Private fund adviser · New York, NY
Commodore Capital
Commodore Capital LP · SEC-registered investment adviser · CRD 304370 · SEC 801-117168
At a glance
Commodore Capital is an SEC-registered investment adviser based in New York, New York, with $2.4 billion in regulatory assets under management as of its Form ADV filed March 31, 2026. Its largest client group by assets is pooled investment vehicles. By Form ADV it is a private fund adviser, ranked 1,523rd of 4,686 private fund advisers and 3,292nd of 17,210 SEC-registered advisers by assets.
Main office 212-256-8600commodorecapital.comLinkedInAs filed on Form ADV
- Regulatory AUM
- $2.4B
- Rank among private fund advisers
- #1,523 of 4,686
- Rank among all SEC RIAs
- #3,292 of 17,210
- Rank in New York
- #788 of 2,591
- Clients
- 3
- Accounts
- 3
- Discretionary
- 100% of AUM
- Employees
- 12
- Advisory staff
- 6
- Offices
- 1
Owners and executives on its Form ADV
- Michael J. KramarzManaging Partner
- Robert Egen T. AtkinsonManaging Partner
- Ameya V. BapatChief Compliance Officer, Chief Operating Officer, General Counsel
- Anand B. PandyaChief Financial Officer
Custody and brokerage
Custodian
Commodore Capital’s Form ADV lists no custodian for separately managed accounts. Firms report one only when they manage $10 million or more in those accounts.
Who it serves
| Client type | Clients | Regulatory AUM | Share |
|---|---|---|---|
| Pooled investment vehicles | 3 | $2.4B | 100% |
Private funds
Commodore Capital reports 1 private funds with $2.4B in gross assets: hedge funds (Form ADV Item 7.B).
Disciplinary disclosures
Commodore Capital reports no disciplinary disclosures in Item 11 of Form ADV. Read the details on the SEC’s adviser search ↗
Services
- Portfolio management for pooled investment vehicles
How it’s paid
- A percentage of assets under management
- Performance-based fees
Form ADV and brochures on the SEC’s adviser search ↗commodorecapital.com ↗
AtlasMembers
The full record on Commodore Capital
Ten years of SEC filings, its owners and contacts, and how it stacks up against its peers. Atlas members see all of it.
- Assets, accounts, clients and staff, 6 years of filings
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- Growth over one, three and five years
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- Rank against 1,790 peers of its type and size
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- Owners and executives, with titles and stakes
- 4 namedLocked
- Main office, fax and compliance officer
- Locked
- Filing changes this year, with alerts
- 1Locked
Free while Atlas launches: create a free account and confirm your email. Every figure comes from SEC filings.
Background
Questions
How much does Commodore Capital manage?
Commodore Capital reports $2.4 billion in regulatory assets under management across 3 accounts, 100% of it on a discretionary basis, on its Form ADV filed March 31, 2026.
What kind of firm is Commodore Capital?
Commodore Capital is a private fund adviser by its Form ADV answers. Private funds are at least half of its business by assets.
Who are Commodore Capital’s clients?
By assets, its largest client types are pooled investment vehicles ($2.4 billion, 3 clients).
Does Commodore Capital manage private funds?
Yes. It reports 1 private funds with $2.4 billion in gross assets, including hedge funds.
Does Commodore Capital have any disciplinary history?
Commodore Capital reports no disciplinary disclosures in Item 11 of its Form ADV. Check the SEC’s adviser search for the latest record.
Where these numbers come from
Every figure is Commodore Capital’s own answer on its latest Form ADV, from the SEC’s registered-adviser list as of October 1, 2026: regulatory assets and accounts (Item 5.F), clients by type (5.D), employees (5.A and 5.B), compensation (5.E) and services (5.G). Custodians come from Schedule D 5.K(3) of its latest filing (2026-03-31), which lists those holding 10% or more of separately managed account assets and the amount at each. “Hybrid” means some employees are also registered representatives of a broker-dealer (Item 5.B(2)); affiliated broker-dealers are the related persons it lists in Item 7.A and Schedule D. Firm type comes from its own answers: broker-dealer firms are registered broker-dealers themselves (Item 6.A); private fund advisers manage mostly private funds (Item 7.B, 5.D); wealth managers manage at least half their assets for individuals (5.D). Ranks compare it by regulatory assets with every SEC-registered adviser and with firms of its type. Figures are as of the firm’s last annual update, so they can lag recent deals and market moves. Regulatory AUM counts assets the firm continuously supervises and can differ from what a firm markets.
Not an endorsement or a recommendation. Before hiring any adviser, read its Form ADV Part 2A brochure and check its record on the SEC’s adviser search. How to check a financial advisor →