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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
Prairie Capital Management
Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101 Main
(800) 385-9406 Toll Free
(816) 960-4806 Fax
www.prairiecapital.com
March 31, 2025
is available on
This brochure provides information about the qualifications and business practices of Prairie Capital
Management Group, LLC. If you have any questions about the contents of this brochure, please contact
us at (816) 531-1101. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority. The terms “registered
investment adviser” or “registered” does not imply any level of skill or training. Additional information
about Prairie Capital Management Group, LLC.
the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Material Changes
We updated our regulatory assets under management and assets under advisement as of December 31,
2024. See Item 4, Advisory Business.
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................. 1
Item 2: Material Changes ........................................................................................................................................ 2
Item 3: Table of Contents ........................................................................................................................................ 2
Item 4: Advisory Business ....................................................................................................................................... 3
Item 5: Fees and Compensation ............................................................................................................................. 5
Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................... 9
Item 7: Types of Clients ......................................................................................................................................... 12
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................................... 12
Item 9: Disciplinary Information ............................................................................................................................ 20
Item 10: Other Financial Industry Activities and Affiliations .................................................................................. 20
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 24
Item 12: Brokerage Practices ................................................................................................................................ 25
Item 13: Review of Accounts ................................................................................................................................. 26
Item 14: Client Referrals and Other Compensation .............................................................................................. 27
Item 15: Custody................................................................................................................................................... 28
Item 16: Investment Discretion ............................................................................................................................. 29
Item 17: Voting Client Securities ........................................................................................................................... 30
Item 18: Financial Information ............................................................................................................................. 30
Item 4: Advisory Business
Prairie Capital Management Group, LLC (“Prairie Capital”) is part of the Focus Financial Partners, LLC (“Focus
LLC”) partnership. Specifically, Prairie Capital Management Group, LLC is a wholly-owned subsidiary of Focus
Operating, LLC (“Focus Operating”),1 which is, directly and indirectly, a wholly-owned subsidiary of Focus
LLC. Focus Financial Partners Inc. (“Focus Inc.”) is the sole managing member of Focus LLC and has 100% of
its governance rights. Accordingly, all governance is conducted through the voting rights and the Board of
Directors at Focus Inc. Focus Inc. is the managing member of and owns, directly and indirectly, approximately
99% of the economic interests in Focus LLC.
Prairie Capital is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Prairie Capital
is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member
of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP
Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles
affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital
LLC (“Stone Point”) are indirect owners of Focus LLC. Because Prairie Capital is an indirect, wholly-owned
subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Prairie Capital.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers,
and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or
investment companies as disclosed on their respective Form ADVs.
Prairie Capital is managed by Brian Kaufman, Curtis Krizek, Robyn Schneider, Michael Gentry, and Andrew
Klocke (“Prairie Capital Principals”) pursuant to a management agreement between Main Street 25
Management, LLC and Prairie Capital. The Prairie Capital Principals serve as officers of Prairie Capital and
are responsible for the management, supervision and oversight of Prairie Capital.
Prairie Capital provides the following asset consulting services as investment supervisory services: (a)
origination of investment policy statement and asset allocation study, search for managers or mutual
funds in accordance with criteria established by client, ongoing performance monitoring and analysis;
and (b) management of investment advisory accounts on a non-discretionary basis with the investment
objective of income for fixed income portfolios and the objective of long term capital appreciation for
equity portfolios. Prairie Capital does not directly invest the assets of the clients.
In addition, Prairie Capital, manages investment advisory accounts not involving investment supervisory
services by managing investments of limited partnerships. In managing such accounts, Prairie Capital
generally utilizes a multi-manager, multi-strategy investment philosophy pursuant to which it sets asset
allocation parameters, selects investment strategies to be used in the management of client assets and
selects and monitors independent investment advisory firms (or, if appropriate, private or registered
investment companies managed by them) to manage the separate asset classes and strategies used.
There are no restrictions on Prairie Capital’s ability to select asset classes for any particular pooled
account. Thus, Prairie Capital does not directly invest the assets of multi-manager, multi-strategy
accounts.
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Upon evaluating a client’s investment history, present situation, and future outlook, Prairie Capital
constructs a plan designed specifically to meet each client’s goals and objectives within each client’s
defined risk tolerance, risk capacity and return expectation.
4
Prairie Capital is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) with respect to investment management services and investment advice provided to ERISA
plan clients, including plan participants. Prairie Capital is also a fiduciary under section 4975 of the
Internal Revenue Code (the “IRC”) with respect to investment management services and investment
advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants.
As such, Prairie Capital is subject to specific duties and obligations under ERISA and the IRC that include,
among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting
on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary
must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on
us by the federal and state securities laws. As a result, you have certain rights that you cannot waive
or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our
obligations under the federal and state securities laws or as a waiver of any unwaivable rights you
possess.
As of December 31, 2024, Prairie Capital manages $1,732,366,867 client assets on a discretionary basis. the
investment advisory, consulting and other services to many other clients
Firm also provides
whose assets are not included or reflected as part of the Firm’s regulatory assets under management
(in light of the instructions to Part 1A of Form ADV). In addition to the Firm’s regulatory assets
under management, as disclosed in Item 5.F(2) of Form ADV and referenced above, the Firm had
client “assets under advisement” of approximately $3,128,857,741 as of December 31,2024 (which
was computed using a method that is different from the method used to compute our “regulatory
assets under management” for purposes of Item 5.F. in Part 1A).
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its
affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller
discussion of these services and other important information.
We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by
introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our
parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these
services and other important information.
Item 5: Fees and Compensation
Clients participating in the asset consulting service are required to enter into an investment advisory
agreement (“agreement”). This agreement may be terminated at will upon written notice by either
party to the other and termination will become effective upon receipt of such notice. Termination shall
not affect any liability resulting from transactions initiated before Prairie Capital receives written notice
of termination. Upon termination of agreement, any fees paid in advance will be prorated, and the client
will be entitled to a refund from the date of termination through the end of the billing period. To the
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extent that there are amounts owed by client to Prairie Capital upon the date of termination of the
agreement, the client will immediately pay such amounts to Prairie Capital without further notice or
demand. Clients shall have the right to terminate the agreement, without penalty, within five business
days of the date of execution of this agreement by client and to receive a full refund of all amounts paid
in advance to Prairie Capital.
Investment advisory services are generally provided for a fee based on a percentage of the assets under
management as follows:
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Assets under Management
$0 to $10,000,000
$10,000,001 to $25,000,000
$25,000,001 to $50,000,000
$50,000,001 to $100,000,000
$100,000,001 plus
Fee
0.80% - 1.00%
0.65% - 0.80%
0.50% - 0.65%
0.35% - 0.50%
0.20% - 0.35%
Generally, a minimum annual fee of $30,000 will apply to all accounts. These fees are guidelines only
and are subject to negotiation with each client. The fee is calculated by applying the applicable schedule
of fees to the value of assets under management on the last day of each calendar month or quarter,
whichever is applicable.
Investment advisory services may be provided to Clients for a flat quarterly or monthly fee based on a
combination of factors; including, but not limited to, the total assets under management and the
specific advisory services provided to the client. The flat fee is reviewed with the client periodically and
adjusted according to mutual agreement between Prairie Capital and the client.
Certain asset consulting services may be provided on a fixed-fee basis. For example, the origination of
an investment policy statement and asset allocation study and a manager search may be performed on
a fixed-fee basis. Some of these fixed fees may be payable in addition to the fees based on a percentage
of assets under management. The fees will be based on the extent of efforts involved in the asset
consulting services determined by the requests of the client, and thus will be determined pursuant to
negotiations between Prairie Capital and the client.
Investment advisory services are provided to clients for performance based fees. These fees are
typically based on a share of capital gains on or capital appreciation of the assets of a client. Additional
information regarding performance based fees may be found in Item 6.
On a case-by-case basis, certain asset consulting services may be provided on the basis of hourly
charges upon request of a client.
Prairie Capital’s fee is typically billed to and paid by the client’s custodian(s) from the assets of the
client’s portfolio. The client may request to be billed directly. Direct bills are due upon receipt. Fees are
calculated and payable either monthly or quarterly pursuant to the Agreement with client.
In addition to our fees, clients are responsible for the fees and expenses associated with the investment
of their assets, such as the fees and expenses of mutual funds, ETFs and other pooled investment
products held in the client’s account, transaction fees, taxes and other brokerage charges for purchases
and sales of investments and custodial fees for holding and safekeeping of client assets.
Prairie Capital’s fee could be avoided if the client invested directly in investment vehicles managed by
third parties but would not receive Prairie Capital’s advice regarding the allocation of assets in the
client’s portfolios.
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We offer clients the option of obtaining certain financial solutions from unaffiliated third-party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and
its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners, LLC (“Focus”)
is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such
third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits
UPTIQ Inc.’s investors, including Focus, our parent company. When legally permissible, UPTIQ also
shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For
non-residential mortgage loans made to our clients, UPTIQ will share with FSH up to 25% of all
revenue it receives from such third-party financial institutions. For securities-backed lines of credit
(“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from
such third-party financial institutions. For cash management products and services provided to our
clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial
institutions and other intermediaries that provide administrative and settlement services in
connection with this program. As noted above, Flourish facilitates cash management solutions for
our clients. When legally permissible, Flourish pays FSH a revenue share of up to 0.10% of the total
amount of cash held in Flourish cash accounts by our clients. This earned revenue is indirectly paid
by our clients through an increased interest rate charged by the third-party financial institutions or,
for cash balances, a lowered yield. FSH distributes this revenue to us when we are licensed to receive
such revenue (or when no such license is required) and the distribution is not otherwise legally
prohibited. Further information on this conflict of interest is available in Item 10 of this Brochure.
We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by
introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our
parent company, Focus Financial Partners, LLC. FRS has arrangements with certain third-party
insurance brokers (the “Brokers”) under which the Brokers assist our clients with regulated insurance
sales activity. If FRS refers one of our clients to a Broker and there is a subsequent purchase of insurance
through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions paid to
the Broker by the insurance carrier with which the policy was placed. The amount of revenue earned
by FRS for the sale of these insurance products will vary over time in response to market conditions.
The amount of insurance commission revenue earned by FRS is considered for purposes of determining
the amount of additional compensation that certain of our financial professionals are entitled to
receive. The amount of revenue earned by FRS for a particular insurance product will also differ from
the amount of revenue earned by FRS for other types of insurance products. Further information on
this conflict of interest is available in Item 10 of this Brochure.
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Item 6: Performance-Based Fees and Side-By-Side Management
Prairie Capital offers performance or incentive based fees. These fees may consist of a lower base fee
with additional fees earned if the client portfolio outperforms its benchmark index. Alternatively, or in
addition, the fee may be based on a share of capital gains on or unrealized appreciation of the assets of
the client. The performance fee is only offered to qualified clients as defined under SEC Rule 205-3. The
fee would be payable quarterly, in arrears, based on a portfolio’s trailing 12- month or other period
performance or gains, either realized or unrealized. Performance based fees create an incentive for the
adviser to enter into riskier or more speculative investments than would otherwise be the case and to
invest more time and energy into investments or clients that have the potential of paying a
performance based fee than clients and investments that do not pay such fees. We address these
conflicts of interest through this disclosure and by remaining mindful of our duties as fiduciaries to our
clients.
The Principals are, among other entities, the owners of Cotton Creek Capital Management, LLC
(“CCCM”), a private fund manager that serves as the general partner of, and provides investment
management, advisory and other services to, Cotton Creek Capital Partners, Ltd., a Texas limited
partnership and private equity fund (“CCCP”) and Cotton Creek Terrace SBS, Ltd., a Texas limited
partnership (“CCTSBS” and, together, “CCCM Funds”). See Item 10.
The Firm or an affiliate or predecessor thereof has in the past recommended, and expects to
recommend in the future, that certain of the Firm’s advisory clients invest in one or more of the
CCCM Funds or other private investment funds formed, sponsored, managed and/or advised by
CCCM, the Firm or affiliates thereof. Because the Principals have financial interests in the CCCM Funds
and the Firm, the Principals and other persons associated or affiliated with the Firm may have
financial or other interests in other private investment funds formed, managed, advised or sponsored
by the Firm or an affiliate, the Firm has or may have a financial or other incentive to recommend that
Firm clients invest in the CCCM Funds and other affiliated pooled investment vehicles and face
conflicts of interest relating thereto. To address this conflict, the Firm provides full and fair disclosure
to its clients (including in the applicable offering materials). Additionally, the Firm’s officers are
mindful of the fiduciary duties they owe to all of their advisory clients.
Affiliates of CCCM (including entities owned or controlled by the Principals) and the Firm are or
may be entitled to receive performance-based allocations and/or carried interest distributions with
respect to the Funds and other entities. Performance-based fees and allocations (including carried
interest distributions) could motivate the Firm and other persons to make investment decisions (or
recommend investments) that are riskier or more speculative than would be the case if these
arrangements were not in effect. The method of calculating carried interest or performance-based
compensation arrangements raises potential conflicts of interest with respect to the management
and disposition of investments, including the sequence of dispositions.
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Differences in the performance-based compensation structures of the Funds may incentivize the Firm
to favor one Fund over another. To address this conflict, the Firm provides up-front disclosures
regarding such compensation conflicts of interest to prospective investors and clients in the offering
and governing documents of each fund. Additionally, the Firm and its employees are mindful of the
fiduciary duties owned to all advisory clients.
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In addition, Prairie Capital manages the portfolios of limited partnerships (collectively hereinafter referred
to as “Flint Hills Funds”) which pay a performance-based fee, in addition to a management fee, to Prairie
Capital.
Flint Hills Funds are fund of funds where a fund pools capital from various investors and then invests in
multiple private equity funds or hedge funds rather than directly in individual companies or assets. Fund
of funds offer access to funds that might be difficult for individual investors to reach due to high minimum
investment requirements or limited availability. Flint Hills funds have a wide range of investment
strategies.
• Activist Strategies: Funds like Activist Strategies L.P. and Elliott Co-Invest L.P. utilize corporate activism to
drive value-creating catalysts
• Co-Investment Funds: Several Funds, such as AEP Co-Invest L.P., Ascent Co-Invest II L.P., Coinvest, and
Spartan Co-Invest L.P. focus on co-investing alongside other funds in specific sectors like energy and
private equity.
• Credit Opportunities: Credit Opportunities II L.P. and its successors invest in small and mid-sized credit
markets, focusing on preservation of capital, current yield, and capital appreciation. In addition SLXII
invests in middle market direct lending credit opportunities.
• Diversified Strategies: Diversified Strategies L.P. and Titan L.P. invest in funds that seek capital
appreciation with low correlation to major equity and fixed income markets, employing a variety of
investment strategies including event driven, relative value, and other trading strategies
• Energy and Minerals: Funds like CEC Opportunity L.P. and EMG Opportunity L.P. invest in energy debt
and equity markets and natural resources
•
Long/Short Equity: Concentrated Global L/S Equity L.P. and Long/Short Equity L.P. invest in funds that
seek capital appreciation, focusing on U.S. and global long/short equity strategies
• Private Equity: Private Equity Funds (III-VI) invest in private equity funds that acquire or form new
businesses, aiming for long-term capital appreciation
• Sector-Specific Funds: Funds like BH New Opportunity 2015 Co-Invest Fund L.P., CGFIV, Cybersecurity
L.P., DOFV, FCCIII, IVYII, MCR Hospitality IV L.P., and MPIV, invest in specific sectors or strategies, such as
real estate, cybersecurity, consumer, hospitality, healthcare, hotel real estate, reinsurance, technology
and midstream infrastructure, respectively
• Growth and Venture Opportunities: Founders L.P. and its successors invest in growth-stage technology
companies and other venture opportunities
The Flint Hills Funds have varying fee structures depending on the specific fund. A general range and
type of fees will be as follows.
• Management Fees: These typically range from 0.50% to 2.00% per annum of the capital
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commitments or contributions of the limited partners.
• Performance-Based Fees: Some funds charge performance-based fees, which can include a
percentage of net profits exceeding a hurdle rate. For example, a common structure is 5% of net
profits exceeding a 5% hurdle rate per annum.
• Administrative Fees: Certain funds also charge administrative fees, which can be around 0.25% of the
aggregate capital commitment or based on actual ongoing expenses.
• Carried Interest: Some funds have carried interest arrangements, where a percentage of the profits
(e.g., 5% to 20%) is allocated to the general partner after limited partners have recovered their capital
contributions and received a preferred return.
These fees are exclusive of the fees and expenses charged by underlying hedge funds, private equity
funds, and other pooled investment vehicles in which the Flint Hills Funds may invest. For further
specific information related to fees please reference the specific fund offering document.
Item 7: Types of Clients
Prairie Capital’s clients include individuals; pension and profit sharing plans; trusts and estates;
charitable organizations; and corporations and other business entities. Clients also include multi-
manager, multi-strategy private investment company partnerships with different investment objectives
and risk/return characteristics, as described above in Item 6.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Prairie Capital’s methods of investment analysis and strategies include; investment charting,
fundamental analysis, technical analysis and cyclical analysis. With respect to accounts managed utilizing
a multi-manager, multi-strategy philosophy, the methods of analysis for recommending managers also
include quarterly analysis of actual performance returns of investment management firms and analysis
of style index performance results. The analytical process also includes direct contact with the
investment management firms, reading their materials describing their philosophy and methodology,
and studying their Forms ADV or other brochures. The final source of analysis involves direct personal
meetings with the individual principals and portfolio managers of the investment management firms.
For multi-manager, multi-strategy accounts, the assets of the client accounts are divided into separate
investment strategy portfolios as determined by Prairie Capital pursuant to its asset allocation process,
to be: (1) invested in registered investment companies, private investment companies or other pooled
accounts managed by different investment management firms (“Portfolio Managers”) selected by
Prairie Capital; and/or (2) invested in separate individual accounts, each managed by different
investment management firms selected by Prairie Capital.
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The remaining parts of Prairie Capital’s strategy
involve monitoring and changing Portfolio
Managers or increasing or reducing allocations. In monitoring the Portfolio Managers, Prairie Capital
will maintain records for each firm and receive both written and oral reports. It is also expected that
Prairie Capital will speak at least once a year with each Portfolio Manager to discuss the progress of
the portfolio. The performance of each Portfolio Manager will be continuously compared with the
performance of other managers utilizing a similar strategy
The success of client’s
investment activities may be affected by general economic and
market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty,
changes in laws and national and international political circumstances. These factors may affect the
level and volatility of securities prices and the liquidity of the client’s investments. Unexpected
volatility or illiquidity could impair the client’s profitability or result in losses.
to
clients
investing
in
these
types
of
All securities investing and trading activities risk the loss of capital. There can be no assurance that the
client’s investment activities will be successful, or the client will not suffer losses. Interests in private
funds are speculative securities and should be considered by clients only if the client can afford the
risk of loss of their entire investment. Private Funds are not subject to the same regulatory and
disclosure requirements as mutual funds and ETFs. Moreover, private placement interests are
generally illiquid and may charge higher fees. Private Funds are offered through an offering
memorandum, which contains detailed information on the various risks and fees relating to the
particular investment. An offering memorandum and accompanying subscription documents will be
provided
securities.
The following discussion sets forth some of the more significant risks associated with Prairie Capital’s,
the Portfolio Manager's and the client’s style of investing:
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Equity Securities
in
invest
The investment programs of Portfolio Managers selected by the client for investment may be
primarily equity-focused. The value of equity securities may fluctuate in response to specific
situations for each company, industry market conditions and general economic environments.
Portfolio Managers may acquire
listed and unlisted common
long and short positions
equities, preferred equities and convertible securities of issuers domiciled in developed or in
emerging countries. (See "Non-U.S. Investments" below.) Portfolio Managers may
in
equity securities regardless of market capitalization, including micro and small cap companies.
The securities of smaller companies may involve more risk and their prices may be subject to more
volatility. Portfolio Managers may also invest in distressed equity securities, which are generally
considered to be more risky, speculative and less liquid.
Short Selling
The Portfolio Managers with which the assets of the client are invested will engage in short selling.
Short selling involves selling securities which may or may not be owned and borrowing the same
securities for delivery to the purchaser, with an obligation to replace the borrowed securities at a later
date. Short selling allows the investor to profit from declines in securities. A short sale creates the risk
of a theoretically unlimited loss, in that the price of the underlying security could theoretically increase
without limit, thus increasing the cost of buying those securities to cover the short position. There can
be no assurance that the security necessary to cover a short position will be available for purchase.
Purchasing securities to close out the short position can itself cause the price of the securities to
rise further, thereby exacerbating the loss.
Investments Are Leveraged
The investment vehicles we recommend or select generally do not utilize leverage in connection
with their investment programs but may, however, utilize short-term borrowings for operating and
investing purposes and funding withdrawals. In addition, the Portfolio Managers with which the assets
of pooled investment vehicles or the client are invested, including through managed accounts, may
buy and sell securities on margin and otherwise utilize leverage, increasing the volatility of the client's
investments. The use of leverage can, in certain circumstances, substantially increase the adverse
impact to which the client’s investment portfolio may be subject. Trading securities on margin, unlike
trading in futures
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(which also involves margin), will result in interest charges and, depending on the amount of trading
activity, such charges could be substantial. The low margin deposits normally required in futures and
forward trading permit a high degree of leverage; accordingly, relatively small price movement in a
futures contract may result in immediate and substantial losses to the investor. Irrespective of the
control objectives of Prairie Capital’s multi-asset, multi-manager approach, such a high degree of
leverage necessarily entails a high degree of risk. In the event that the client enters into an investment
advisory agreement with a Portfolio Manager that utilizes leverage in its investment program, the client
may become subject to claims by financial intermediaries that extended "margin" loans in respect of
such managed account. Such claims could exceed the value of the assets allocated to such Portfolio
Manager by the client. The risks involved in the use of leverage are increased to the extent that the
client itself leverages its capital.
Non U.S. Investments
The client or the Portfolio Managers may invest in securities of foreign corporations and foreign
countries. Investing in the securities of companies (and, from time to time, governments) of foreign
countries involves certain considerations not usually associated with investing in securities of United
States companies or the United States Government. Such risks include, among other things, political
and economic considerations, such as greater risks of expropriation and nationalization, the potential
difficulty of repatriating funds and general social, political and economic instability; the small size of the
securities markets in some countries and the low volume of trading, resulting in potential lack of
liquidity and in price volatility; fluctuations in the rate of exchange between currencies and costs
associated with currency conversion; and certain government policies that may restrict the client’s
investment opportunities. There may be less publicly available information about certain foreign
companies than would be the case for comparable companies in the United States, and certain foreign
companies may not be subject to accounting, auditing and financial reporting standards and
requirements comparable to or as uniform as those of United States companies. Securities markets
outside the United States, while growing in volume, have for the most part substantially less volume
than U.S. markets, and many securities traded on these foreign markets are less liquid and their prices
more volatile than securities of comparable United States companies. In addition, settlement of trades
in some non-U.S. markets is much slower and more subject to failure than in U.S. markets. There also
may be less extensive regulation of the securities markets in particular countries than in the United
States. Additional costs could be incurred in connection with the Portfolio Managers' international
investment activities. Foreign brokerage commissions generally are higher than in the United States.
Expenses also may be incurred on currency exchanges when the Portfolio Managers change
investments from one country to another. Increased custodian costs as well as administrative
difficulties (such as the applicability of foreign laws to foreign custodians in various circumstances,
including bankruptcy, ability to recover lost assets, expropriation, nationalization and records access)
may be associated with the maintenance of assets in foreign jurisdictions.
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Call Options
There are risks associated with the sale and purchase of call options. The seller (writer) of a call option
which is covered (e.g., the writer holds the underlying security) assumes the risk of a decline in the
market price of the underlying security below the purchase price of the underlying security less the
premium received, and gives up the opportunity for gain on the underlying security above the exercise
price of the option. The seller of an uncovered call option assumes the risk of the theoretically unlimited
increase in the market price of the underlying security above the exercise price of the option. The
securities necessary to satisfy the exercise of the call option may be unavailable for purchase except at
much higher prices. Purchasing securities to satisfy the exercise of the call option can itself cause the
price of the securities to rise further, sometimes by significant amount, thereby exacerbating the loss.
The buyer of a call option assumes the risk of losing its entire premium invested in the call option.
Put Options
There are risks associated with the sale and purchase of put options. The seller (writer) of a put option
which is covered (e.g., the writer has a short position in the underlying security) assumes the risk of an
increase in the market price of the underlying security above the sales price (in establishing the short
position) of the underlying security plus the premium received, and gives up the opportunity for gain
on the underlying security below the exercise price of the option. The seller of an uncovered put option
assumes the risk of the decline in the market price of the underlying security below the exercise price
of the option. The buyer of a put option assumes the risk of losing his entire premium invested in the
put option.
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Forward Trading
Forward contracts and options thereon, unlike futures contracts, are not traded on exchanges and are
not standardized; rather, banks and dealers act as principals in these markets, negotiating each
transaction on an individual basis. Forward and "cash" trading is substantially unregulated; there is no
limitation on daily price movements and speculative position limits are not applicable. The principals
who deal in the forward markets are not required to continue to make markets in the currencies or
commodities they trade, and these markets can experience periods of illiquidity, sometimes of
significant duration. There have been periods during which certain participants in these markets have
refused to quote prices for certain currencies or commodities or have quoted prices with an unusually
wide spread between the price at which they were prepared to buy and that at which they were
prepared to sell. Disruptions can occur in any market traded by a Portfolio Manager due to unusually
high trading volume, political intervention or other factors. The imposition of controls by governmental
authorities might also limit such forward (and futures) trading to less than that which the Portfolio
Manager would otherwise recommend, to the possible detriment of the client. Market illiquidity or
disruption could result in significant losses to the client. In addition, managed accounts or investment
funds in which the assets of the client are invested may be exposed to credit risks with regard to
counterparties with whom the Portfolio Managers trade as well as risks relating to settlement default.
Such risks could result in substantial losses to the client. To the extent possible, the General Partner will
endeavor to select Portfolio Managers that it believes will deal only with counterparties that are
creditworthy and reputable institutions, but such counterparties may not be rated investment grade.
Futures Contracts
Futures positions may be illiquid because, for example, most U.S. commodity exchanges limit
fluctuations in certain futures contract prices during a single day by regulations referred to as "daily
price fluctuation limits" or “daily limits." Once the price of a contract for a particular future has increased
or decreased by an amount equal to the daily limit, positions in the future has increased or decreased
by an amount equal to the daily limit, positions in the future can neither be taken nor liquidated unless
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traders are willing to effect trades at or within the limit. Futures contract prices on various commodities
or financial instruments occasionally have moved the daily limit for several consecutive days with little
or no trading. Similar occurrences could prevent a Portfolio Manager from promptly liquidating
unfavorable positions and subject such Portfolio Manager, and therefore the Partnership, to substantial
losses. In addition, Portfolio Managers may not be able to execute futures contract trades at favorable
prices if trading volume in such contracts is low. It is also possible that an exchange or a regulator (such
as the SEC or the CFTC) may suspend trading in a particular contract, order immediate liquidation and
settlement of a particular contract or order that trading in a particular contract be conducted for
liquidation only. In addition, the CFTC and various exchanges impose speculative position limits on the
number of positions that may be held in particular commodities. Trading in commodity futures
contracts and options is a highly specialized activity that may entail greater than ordinary investment
or trading risks. Furthermore, low margin or premiums normally required in such trading may provide
a large amount of leverage, and a relatively small change in the price of a security or contract can
produce a disproportionately larger profit or loss.
Currency Trading
A portion of the client’s assets may be invested by the Portfolio Managers in equity and debt securities
and in other financial instruments denominated in various currencies, the price of which is determined
with reference to such currencies. Prairie Capital will, however, value the client’s investments and other
assets in U.S. dollars. To the extent unhedged, the value of the client’s net assets will fluctuate with
U.S. dollar exchange rates as well as with price changes of a Portfolio Manager's investments in the
various local markets and currencies. Forward currency contracts and options may be utilized on behalf
of the client by the Portfolio Managers to hedge against currency fluctuations, but the Portfolio
Managers are not required to hedge and there can be no assurance that such hedging transactions,
even if undertaken, will be effective.
Swap Agreements
Investment vehicles we recommend or select may enter into swap agreements. Swap agreements can
be individually negotiated and structured to include exposure to a variety of different types of
investments or market factors. Depending on their structure, swap agreements may increase or
decrease a portfolio's exposure to equity securities, long-term or short-term interest rates, foreign
currency values, corporate borrowing rates, or other factors. Swap agreements can take many different
forms and are known by a variety of names.
Depending on how they are used, swap agreements may increase or decrease the overall volatility of
an investment’s portfolio. The most significant factor in the performance of swap agreements is the
change in the individual equity values, specific interest rate, currency or other factors that determine
the amounts of payments due to and from the counterparties. If a swap agreement calls for payments
by a Portfolio Fund, such Portfolio Fund must be prepared to make such payments when due. This is
only true in default and not part of mark-to-market.
Single Stock Future
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A single stock futures contract is an agreement to buy or to sell shares of a specific stock at a specified
price on a designated date in the future. Investment in single stock futures involves a substantial degree
of risk. The market for single stock futures is new to the United States. Therefore, the size of the market
for single stock futures is yet unknown. There is no assurance that a liquid secondary market will exist
for single stock futures contracts purchased or sold, and the Portfolio Managers may be required to
maintain a position until exercise or expiration, which could result in losses. Furthermore, margin for
single stock futures contracts is typically low relative to the value of the futures contracts purchased or
sold. Low margin requirements mean that a relatively small price movement in a single stock futures
contract may result in immediate and substantial losses to a Portfolio Fund.
Highly Volatile Markets
Price movements of forward contracts, futures contracts and other derivative contracts in which the
client’s assets may be invested are influenced by, among other things, interest rates, changing supply
and demand relationships, trade, fiscal, monetary and exchange control programs and policies of
governments, and national and international political and economic events and policies. In addition,
governments from time to time intervene, directly and by regulation, in certain markets, particularly
those in currencies and interest rate-related futures and options. Such intervention often is intended
directly to influence prices and may, together with other factors, cause all of such markets to move
rapidly in the same direction because of, among other things, interest rate fluctuations. Moreover, since
there is generally less government supervision and regulation of foreign stock exchanges and
clearinghouses than in the United States, Portfolio Managers also are subject to the risk of the failure
of the exchanges on which their positions trade or of their clearinghouses, and there may be a higher
risk of financial irregularities and/or lack of appropriate risk monitoring and controls.
Investment and Trading Risks in General
All investments made by the Partnership risk the loss of capital. The Portfolio Managers may utilize such
investment techniques as margin transactions, short sales, option transactions and forward and futures
contracts, which practices can, in certain circumstances, maximize the adverse impact to which the
client may be subject. Prairie Capital believes that the investment programs and research techniques
moderate this risk through diversification and careful selection of investment strategies and Portfolio
Managers. No guarantee or representation is made that the client’s investment program will be
successful, and investment results may vary substantially over time.
Trading in Securities and Other Investments May be Illiquid
Certain investment positions in which the assets of the client are invested may be illiquid. The Portfolio
Managers may invest in restricted or non-publicly traded securities, securities on foreign exchanges and
futures. Futures positions may be illiquid because certain commodity exchanges limited fluctuations in
certain futures contract prices during a single day by regulations referred to as "daily price fluctuation
limits" or "daily limits". Under such daily limits, during a single trading day no trades may be executed
at prices beyond the daily limits. Once the price of a contract for a particular future has increased or
decreased by an amount equal to the daily limit, positions in the future can neither be taken nor
liquidated unless traders are willing to effect trades at or within the limit. Such investment
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positions could prevent the Portfolio Managers from liquidating unfavorable positions promptly and
subject the client to substantial losses which could also impair a fund’s ability to make distributions to
a withdrawing Partner in a timely manner. Portfolio Managers may invest in securities that are subject
to legal or other restrictions on transfer or for which no liquid market exists. The market prices, if any,
for such securities tend to be volatile and a Portfolio Manager may not be able to sell them when it
desires to do so or to realize what it perceives to be their fair value in the event of a sale. The sale of
restricted and illiquid securities often requires more time and results in higher brokerage charges or
dealer discounts and other selling expenses than does the sale of securities eligible for trading on
national securities exchanges or in the over-the-counter markets. Restricted securities may sell at a
price lower than similar securities that are not subject to restrictions on resale.
Cybersecurity
The computer systems, networks and devices used by Prairie Capital and service providers to us and
our clients to carry out routine business operations employ a variety of protections designed to prevent
damage or interruption from computer viruses, network failures, computer and telecommunication
failures, infiltration by unauthorized persons and security breaches. Despite the various protections
utilized, systems, networks, or devices potentially can be breached. A client could be negatively
impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access
to systems, networks, or devices; infection from computer viruses or other malicious software code;
and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or
website access or functionality. Cybersecurity breaches may cause disruptions and impact business
operations, potentially resulting in financial losses to a client; impediments to trading; the inability by
us and other service providers to transact business; violations of applicable privacy and other laws;
regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or
additional compliance costs; as well as the inadvertent release of confidential information. Similar
adverse consequences could result from cybersecurity breaches affecting issuers of securities in which
a client invests; governmental and other regulatory authorities; exchange and other financial market
operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition,
substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in
the future.
Item 9: Disciplinary Information
As a registered investment adviser, Prairie Capital is required to disclose all material facts for any legal
or disciplinary event that would be material to a client or a potential client’s evaluation of the firm and
the integrity of the business and personnel employed by the firm. None of Prairie Capital Principals or
employees have ever been the subject of any legal or disciplinary actions material to our business.
Item 10: Other Financial Industry Activities and Affiliations
Prairie Capital recommends and selects other Investment Advisers. Prairie Capital does receive
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solicitor’s fees or other compensation from some Investment Advisers. Any such fees or compensation
is disclosed to the client and may be offset against other fees due to Prairie Capital by the client per
mutual agreement.
Focus Financial Partners
As noted above in response to Item 4, certain funds affiliated with CD&R collectively are indirect majority
owners of Focus Inc., and certain funds affiliated with Stone Point are indirect owners of Focus Inc. Because
Prairie Capital is an indirect, wholly-owned subsidiary of Focus Inc., CD&R and Stone Point investment
vehicles are indirect owners of Prairie Capital.
Focus Risk Solutions
We help clients obtain certain insurance products from unaffiliated insurance companies by introducing
clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent
company, Focus Financial Partners, LLC (“Focus”). FRS acts as an intermediary to facilitate our clients’
access to insurance products. FRS has agreements with certain third-party insurance brokers (the
“Brokers”) under which the Brokers assist our clients with regulated insurance sales activity.
If FRS refers one of our clients to a Broker and there is a subsequent purchase of insurance through the
Broker, FRS will receive a portion of the upfront and/or ongoing commissions paid to the Broker by the
insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale
of these insurance products will vary over time in response to market conditions. The amount of
insurance commission revenue earned by FRS is considered for purposes of determining the amount of
additional compensation that certain of our financial professionals are entitled to receive. The amount
of revenue earned by FRS for a particular insurance product will also differ from the amount of revenue
earned by FRS for other types of insurance products. This revenue is also revenue for our and FRS’s
common parent company, Focus. Accordingly, we have a conflict of interest when recommending FRS’s
services to clients because of the compensation to certain of our financial professionals and to our
affiliates, FRS and Focus. We address this conflict by: (1) fully and fairly disclosing the material facts
concerning the above arrangements to our clients, including in this Brochure; and (2) offering FRS
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solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any
discretionary investment services. Additionally, we note that clients who use FRS’s services will receive
product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party
intermediaries that provide services to our clients.
The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances
the Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the
policy. The final rate may be higher or lower than the prevailing market rate, and may be higher than if
the policy was purchased directly through the Broker without the assistance of FRS. We can offer no
assurances that the rates offered to you by the insurance carrier are the lowest possible rates available
in the marketplace.
Credit and Cash Management Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and
its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). These third-party financial institutions
are banks and non-banks that offer credit and cash management solutions to our clients, as well as
certain other unaffiliated third parties that provide administrative and settlement services to
facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’
access to these credit and cash management solutions. Flourish acts as an intermediary to facilitate
our clients’ access to cash management solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority
investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party
financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ Inc.’s
investors, including Focus. When legally permissible, UPTIQ also shares a portion of this earned
revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For non-residential mortgage loans
made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from the third-
party financial institutions. For securities-backed lines of credit (“SBLOCs”) made to our clients,
UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial
institutions. For cash management products and services provided to our clients, UPTIQ will share
with FSH up to 33% of all revenue it receives from the third-party financial institutions and other
intermediaries that provide administrative and settlement services in connection with this program.
As noted above, Flourish facilitates cash management solutions for our clients. When legally
permissible, Flourish pays FSH a revenue share of up to 0.10% of the total amount of cash held in
Flourish cash accounts by our clients. This earned revenue is indirectly paid by our clients through
an increased interest rate charged by the third-party financial institutions for credit solutions or
reduced yield paid by the providers of cash management solutions. [FSH distributes this revenue to
us when we are licensed to receive such revenue (or when no such license is required) and the
distribution is not otherwise legally prohibited.] This revenue is also revenue for FSH’s and our
common parent company, Focus. Additionally, the volume generated by our clients’ transactions
allows Focus to negotiate better terms with UPTIQ and Flourish, which benefits Focus and us.
Accordingly, we have a conflict of interest when recommending UPTIQ’s and Flourish’s services to
clients because of the compensation [to us and] to our affiliates, FSH and Focus, and the transaction
volume to UPTIQ and Flourish. We mitigate this conflict by: (1) fully and fairly disclosing the material
facts concerning the above arrangements to our clients, including in this Brochure; and (2) offering
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UPTIQ’s and Flourish’s solutions to clients on a strictly nondiscretionary and fully disclosed basis, and
not as part of any discretionary investment services. Additionally, we note that clients who use
UPTIQ’s and Flourish’s services will receive product-specific disclosure from the third-party financial
institutions and other unaffiliated third-party intermediaries that provide services to our clients.
We have an additional conflict of interest when we recommend credit solutions to our clients because
our interest in continuing to receive investment advisory fees from client accounts gives us a financial
incentive to recommend that clients borrow money rather than liquidate some or all of the assets we
manage.
Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’
custodians. While credit solution programs that we offer facilitate secured loans through third-party financial
institutions, clients are free instead to work directly with institutions outside such programs. Because of the
limited number of participating third-party financial institutions, clients may be limited in their ability to
obtain as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms
or obtain other financial arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves additional risk and
restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged
securities at any time, without prior notice to clients and without their consent, to maintain required
collateral levels. The third-party financial institution also has the right to call client loans and require
repayment within a short period of time; if the client cannot repay the loan within the specified time period,
the third-party financial institution will have the right to force the sale of pledged assets to repay those loans.
Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a
declining market, leading to the permanent loss of capital. These sales also may have adverse tax
consequences. Interest payments and any other loan-related fees are borne by clients and are in addition to
the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The
returns on pledged assets may be less than the account fees and interest paid by the account. Clients should
consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in
order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally,
before borrowing funds, a client should carefully review the loan agreement, loan application, and other
forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks
consistent with the client’s financial circumstances and risk tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative and settlement
services to our clients. Engaging the third-party financial institutions and other intermediaries to provide
cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients
should understand that in rare circumstances, depending on interest rates and other economic and market
factors, the yields on cash management solutions could be lower than the aggregate fees and expenses
charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently,
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in these rare circumstances, a client could experience a negative overall investment return with respect to
those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash
management program if the client prefers to hold cash at the third-party financial institutions rather than at
other financial institutions (e.g., to take advantage of FDIC insurance).
We use UPTIQ and Flourish to facilitate cash management solutions for our clients.
Cotton Creek Capital Management, LLC
As discussed in response to Item 6 above, the Principals, executive officers of the Firm, are, among
other entities, the owners and investment adviser representatives of CCCM, a private fund manager
that serves as the general partner of, and provides investment management, advisory and other
services to, the CCCM Funds. Activities on behalf of CCCM and its clients will take up a portion
of the Principals’ business time and may raise various other actual or potential conflicts of interest.
The Firm has entered into an Administrative Services Agreement with CCCM, pursuant to which
CCCM will pay most of the CCCM Funds’ management fees and any other revenues CCCM
receives from the CCCM Funds to the Firm in exchange for providing non-advisory administrative,
back-office, investor communications, consultation and various other operational and support
services to CCCM.
The Firm has in the past recommended and may in the future recommend that certain of the Firm’s
advisory clients invest in one or more of the CCCM Funds, the Funds or other private investment
funds formed, advised, sponsored or managed by CCCM, the Firm or affiliates thereof. Because the
Principals have financial interests in the CCCM Funds, the Funds and the Firm, the Principals and
others associated with the Firm have or may have financial and other interests in other private
investment funds, they have or may have a financial or other incentive to recommend that Firm
clients invest in the CCCM Funds, the Funds and such other affiliated pooled investment vehicles
and face conflicts of interest relating thereto. The Principals additionally have a greater financial
incentive to expend efforts on behalf of the CCCM Funds or the Funds than on their activities on
behalf of the Firm and its clients. To address this conflict, the Firm provides full and fair disclosure
to its clients. The Firm and the Principals additionally are mindful of the fiduciary duties they owe
to all of their advisory clients.
To subscribe for an interest in a Fund, each investor will be required to complete and execute various
subscription documents, pursuant to which it will, among other things, acknowledge, consent and
agree to various applicable actual or potential conflicts of interest that are or may be applicable with
respect to such Fund (including the Firm’s recommendation of investments in the Funds to advisory
clients).
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Prairie Capital has adopted a Code of Ethics (“Code”) designed to comply and meet the requirements of
Rule 204A-1 under the Investment Advisers Act of 1940, and to reflect fully a registered investment
adviser’s fiduciary obligations and those of its supervised persons.
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Prairie Capital’s Code of Ethics, among other things, requires our Firm’s personnel to comply with
applicable laws, act in accordance with the Prairie Capital’s fiduciary duties to clients and to report their
personal securities holdings and transactions for compliance review.
Clients and potential clients may request a written copy of Prairie Capital’s Code at any time by
contacting their representative at Prairie Capital.
Item 12: Brokerage Practices
Prairie Capital will recommend that our clients establish brokerage accounts with unaffiliated custodian
broker-dealers to maintain custody of their respective assets. The custodian broker-dealer we will
recommend is Fidelity Institutional Wealth Services (“IWS”). IWS provides brokerage, custody, research,
and access to mutual funds and other investments. IWS generally does not charge separately for custody
but is compensated by account holders through commissions or other transaction-related fees for
securities trades they execute and for client assets held in their cash sweep.
Prairie Capital will generally recommend IWS based on its reputation, quality of service, financial
strength and the estimated cost and convenience to the client. Prairie Capital will have an institutional
relationship with IWS and IWS will provide Prairie Capital and our clients with access to services that
are not typically available to retail customer accounts. These include custody, reporting, and related
services, as well as services to help us administer our clients’ accounts and manage and grow our
business. These services generally are available to independent investment advisers on an unsolicited
basis, at no charge to them so long as they maintain a required minimum level of client assets.
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IWS makes available to independent advisers other products and services that benefit the adviser and
its clients but that do not benefit individual client accounts. Some of these other products and services
assist the adviser in managing and administering client accounts. The products and services include
software and other technology that provide access to client account data (such as trade confirmations
and account statements); facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts); provide research, pricing information and other market data; facilitate
payment of advisory fees from client accounts; and assist with back-office functions, recordkeeping and
client reporting. Many of these services generally can be used to service all or a substantial number of
client accounts, including accounts not maintained at IWS.
IWS also make available to independent advisers other services intended to help the adviser further
develop its business enterprise. These available services include consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, and marketing. IWS makes available, arranges and/or pays for these types of services
rendered to advisers by independent third parties.
The provision of the above benefits [and payments] to the Firm represent a conflict of interest because
the Firm has a financial incentive to recommend that clients engage with the Custodian and to
recommend switching investment products or services when a client’s current investments are not
available through the Custodian. This arrangement does not cause the Firm’s clients to pay more for
investment transactions effected and/or assets maintained at the Custodian than such clients would
pay at the Custodian absent the agreement. There is no express commitment made by the Firm to the
Custodian or any other entity to invest any specific amount or percentage of client assets in any specific
mutual funds, securities, or other investment products as result of the above arrangement. Also, any
benefits received by the Firm from the Custodian do not depend on the specific amount of brokerage
transactions directed to the Custodian. The benefits and payments, however, are an inducement to the
Firm to utilize the services of the Custodian and are provided based on an expectation by the Custodian
that the Firm will direct enough business to the Custodian to make it financially advantageous for the
Custodian to provide those benefits and payments. Clients and future clients should be aware that the
receipt of economic benefits by the Firm in and of itself influences the Firm’s recommendation to clients
to utilize the Custodian for custody and brokerage services.
Item 13: Review of Accounts
When a client chooses Prairie Capital for asset allocation and manager selection services, Prairie Capital
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will review the client’s portfolio, develop an investment policy statement and asset allocation study,
review manager and mutual fund databases to formulate a portfolio meeting client criteria, assist client
in selecting managers and mutual funds, and provide ongoing performance monitoring and analysis of
the various managers and mutual funds selected by the client. Generally, these reviews will be
performed on a quarterly basis, although clients may, on occasion, request more frequent or less
frequent reviews. Prairie Capital’s Managing Directors will all be extensively involved in and provide
overall supervision of the ongoing performance monitoring and analysis. Prairie Capital’s Managing
Directors may involve other appropriate qualified personnel in such reviews, and the level of reviews
will be specifically customized and tailored to the needs and requirements of the clients. All individuals
named above will be extensively involved in reviews and in preparation of ongoing performance
monitoring and analysis reports for each and every client. On a case-by-case basis, certain review
services may be provided on the basis of monthly charges upon request of a client.
When a client chooses Prairie Capital to manage accounts on a discretionary basis, one or more of the
individuals noted in the above paragraph will review all accounts on a continuing basis.
Clients will all receive monthly and/or quarterly, written statements reporting all activity of their
accounts. Additionally, periodic reviews of performance will be provided to clients based on the specific
needs and instructions of the clients.
Item 14: Client Referrals and Other Compensation
From time to time, Prairie Capital enters into agreements providing cash compensation to persons who
refer clients to Prairie Capital. These agreements are governed by and require that the solicitor meet
the disclosure and other requirements of SEC Rule 206(4)-1 under the Investment Advisers Act. The
terms of the agreements differ somewhat depending upon the circumstances, but generally provide
either for the compensation equal to a specified percentage of the fees received by Prairie Capital from
clients referred; or for fixed compensation payable monthly or quarterly and subject to periodic review
not less frequently than annually. The agreements generally are subject to termination on thirty (30)
days prior written notice.
Prairie Capital’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus
holds partnership meetings and other industry and best practices conferences, which typically include
Prairie Capital, other Focus firms and external attendees. These meetings are first and foremost
intended to provide training or education to personnel of Focus firms, including Prairie Capital.
However, the meetings do provide sponsorship opportunities for asset managers, asset custodians,
vendors and other third-party service providers. Sponsorship fees allow these companies to advertise
their products and services to Focus firms, including Prairie Capital. Although the participation of Focus
firm personnel in these meetings is not preconditioned on the achievement of a sales target for any
conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and
education activities conducted, and the access granted, at such meetings and conferences could cause
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Prairie Capital to focus on those conference sponsors in the course of its duties. Focus attempts to
mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting
or future meetings and not as revenue for itself or any affiliate, including Prairie Capital. Conference
sponsorship fees are not dependent on assets placed with any specific provider or revenue generated
by such asset placement.
The following entities have provided conference sponsorship to Focus from January 1, 2024 to
February 1, 2025:
• Advent Software, Inc. (includes SS&C)
• BlackRock, Inc.
• Blackstone Administrative Services Partnership L.P.
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
• Confluence Technologies Inc.
•
•
•
•
Salus GRC, LLC
Stone Ridge Asset Management LLC
The Vanguard Group, Inc.
TriState Capital Bank
Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates)
Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity
Institutional Asset Management and FIAM)
Flourish Financial LLC
Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and
CANVAS)
• K&L Gates LLP
• Nuveen Securities, LLC
• Orion Advisor Technology, LLC
• Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions)
• Practifi, Inc.
•
•
•
•
• UPTIQ, Inc.
You can access a more recently updated list of recent conference sponsors on Focus’ website
through the following link: https://focusfinancialpartners.com/conference-sponsors/
Item 15: Custody
We are deemed to have legal custody over client assets when we have the authority to debit our fees
from client accounts. Rule 206(4)-2 of the Advisers Act, the “Custody Rule,” requires advisers who have
custody over client assets to maintain those assets with a qualified custodian who sends account
statements to clients at least quarterly.
Clients will receive monthly and/or quarterly written statements from Prairie Capital. Clients should
compare these accounts statements with any account statements the client receives from broker-
dealers and other qualified custodians maintaining client assets and report any discrepancies to Prairie
Capital immediately.
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Prairie Capital Management Group is an affiliate of each of the General Partners of the Flint Hills Funds.
Due to this affiliation, PCMG is considered to have custody of assets in the Flint Hills Funds. Prairie
Capital complies with all aspects of Rule 206(4)-2, the “Custody Rule”, including an annual,
independent audit of the Flint Hills Funds. PCM does not take custody of any other clients’ assets.
Item 16: Investment Discretion
Prairie Capital is generally given no discretionary authority to invest client funds. Other than selecting
interests in private or registered investment companies in conjunction with the management of a
particular segment of a client’s portfolio or investing client uninvested funds in money market mutual
funds, Prairie Capital does not directly invest client assets for its multi-manager, multi-strategy
accounts. Rather, such client accounts are invested by the separate investment advisory firms
(“portfolio managers”) selected by Prairie Capital who, for the portfolios managed by them, select
securities to be bought and sold and the amount of the securities to be bought or sold.
Clients must sign a non-discretionary investment advisory agreement indicating that Prairie Capital has
no investment discretion prior to Prairie Capital assuming such authority.
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Item 17: Voting Client Securities
Currently, Prairie Capital does not have nor accept authority to vote client securities. Clients will receive
their proxies or other solicitations directly from their custodian or a transfer agent. Clients may contact
their representative Prairie Capital with questions regarding a particular solicitation.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information
or disclosures about their financial condition. Prairie Capital has no financial commitment that impairs
its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a
bankruptcy proceeding.
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Item 1: Cover Page
Part 2B of Form ADV: Supplement
Michael M. Gentry
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
This brochure supplement provides information about Michael M. Gentry that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital Management
Group, LLC’s brochure or if have any questions about the contents of this supplement.
Additional information about Michael M. Gentry is available on the SEC’s website at www.adviserinfo.sec.gov.
31
Item 2: Educational Background and Business Experience
Michael M. Gentry is a Managing Director of Prairie Capital Management Group, LLC in the Kansas City
office. Michael is responsible for managing client relationships, investment manager due diligence and
serves on the firm’s Investment Committee. Michael served as a Managing Director of the predecessor
investment adviser Prairie Capital Management, LLC for over four years. Prior to joining the Prairie
Capital Management Group, LLC predecessor firm, Michael spent over seven years with Credit Suisse in
Chicago as a Director in the HOLT division. Prior to joining Credit Suisse, Michael spent two years with
Ernst & Young’s corporate restructurings practice. He holds the following securities licenses: 63 and 66.
Mr. Gentry, aged 44, received his B.S. in Accounting and Business Administration and M.S. in accounting
(both with Highest Distinction) from the University of Kansas, and his M.B.A. from the University Of
Chicago Booth School Of Business (with Honors). Michael has successfully passed the CPA exam in the
state of Kansas.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
Michael Gentry may be eligible for additional compensation from our indirect parent company, Focus
Financial Partners, LLC (or one of its affiliates), depending on the performance of Prairie Capital
Management Group, LLC. Eligibility will be determined based on all or a portion of Prairie Capital
Management Group’s revenues and/or earnings. This potential for increased compensation provides an
incentive for Michael Gentry to encourage you to maintain and even increase the size of your investment
account with us.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Gentry’s advisory activities are supervised Andrew S Klocke,
a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Gentry through reports,
discussions and meetings relating to investment strategies and specific client portfolios. Additionally, the
Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs regularly
scheduled compliance reviews.
32
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Brian N. Kaufman
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
This brochure supplement provides information about Brian N. Kaufman that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital Management
Group, LLC’s brochure or if have any questions about the contents of this supplement. Additional
information about Brian N. Kaufman is available on the SEC’s website at www.adviserinfo.sec.gov.
33
Item 2: Educational Background and Business Experience
Brian N. Kaufman is a Managing Director of Prairie Capital Management Group, LLC in the Kansas City
office, and a founder of the predecessor investment adviser Prairie Capital Management, LLC. Brian is
responsible for managing client relationships, investment manager due diligence, and serves on the
firm’s Investment Committee. Brian also coordinates business, legal and tax matters with clients and
their legal and tax advisors. From 1995 to March 2021, Mr. Kaufman served in similar roles with the
predecessor entities of Prairie Capital Management Group, LLC. Previously, Brian practiced law for over
a decade as a partner with the Kansas City office of a major international law firm. His practice
emphasized tax law, securities law, and venture capital. He has served on the boards of a number of
charitable organizations, foundations, and private companies. He has held the following securities
licenses: Series 4, 7, 27, and 66. Mr. Kaufman, aged 65, he received a B.S. in Accounting and Business
Administration (with Highest Distinction) from the University of Kansas, and a J.D. from Stanford Law
School.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
Brian Kaufman may be eligible for additional compensation from our indirect parent company, Focus
Financial Partners, LLC (or one of its affiliates), depending on the performance of Prairie Capital
Management Group, LLC. Eligibility will be determined based on all or a portion of Prairie Capital
Management Group’s revenues and/or earnings. This potential for increased compensation provides an
incentive for Brian Kaufman to encourage you to maintain and even increase the size of your investment
account with us.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Kaufman’s advisory activities are supervised Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Kaufman through reports,
discussions and meetings relating to investment strategies and specific client portfolios. Additionally, the
Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs regularly
scheduled compliance reviews.
34
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Andrew S. Klocke
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
This brochure supplement provides information about Andrew S. Klocke that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital Management
Group, LLC’s brochure or if have any questions about the contents of this supplement. Additional
information about Andrew S. Klocke is available on the SEC’s website at www.adviserinfo.sec.gov.
35
Item 2: Educational Background and Business Experience
Andrew S. Klocke is a Managing Director of Prairie Capital Management Group, LLC in the Kansas City
office. Andy is responsible for managing client relationships, investment manager due diligence, and
serves on the firm’s Investment Committee. From 2003 to March 2021, Mr. Klocke served in similar roles
with the predecessor entities of Prairie Capital Management Group, LLC. He has served on the boards of
a number of charitable organizations, foundations, and private companies. He has held the Series 7 and
66 securities licenses. Mr. Klocke, aged 43, he received his B.S. in Finance (Phi Kappa Phi) and his M.B.A.
from Kansas State University.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
Andrew Klocke may be eligible for additional compensation from our indirect parent company, Focus
Financial Partners, LLC (or one of its affiliates), depending on the performance of Prairie Capital
Management Group, LLC. Eligibility will be determined based on all or a portion of Prairie Capital
Management Group’s revenues and/or earnings. This potential for increased compensation provides an
incentive for Andrew Klocke to encourage you to maintain and even increase the size of your investment
account with us.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients is
subject to oversight by another person. Mr. Klocke’ s advisory activities are supervised by Angela Tower the
Chief Operating Officer of Prairie Capital Management Group, LLC. Ms. Tower oversees the investment
advice provided by Mr. Klocke through reports, discussions and meetings relating to investment strategies
and specific client portfolios. Additionally, the Chief Compliance Officer monitors adherence to the Code of
Ethics, as well as, performs regularly scheduled compliance reviews.
36
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Curtis A. Krizek
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
information about Curtis A. Krizek
is available on
This brochure supplement provides information about Curtis A. Krizek that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital
Management Group, LLC’s brochure or if have any questions about the contents of this supplement.
Additional
the SEC’s website at
www.adviserinfo.sec.gov.
37
Item 2: Educational Background and Business Experience
Curtis A. Krizek, a Managing Director of Prairie Capital Management, LLC in the Kansas City office, is
responsible for client relationship management and investment evaluation. From 1995 to March 2021,
Mr. Krizek was a founder of, and served in similar roles with the predecessor entities of Prairie Capital
Management Group, LLC. From 1985 to 1995, Mr. Krizek practiced corporate law with a Kansas City
based regional law firm. He has served on the boards of a number of charitable organizations,
foundations, and private companies, and has held the following securities licenses: 7, 53, and 67. Mr.
Krizek, aged 63, received a B.S. in Life Sciences, Honors Program, from Kansas State University and earned
a J.D. from The University of Virginia School of Law.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
Curtis Krizek may be eligible for additional compensation from our indirect parent company, Focus Financial
Partners, LLC (or one of its affiliates), depending on the performance of Prairie Capital Management Group,
LLC. Eligibility will be determined based on all or a portion of Prairie Capital Management Group’s revenues
and/or earnings. This potential for increased compensation provides an incentive for Curtis Krizek to
encourage you to maintain and even increase the size of your investment account with us.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Krizek’s advisory activities are supervised by Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Krizek through reports,
discussions and meetings relating to investment strategies and specific client
portfolios. Additionally, the Chief Compliance Officer monitors adherence to the Code of Ethics, as well
as, performs regularly scheduled compliance reviews.
38
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Riley R Pratt
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
This brochure supplement provides information about Riley R Pratt that supplements the Prairie Capital
Management Group, LLC brochure. You should have received a copy of that brochure. Please contact
our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital Management Group,
LLC’s brochure or if have any questions about the contents of this supplement. Additional information
about Riley R Pratt is available on the SEC’s website at www.adviserinfo.sec.gov.
39
Item 2: Educational Background and Business Experience
Riley Pratt is a Managing Director working out of the Denver Colorado area. Riley is responsible for
managing client relationships, investment manager due diligence, and serves on the firm’s Investment
Committee. Riley joined the predecessor firm Prairie Capital Management, LLC in March of 2019. Prior
to joining Prairie Capital Management LLC, Riley spent five years with Morgan Stanley where he served
as a Private Wealth Advisor for ultra high net worth individuals and families. His responsibilities included
creating and implementing highly customized investment portfolios as well as co-leading the group’s
efforts in third-party asset manager selection, due diligence, and performance measurement. Prior to
joining Morgan Stanley, Riley was a senior associate in the financial services audit practice at
PricewaterhouseCoopers LLP, specializing in the asset management industry. Riley, aged 35 graduated
from the Honors College at Michigan State University with a B.A. in Accounting and earned a Master of
Accounting degree from Oakland University. He is a licensed Certified Public Accountant (CPA) in the
state of Illinois and a CFA® charter holder. Riley is also involved in the iMentor program, volunteering to
help mentor students in the Chicago area for college success.
To earn the Chartered Financial Analyst (CFA) candidates must: 1) pass three sequential, six-hour
examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute
as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of
Ethics and Standards of Professional Conduct.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Pratt’s advisory activities are supervised by Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Pratt through reports,
discussions and meetings relating to investment strategies and specific client portfolios. Additionally, the
Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs regularly
scheduled compliance reviews.
40
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Robyn R. Schneider
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
information about Robyn R. Schneider
is available on
the SEC’s website at
This brochure supplement provides information about Robyn R. Schneider that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital Management
Group, LLC’s brochure or if have any questions about the contents of this supplement.
Additional
www.adviserinfo.sec.gov.
41
Item 2: Educational Background and Business Experience
Robyn R. Schneider is a Managing Director of the Prairie Capital Management Group, LLC in the Hinsdale,
Illinois office. He is responsible for client relationship management, investment manager due diligence,
and manager relations. From 1995 to March 2021, Mr. Schneider served in similar roles with the
predecessor entities of Prairie Capital Management Group, LLC. He has served on the boards of a number
of charitable organizations, foundations, and private companies, and has held the following securities
licenses: Series 3, 7, 30, and 63. Mr. Schneider, aged 65, earned a B.S. in Finance and Business Marketing
from Kansas State University.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
Robyn Schneider may be eligible for additional compensation from our indirect parent company, Focus
Financial Partners, LLC (or one of its affiliates), depending on the performance of Prairie Capital
Management Group, LLC. Eligibility will be determined based on all or a portion of Prairie Capital
Management Group’s revenues and/or earnings. This potential for increased compensation provides an
incentive for Robyn Schneider to encourage you to maintain and even increase the size of your
investment account with us.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Schneider’s advisory activities are supervised by Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Schneider through reports,
discussions and meetings relating to investment strategies and specific client portfolios.
Additionally, the Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs
regularly scheduled compliance reviews.
42
Item 1: Cover Page
Part 2B of Form ADV: Supplement
John S Thurlow
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
information about
John S Thurlow
is available on
This brochure supplement provides information about John S Thurlow that supplements the Prairie
Capital Management Group, LLC brochure. You should have received a copy of that brochure. Please
contact our Chief Compliance Officer at (816) 531-1101 if you did not receive Prairie Capital
Management Group, LLC’s brochure or if have any questions about the contents of this supplement.
Additional
the SEC’s website at
www.adviserinfo.sec.gov
43
Item 2: Educational Background and Business Experience
John S. Thurlow is a Managing Director in the Kansas City office. John is responsible for managing client
relationships, investment manager due diligence, and serves on the firm’s Investment Committee. John
joined the predecessor firm Prairie Capital Management, LLC January 2021. Prior to joining the
predecessor Prairie Capital Management, LLC, John served entrepreneurs, family offices, and
foundations with Goldman Sachs’ Investment Management Division. John completed his MBA from
Duke’s Fuqua School of Business and previously worked as a Strategy and Operations consultant with
Deloitte Consulting in Kansas City. John, age 38, is originally from Wichita, KS and received a B.S. in
Finance and Accounting from Kansas State University. He serves on the Kansas State University College
of Business Finance Advisory Board and as an Executive Mentor.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Thurlow’s advisory activities are supervised by Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Thurlow through reports,
discussions and meetings relating to investment strategies and specific client portfolios. Additionally,
the Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs regularly
scheduled compliance reviews.
20549312.5
44
Item 1: Cover Page
Part 2B of Form ADV: Supplement
Cory M Ross
Prairie Capital Management Group, LLC
4900 Main Street, Suite 700
Kansas City, MO 64112
(816) 531-1101
March 31, 2023
45
Item 2: Educational Background and Business Experience
Cory Ross is a Managing Director working out of the Denver Colorado area. Cory is responsible for managing
client relationships, investment manager due diligence, and serves on the firm’s Investment Committee.
Cory has been an investment professional since 2012 and joined Prairie Capital in 2022. Prior to joining
Prairie Capital, Cory spent ten years with Marsico Capital Management, where he served clients across the
institutional, family office, and RIA channels. Cory received his B.S. from Louisiana State University, where
he captained the men’s tennis team. In addition, Cory received an M.B.A. in Finance from the University of
Denver. He is active in the Denver community, including serving as a trustee for the Arnold Palmer
scholarship program.
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
As part of the normal compliance process, every person performing advisory services on behalf of clients
is subject to oversight by another person. Mr. Ross’s advisory activities are supervised by Andrew S
Klocke, a Managing Director of Prairie Capital Management Group, LLC and a member of the Investment
Committee. Mr. Klocke oversees the investment advice provided by Mr. Ross through reports,
discussions and meetings relating to investment strategies and specific client portfolios. Additionally,
the Chief Compliance Officer monitors adherence to the Code of Ethics, as well as, performs regularly
scheduled compliance reviews.
46