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FORM ADV PART 2A - FIRM BROCHURE
____________________________________________________________________________________
Item 1: Cover Page
DARA CAPITAL US, INC.
1395 Brickell Ave, Suite 800
Miami, Florida 33131
Phone: 646-779-9760
Fax: 646-779-9758
www.daracapital.com
February 26th, 2025
FORM ADV PART 2A
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Dara Capital
US, Inc. If you have any questions about the contents of this brochure, please contact us at
info@daracapital.com. The information in this brochure has not been approved or verified by the
Unites States Securities and Exchange Commission or by any state securities authority.
Additional information about Dara Capital US, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable CRD number of Dara Capital US, Inc. is 153544.
Dara Capital US, Inc. is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level
of skill or training.
The oral and written communications of an adviser provide you with information with which you
determine to hire or retain an adviser.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 2: Material Changes
This item only discusses specific material changes that are made to the brochure and provides clients
with a summary of these changes since our last update of the brochure on February 28th, 2024.
Pursuant to the SEC rules, we will ensure that you receive a summary of any material changes to this
and subsequent brochures within 120 days of the close of the business’ fiscal year. We may further
provide other ongoing disclosure information about material changes as necessary.
We will provide you with a new brochure as necessary based on changes or new information, at any
time, without charge.
Changes to the brochure include, but are not limited to, the following:
• Page 5 - Regulatory assets under management
Currently, this brochure and its supplements may be requested at 646-779-9760 or alternatively, at
info@daracapital.com.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 3: Table of Contents
Item 1
Cover Page
1
Item 2 Material Changes
2
Item 3
Table of Contents
3
Item 4
Advisory Business
4
Item 5
Fees and Compensation
5
Item 6
Performance-Based Fees and Side-by-Side Management
6
Item 7
Types of Clients
6
Item 8 Methods of analysis, Investment Strategies and Risk of Loss
6
Item 9
Disciplinary Information
10
Item 10 Other Financial Industry Activities and Affiliations
10
Item 11 Code of Ethics
11
Item 12 Brokerage Practices
12
Item 13 Review of Accounts
12
Item 14 Client Referrals and Other Compensation
13
Item 15 Custody
13
Item 16
Investment Discretion
13
Item 17 Voting Client Securities
13
Item 18 Financial Information
14
Item 19 Requirements for State-Registered Advisers
14
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 4: Advisory Business
Dara Capital US, Inc. (“Dara Capital”), a Delaware corporation established in November 2008, primarily
provides independent financial advisory services to clients seeking wealth preservation, global
institutional investments and jurisdictional diversification. Dara Capital’s registration as an investment
adviser was granted by the United States Securities and Exchange Commission on June 21, 2010.
Dara Capital is wholly owned by the Swiss corporation, Dara Capital AG (also known as Dara Capital
Ltd.). Mr. Anton Josef Knecht is a principal owner of Dara Capital AG. Dara Capital AG is licensed by
the Swiss Financial Market Supervisory Authority (FINMA), is supervised by the Swiss supervision
organization AOOS (SO AOOS), and is a member of the Swiss Association of Asset Managers. Dara
Capital AG also provides investment advisory and wealth management services to clients. Neither
Dara Capital nor Dara Capital AG are publicly owned or traded.
Dara Capital services are generally provided to sophisticated investors, trusts, charitable and other
tax-exempt organizations, estates, and corporations, including, without limitation, single family
offices (hereinafter the "Client" or "Clients"). Client portfolios may be managed on a discretionary or
non-discretionary basis. Dara Capital also offers storage solutions for physical gold and other metals,
as well as cash notes.
Dara Capital is dedicated to providing comprehensive and tailored advice to multi-jurisdictional
families who require assistance with planning of their foreign estates, management of investments,
philanthropy and family governance structures.
While Dara Capital considers quantitative analysis a prerequisite in making investment decisions,
great emphasis is placed on qualitative analysis of managers and their human capital. Dara Capital's
investment team holds regular calls and convenes periodic face-to-face meetings with Clients during
which the respective portfolios are reviewed. Tactical asset allocation changes might be suggested,
and buy and sell decisions may be made jointly with the Client. Even in the rare circumstance that a
Client has opted for a discretionary management mandate, Dara Capital would typically inform the
Client about material changes to the portfolio prior to implementation of such changes.
Since custodians and fund administrators of each Client might have different processes and execution
policies, the same investment decisions made with respect to Client portfolios may result in
performance and Net Asset Value (“NAV”) calculations at variance (higher or lower).
Dara Capital tailors its advisory services to the individual needs of its Clients, whether investments or
storage solutions. Each Client’s portfolio is tailor-made and structured in accordance with the Client's
specific circumstances, emphasizing objectivity, transparency, sound risk management and broader
diversification. Our tailored portfolios generally aim at keeping downside volatility low while
attempting to deliver high, single-digit returns.
Clients may impose restrictions on investing in certain securities or types of securities. Dara Capital
does not participate in any wrap fee programs.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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As of December 31, 2024, Dara Capital US, Inc. had approximately $515,850,000 in regulatory assets
under management, the majority of which were managed on a non-discretionary basis.
Item 5: Fees and Compensation
Clients may pay fixed, flat or performance fees to Dara Capital for investment advisory services:
• The fixed annual advisory fee usually ranges between 0.6% (60 bps) and 2.0% (200 bps) of the
Client’s assets under advisement, a minimum fee applies. These fees are determined on a non-
linear, sliding scale in accordance with the size of the portfolio and may be negotiable;
• A flat advisory fee may be negotiated; and
• For information on performance–based fees, please see Item 6 Performance-Based Fees and
Side-by-Side Management.
Fixed and flat fees are generally payable quarterly in arrears. Dara Capital typically bills the Clients for
the fees incurred. The Clients may, however, authorize fees to be calculated (or confirmed) and paid
by Custodians from a Client’s custodial account.
The investment managers of funds in which a Client invests also usually charge management and
performance fees and the funds may charge other expenses. Dara Capital does not participate in any
portion of those fees.
The Clients may incur transaction fees or commissions from broker-dealers through which investments
are purchased or sold. Custodians and broker-dealers keep all such fees and commissions, and Dara
Capital does not participate in any portion of those fees. With regard to brokerage relationships, please
see Item 12 Brokerage Transactions.
Any commissions, discounts or soft dollars paid to Dara by third party financial intermediaries with
respect to the Portfolio(s), if any, will be credited to the Client’s custody account.
Under no circumstances does Dara Capital require or solicit fees in advance of service.
Dara Capital receives no compensation based on product sale or recommendations. Clients have the
option to purchase investment products that Dara Capital may recommend through any broker of their
choice, including any agents that are not affiliated with Dara Capital. Dara Capital offers no brokerage
services.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 6: Performance-Based Fees and Side-by-Side Management
Depending on negotiations with the Client, an annual performance fee with or without a hurdle rate
can be charged on top of the annual (fixed or flat) advisory fee (please see Item 5: Fees and
Compensation). Performance fees typically range from 5 to 20% of the appreciation in the NAV of the
portfolio as of the last business day of the current calendar year over and above the previous NAV
achieved on the last business day of the preceding calendar year (or with respect to the first year of
an investment advisory agreement with a Client, the first business day following the signing of the
agreement). If a Client has negotiated a hurdle rate, a performance fee can only be charged if the
annual performance is at or above the predefined hurdle rate. The hurdle rate is reset at calendar
year end (no carry forward).
Item 7: Types of Clients
Dara Capital’s Clients are generally sophisticated investors, trusts, charitable and other tax-exempt
organizations, estates, and corporations, including both single and multi-family offices.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Dara Capital employs both fundamental and technical analysis. The investment strategies used to
implement the investment advice given by Dara Capital to its Clients include primarily:
•
long term purchases (securities held at least a year)
short term purchases (securities held less than a year)
short sales
•
•
• margin transactions (futures contracts) and
• option writing, including covered options, uncovered options or spreading strategies.
Fundamental analysis involves determining the value of a particular security by analyzing the financial
data that is 'fundamental' or basic to the issuer, including, without limitation, its earnings, its
dividends, and its sales. It does not, however, take into account, variations in the market that could
affect the value of the security, which poses a risk when using such analysis.
Technical analysis, on the other hand, involves the analysis of the direction of security prices through
the study of past market data. This analysis, however, does not take into account individual company
statistics, which could materially affect a security’s price, regardless of market trends.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Dara Capital offers investment advice on:
• Equity securities (exchange-listed securities, securities traded over the counter and foreign
issuers)
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Mutual fund shares
• United States government securities
• Options contracts on securities and commodities
• Futures contracts on intangibles, and
•
Interests in partnerships
• Alternative Investments
Subject to client needs, Dara Capital tends to implement the investment strategies through
alternative investments. Consequently, the selected investments are often structured in the form
of established fund vehicles, such as limited partnerships and limited liability companies.
Dara Capital also places special emphasis on objectivity, sound diversification and risk management
in order to protect its clients’ wealth. Assessment of risks and money managers’ integrity is at the
center of our due diligence process. Dara Capital invests in money managers who are independent
and have a proven track record. Portfolio construction aims to preserve the long-term purchasing
power and to provide diversification of risk. Dara Capital is committed to keeping downside
volatility low and strives for consistent, positive risk-adjusted absolute portfolio returns, regardless
of market conditions. More volatile assets offer greater opportunity but carry greater risks.
Combining asset classes and investments with different volatility characteristics and correlation
enables us to reduce risks and provide for greater diversification.
Superior knowledge of, and strong relationships with the world’s leading money managers often
enables Dara Capital to have access to rare co-investment opportunities. Dara Capital sets clear
return, liquidity, risk and correlation objectives for each money manager. These drive the strategic
weight and tactical allocations. While quantitative analysis is a prerequisite, Dara Capital places great
emphasis on qualitative analysis of money managers and their human capital.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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EXPLANATION OF RISK – As a principal rule, Dara Capital explains to its Clients prior to entering into
a new investment advisory mandate the risks associated with the purchase, sale and dealing in
securities and alternative investments. It is important to understand that investing in general
involves risk of loss that Clients should consider well and be prepared to bear. Along with the
obvious risk of loss of principal, there are a number of significant risks associated with Dara Capital’s
investment approach. These risks include, but are not limited to:
• Equity Investing Risks: Equity risk is the risk that the value of equity will fall due to general
market dislocations or economic conditions, perceptions of the industry, or company specific
circumstances
• Fixed Investing Risks: Fixed income investing value may fall due to interest rate movement
and specific issuer’s inability to pay its obligations due to unforeseen circumstances
• Country Risks: Country risk can arise if a country restricts securities trading, for instance by
imposing economic sanctions or currency restrictions
•
• Currency Risks: The possibility that returns could be reduced for Americans investing into
foreign securities because of a rise in the value of the US dollar against foreign currencies
• Settlement Risks: A settlement risk occurs when you have to pay the purchase price of a
security in advance but do not actually receive the security until later. In this event, the risk
is that you will pay the purchase price and receive the securities late or even not at all.
Conversely, when you are obliged to deliver securities that you have sold, you may not
simultaneously receive the purchase price from the buyer
Liquidity Risks: Liquidity risk is the risk that you will not always be able to obtain an
appropriate price for your investment when you sell it. When certain securities and
derivatives are impossible to sell, or can only be sold with difficulty and at a sharply reduced
price, the market is said to be illiquid. Illiquidity risk occurs especially with shares in unlisted
or poorly capitalized companies, investments with sales restrictions, and certain structured
products
Given Dara Capital’s strong bias toward hedge funds, you should also pay additional attention to the
risks associated with such investments in alternative (non-traditional) investments and investments
into emerging or developing markets:
With regard to alternative or non-traditional investments, you must be aware that hedge funds do
not necessarily have anything to do with hedging. Indeed, they take on sometimes very high levels of
risk in order to obtain an above-average return. Hedge funds include all forms of investment funds,
investment companies and partnerships that use derivatives not just for hedging but also for
investment, that are able to engage in short selling or take on leverage by borrowing. Other features
typical of hedge funds include their freedom to choose their asset classes, markets (including
emerging markets) and trading methods. Hedge funds normally require high minimum investments.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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They frequently offer only limited opportunities for subscription and redemption with longer notice
periods. The portfolio managers of hedge funds receive performance-related bonuses and often align
their interests with your interests by holding a personal stake in the funds. You must pay special
attention to the following: A hedge fund may be less transparent than a traditional investment fund,
and they are not subject to any disclosure requirements. Unlike traditional collective investments,
hedge funds have limited liquidity (units may generally only be redeemed once a month, quarterly or
annually). Normally, investors can only invest in a hedge fund at specific times. There are generally
longer notice periods for redemptions and some of the Hedge Funds might have long lock-up periods
(periods during which investors are obliged to leave their capital in the fund).
If the Client requires an individual explanation, or fails to understand risks as they are outlined in the
information provided, the Client may ask Dara Capital for further explanation.
While Dara Capital will endeavor to moderate and minimize these risks, there can be no assurance
that its investment advisory services will be successful or that Clients will not suffer losses.
This brochure does not deal with the issues of taxation or any other legal consequences pertaining to
securities transactions. We advise you to look into these matters yourself or obtain professional
advice.
Dara Capital is fully committed to providing investment advisory services that are tailored to meet
the requirements of each Client within the context of their total wealth. Our ability to do so,
however, depends also on the willingness of the Client to share with and to provide Dara Capital
access to such information. If the Client is not willing to reveal all the information needed, it runs the
risk that Dara Capital might be unable to ensure that suggested and implemented investment
strategies are suitable for the Client’s individual circumstances. This is because various types of risk
or risk concentration may arise, particularly due to directional investments or unsuitable investment
combinations. In the absence of the relevant Client information, Dara Capital is unable to identify,
calculate or control such risks.
Dara Capital’s main sources of information for its investment research are:
Industry conferences
• Annual reports, prospectuses, filings with the Securities and Exchange Commission
•
• Financial websites, newspapers and magazines
• On-site meetings and inspections of asset manager offices and activities, and
• Press releases.
In addition to the aforementioned sources of information, Dara Capital also receives information from
large international Single-Family Offices and other sophisticated investors, all being members of
private global family office networks. The dissemination of information on money managers and co-
investment opportunities is a transparent and unbiased resource for future investment suggestions.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of the adviser or the integrity of the
adviser’s management.
Dara Capital has no legal or disciplinary events to disclose.
Item 10: Other Financial Industry Activities and Affiliations
Wealth Advisory - As already mentioned under Item 4 Advisory Business, besides its core investment
business and to a lesser degree, Dara Capital provides comprehensive and tailored advice to families
with multi-jurisdictional backgrounds, who require assistance with planning of their foreign estates
and investments, philanthropy and family governance structures. Typically, cases involve European
families who have members living in the US or vice versa, or European families who own or are
considering acquiring assets in the US.
Fees for the provision of Wealth Advisory Services are negotiated on a case-by-case basis, dependent
upon the nature, activity and complexity of the mandate involved. Generally, such services are charges
at an annual fixed fee, excluding expenses and sundry charges, e.g. other third-party charges, payable
quarterly in arrears. Please see Item 5 Fees and Compensation.
Some of Dara Capital’s directors, executive officers and employees are also directors, officers or
employees of our parent, Dara Capital AG. As a result, the potential for a conflict of interest exists
between the obligations to Dara Capital’s U.S. clients and the incentive to take actions that benefit
Dara Capital AG and such other organizations. There may also be conflicts between Dara Capital and
each of Dara Capital AG and such other organizations with respect to the allocation of resources and
time. Each of Dara Capital’s directors, executive officers and employees who provide services to Dara
Capital’s clients are considered “associated persons” of Dara Capital as that term is defined in the
Advisers Act for purposes of Dara Capital’s required supervision and have agreed to submit to the
jurisdiction of the SEC and to the jurisdiction of the U.S. courts for actions arising under the U.S.
securities laws in connection with the investment advisory services they provide for any of Dara
Capital’s clients. We believe these potential conflicts are mitigated because of the foregoing, as well
as the fact that our executive officers and employees and those of Dara Capital AG that provide
investment advisory services to any of Dara Capital’s clients are subject to Dara Capital’s Code of Ethics
and various policies that require these executive officers and employees to act in the best interests of
Dara Capital’s clients and to put the needs of its clients first at all times.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Dara Capital has adopted a Code of Ethics (the “Code”) consistent with the requirements of Rule 204A-
1 of the Investment Advisers Act of 1940, as amended. The purpose of the Dara Capital Code of Ethics
is to establish standards of conduct expected of its employees and reflect Dara Capital’s fiduciary
responsibilities and duties to its Clients. All employees are required to acknowledge in writing the
receipt of the Code and their agreement to comply with the Code procedures and provisions.
The objectives of the Code are primarily to protect Dara Capital’s Clients, but also to educate and
remind Dara Capital’s employees of their position of trust, and to guard against violations of securities
laws and establish verification procedures. Implicitly stated in the Code of Ethics is the recognition
that as investment adviser, we are fiduciaries and, consequently we have the responsibilities to render
professional, continuous and unbiased advice, acting at all times in the Client’s best interests and
avoiding even the appearance of a conflict of interest.
More specifically Dara Capital’s Code of Ethics covers the following areas:
• Employee personal security transactions and holdings
• Policies and procedures designed to detect and prevent insider trading
• Compliance with federal securities laws
• Protecting confidentiality of Client information
• Sanctions and reporting of violations
• Gifts and entertainment
Please contact us at info@daracapital.com should you wish to review a complete copy of Dara
Capital’s Code of Ethics.
Participation or Interest in Client Transactions
It is not a general practice to recommend a Client purchase or sale of securities in which Dara Capital or a
related person has an interest. Recommendations for Clients are based upon the perceived advantage or
disadvantages of the security in relation to the Client’s investment situation and objectives, and upon
economic, financial, social and other factors bearing on its value and on the valuation of alternatives.
Recommendations are not withheld and Client transactions are not forestalled because Dara Capital or a
related person may have a direct or indirect interest in the security.
All personnel transacting for personal accounts are restricted according to a stated policy regarding
employee personal investments. A record of all such investments must be maintained and reviewed
periodically. Any transactions must be carried out in a manner that does not work to the disadvantage
of Clients’ transactions or result in a conflict of interest, or even the appearance of a conflict of
interest.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 12: Brokerage Practices
Investments under non-discretionary mandates are reviewed and agreed upon jointly by the Client
and Dara Capital before initiating the transactions. Clients in general would choose from among their
own brokerage or banking relationships to effectuate the trades. Dara Capital may choose the broker
or dealer to be used for a purchase or sale of securities for a client’s account under discretionary
mandates.
Dara Capital does not generally recommend any particular broker-dealer or bank, except when a
recommendation is requested by a Client or prospective Client. In such cases, Dara Capital will
recommend a short list of highly reputable brokers and banks. Dara Capital will also consult with
clients about best execution. Dara Capital typically does not receive any commission, soft dollars,
client referrals or any other benefits from recommending a particular broker-dealer. However, any
commissions, discounts or soft dollars paid to Dara Capital by third party financial intermediaries with
respect to the Portfolio(s) will be credited to the Client’s custody account. To the extent that Dara
Capital utilizes research and other services obtained from broker-dealers on a soft dollar commission
basis, it does so in compliance with the safe harbor of Section 28(e) of the Securities Exchange Act of
1934, as amended.
Dara Capital’s policy is to aggregate Client transactions where possible and when advantageous to
Clients. In these instances, Clients participating in any aggregated transactions will receive an average
share price and transaction costs will be shared equally on a pro‐rata basis. The aggregation of Client
purchase or sale orders into blocks for execution allows Dara Capital to achieve more equitable, timely
and efficient executions, lower brokerage cost and better and fairer prices. Dara Capital’s allocation
procedures will be fair and equitable to all Clients with no particular group or Client(s) being favored
or disfavored over any other Clients, unless where deviation is required in order to have a new Client
fully invested as promptly as possible.
Item 13: Review of Accounts
Every Client account is assigned to an investment manager whose responsibility it is to review the
account on a routine basis. Additional reviews may depend on market developments, changes in Client
circumstances, or other factors. Each Client portfolio is structured differently. All accounts are
reviewed to ensure compliance with Dara Capital’s investment strategy and the Clients’ investment
objectives and restrictions, as well as performance and asset allocation of the Portfolio. Currently, two
portfolio managers are actively managing all Client accounts.
Frequent reviews may be triggered by market changes in variables such as the Client’s individual
circumstances, or the global macro environment. Portfolio appraisals are customarily furnished to
Clients on at least a quarterly basis. Different cycles are available upon a Client‘s request.
Clients receive regular written updates on their accounts and the markets through emails, letters,
portfolio review summaries and written quarterly reports. Dara Capital also consults with clients in
person and by phone.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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Item 14: Client Referrals and Other Compensation
Dara Capital does not have any oral or written arrangements to receive cash or economic benefits
(including fees, equipment or non‐research) from third parties in connection with giving advice to
Clients.
Dara Capital may have arrangements to directly or indirectly compensate third parties for Client
referrals, paying fees of up to 50% of gross fees received from Clients. At present, Dara Capital has
three such agreement in place. Clients for which a referral fee is payable would be so informed upon
engagement of Dara Capital.
Item 15: Custody
Neither Dara Capital nor any of its related persons has custody over the Clients’ securities, cash or
bank accounts. The Clients choose the custodians they wish to use. Custodians will send account
statements quarterly, or more frequently, directly to the Clients. Dara Capital strongly encourages its
Clients to carefully review account statements received from their custodians and compare the
information reported on the account statements to any information reported on quarterly statements
or reports Dara Capital may provide.
Item 16: Investment Discretion
Dara Capital is typically retained on a non-discretionary basis. Consequently, all investments for such
Clients are reviewed and agreed upon jointly by the Client and Dara Capital before initiating the
transactions.
When Dara Capital is retained on a fully discretionary basis or with limited discretionary authority (for
instance, the authority to only trade without prior Client approvals based on specific signals received
from a particular trading program), then Dara Capital can enter trades with the Client’s broker based
on the authority granted.
Custodians and brokers will generally require a limited power of attorney granted to Dara Capital by
the Client.
Clients in general would use existing custodial and brokerage relationships to effectuate the trades,
but Dara Capital would typically provide a short list of custodians/brokers without stating any further
preferences if a Client asked for some recommendations.
Item 17: Voting Client Securities
Unless the power to vote proxies for a Client is delegated to Dara Capital and the Client has explicitly
asked us to vote, Dara Capital will not be responsible for voting the proxies related to that Client’s
account. It is the responsibility of the Client to instruct the relevant custodian bank or banks to mail
proxy material directly to such Client. In the rare circumstance where Dara Capital may acquire the
right to vote proxies with respect to the securities in which the Client invests and with respect to
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securities for which it executes trades on behalf of Client, Dara Capital will exercise such voting
authority in accordance with established policies and procedures set forth in Dara Capital’s
Compliance Manual. If Dara Capital acquires the right to vote proxies, the adopted policies and
procedures are reasonably designed to result in proxies being voted in the best interest of our Client
and in accordance with our fiduciary duties and applicable regulations. Generally, Dara Capital will
vote proxies so as to promote the long-term economic value of the underlying securities held by the
Client. Each proxy proposal shall be considered on its own merits, and an independent determination
shall be made whether to support or oppose management’s position.
If a Client has not delegated the power to vote proxies to Dara Capital, that Client may direct Dara
Capital to vote in a particular manner at any time upon written notice to Dara Capital. In those
circumstances, Dara Capital will comply with specific Client directions to vote proxies.
If Dara Capital exercises voting authority with respect to its Client, the Client may at any time make a
written or oral request for information on how the Firm voted proxies on his or her behalf. Dara Capital
must make and retain:
• A copy of each proxy statement that Dara Capital receives,
• A record of each vote cast by Dara Capital on behalf of the Client,
• A copy of any document created by Dara Capital that was material to making a decision on
how to vote proxies on behalf of a Client, and
• A copy of each written Client request for information on how Dara Capital voted proxies on
behalf of the Client and a copy of any written response by Dara Capital to any (written or oral)
Client request for information.
Any Client may obtain a copy of Dara Capital’s proxy voting policies and procedures upon request.
Please contact us at info@daracapital.com should you wish a copy of Dara Capital’s proxy voting
policies and procedures.
Item 18: Financial Information
We do not require or solicit any prepayment in advance and therefore have not included a balance
sheet. We have no financial condition that is reasonably likely to impair our ability to meet contractual
commitments, nor have we been the subject of any bankruptcy petition.
Item 19: Requirements for State-Registered Advisers
Not applicable.
Dara Capital US, Inc., 1395 Brickell Ave, Suite 800, Miami, Florida 33131
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