• Structure, negotiate, document, and market CLO Funds.
• Provide the Trustee of the CLO Funds (the Administrator) with accurate and timely
information and reconcile all reports produced by the Trustee to ensure proper reporting
and investor distributions.
• Purchase loans and other investments for the BDC.
• Active portfolio management including selecting, underwriting, monitoring, and
realization of each Fund investment.
• Manage the Funds to ensure compliance with investor’s objectives and constraints, and
Governing Agreement (as defined below) guidelines.
The relationship between us and each Fund is governed by the Fund documents. In the case of
the CLO Funds, this includes an indenture and a collateral management agreement between us
and each CLO Fund (the “CLO Governing Agreements”). In the case of the BSL Fund, this
includes the limited partnership agreement and other documents (the “BSL Governing
Agreements”). In the case of the BDC, this includes the private placement memorandum
(“PPM”) and public filings (the “BDC Governing Documents”) (collectively, the CLO
Governing Agreements, the BSL Governing Agreements and the BDC Governing Documents
shall be referred to as the “Governing Agreements”) Investments in a CLO Fund are privately
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offered only to qualified purchasers, typically institutional investors, through a placement agent
with a broker dealer; the BSL Fund was offered to qualified purchasers. The BDC is privately
offered to accredited investors through our relationship with S2K Financial, LLC a registered
broker dealer.
As a registered investment adviser with the Securities Exchange Commission, the relationship
between us and each Fund is governed by the Investment Advisers Act of 1940, as amended.
The Funds primarily participate in non-investment grade, high yield senior loans. Other portfolio
investments may include limited second lien and unsecured loans. The investment advice we
provide is limited to portfolio management services provided to the Funds.
D. Client Assets Under Management.
As of December 31, 2023 our regulatory assets under management are approximately
$3,017,087,043 across our eleven Funds.