Apogem Capital LLC

Business, clients and compensation, as filed

Advisory activities

portfolio management for individuals and small businesses, portfolio management for pooled investment vehicles, portfolio management for businesses and institutional clients, selection of other advisers and other advisory activities

Compensated by

a percentage of assets under management, fixed fees and performance-based fees

Client types

high net worth individuals (1); investment companies (1); pooled investment vehicles (137); charitable organizations (1); insurance companies (3); corporations or other businesses (1)

Also engaged as

registered representative of a broker-dealer and commodity pool operator or commodity trading advisor

Related persons include

a broker-dealer, another investment adviser, a commodity pool operator or commodity trading advisor, a trust company, an insurance company or agency, a pension consultant, a sponsor or syndicator of limited partnerships and a sponsor, general partner or managing member of pooled investment vehicles

Affiliates

2 broker-dealers, 15 investment advisers

Form ADV Item 11 disclosures

The firm answered yes to the following Item 11 questions. The answers cover the firm and its advisory affiliates; the Disclosure Reporting Pages on IAPD identify the subject and the outcome.

• SEC or CFTC finding of a false statement or omission (Item 11C(1))
• SEC or CFTC finding of a violation of regulations or statutes (Item 11C(2))
• SEC or CFTC order against the firm or an affiliate (Item 11C(4))
• SEC or CFTC civil money penalty or cease-and-desist (Item 11C(5))
• other regulator finding of a violation (Item 11D(2), 6 reported)
• other regulator order, denial, suspension or revocation (Item 11D(4), 6 reported)
• civil court finding of a violation (Item 11H(1)(b))