Firm Structure & Regulatory Status
Transparency • Governance • Compliance
Regulatory Status
McVinney Capital Management LLC operates as an Exempt Reporting Adviser (ERA) under the Investment Advisers Act of 1940. As an ERA, the firm is not registered with the SEC. The firm files Form ADV with the U.S. Securities and Exchange Commission and is subject to applicable federal and state regulatory requirements.
The State of Georgia, US is the primary regulatory jurisdiction. McVinney Capital Management LLC relies on the de minimis exemption from investment adviser registration under Georgia law.
The State of Delaware is the fund's organizational jurisdiction. McV Compounding Founders Fund LP is registered as a limited partnership with the state of Delaware's Secretary of State.
The firm accepts capital exclusively from accredited investors under Rule 506(c) of Regulation D.
Governing Body
The firm is governed by its Managing Partners, with oversight responsibilities that include:
- Regulatory compliance and filings
- Risk management and supervisory controls
- Policies and procedures for trading, valuation, and conflicts of interest
- Investor communication standards
- Ongoing monitoring of operational integrity
Governance is structured to ensure independence, accountability, and alignment with investor interests.
Compliance Oversight
Compliance is led by Brent Gillett, Chief Compliance Officer and Managing Partner. Brent brings more than 25 years of legal and regulatory experience advising hedge funds, private equity firms, venture funds, and other alternative asset managers.
He is the founder of Investment Law Group (operating through Gillett Joseph LLP), a nationally recognized practice focused on fund formation and investment adviser compliance.
Legal & Operational Framework
The firm operates through a clear and conflict‑free structure:
| Entity / Function | Description |
|---|---|
| General Partner | McVinney Capital Management LLC |
| Management Company | McVinney Capital Management LLC |
| Fund Vehicle | McV Compounding Founders Fund LP |
| Legal Counsel | Independent legal counsel (to be appointed) |
| Administrator | NAV Consulting |
| Custodian / Prime Broker | Tradestation |
| Auditor | Summit LLC, Certified Public Accountants. |
This structure ensures proper segregation of duties, independent oversight, and institutional‑grade operational controls.
Fiduciary Commitment
As an ERA, the firm seeks to adhere to the core fiduciary principles expected of investment advisers:
- Acting in the best interest of investors
- Full and fair disclosure of material information
- Robust internal controls and risk management
- Transparent reporting and communication
Our governance philosophy emphasizes clarity, discipline, and long‑term alignment with our investors.