Skip to content

Kultura Capital Management

Private funds

Park City, UTCRD 327510Updated

Kultura Capital Management is an investment adviser based in Park City, UT, registered with the SEC since 2025. It provides investment management. Its clients include pooled investment vehicles. Its regulatory assets under management total $245 million, as filed on 6 May 2026.

4
Clients
Not reported
AUM per individual client
5
Advisory staff
1
Offices

From Form ADV filed 6 May 2026SEC record

Services and clients

Kultura Capital Management provides portfolio management for pooled vehicles. The firm advises 2 private funds.

Kultura Capital Management reports 4 pooled investment vehicles. These counts refer to investment vehicles, rather than the individual investors in them. Of its assets, 100.0% ($245M across 4 accounts) are managed with discretion. Of its clients, 50% are outside the U.S.

Clients and assets by client type
Clients4 clients
Assets$245M
Share of clients and assets by client type
Client typeClientsAssets
Pooled investment vehicles100%100%
Client breakdown and activity details
Pooled investment vehicles
Clients
4
Regulatory AUM
$245M
AUM share
100.0%
Avg. per client
$61.2M

Total

Clients
4
Regulatory AUM
$245M
AUM share
100%
Avg. per client
$61.2M
Clients outside the U.S.
50%
Clients advised without assets under management last fiscal year
0
Private funds advised
2

Fees and minimums

Kultura Capital Management is paid through a percentage of assets under management and performance-based fees; its fees and minimums are set out in its brochures on the SEC website.

Ownership and people

Kristov Paulus owns 75% or more of Kultura Capital Management. The leadership team of Kultura Capital Management includes Chief Operating Officer Dunyelle Rosen and Chief Financial Officer Kristopher McPherson. It has 12 employees, 5 of them in advisory roles.

Leadership

  • Kristopher McPherson
    Chief Financial Officer & Chief Compliance Officer
  • Dunyelle Rosen
    General Counsel & Chief Operating Officer
  • Kristov Paulus
    Managing Partner & CIO

Staff

  • 12 employees
  • 5 in advisory functions
  • 1 soliciting firm
Who owns the firm
Kultura Capital Management LP· the adviser
  • Kristov Paulus

    Control person · since April 2023

    Owns 75% or more of Kultura Capital Management LP
  • Dunyelle Rosen

    Control person · since April 2023

    Owns 25% to 50% of Kultura Capital Management LP
  • Christopher Conforti

    Control person · since April 2023

    Owns 25% to 50% of Kultura Capital Management LP

Growth and acquisitions

Kultura Capital Management’s regulatory assets grew 2.0× from $119M (June 2025) to $245M (May 2026); clients were 4 in both filings and employees rose from 11 to 12.

By annual filing
Measure
Figures from each annual filing
Kultura Capital Management figures from each annual Form ADV filing
FiledRegulatory AUMClientsEmployeesOffices
May 2026$245M4121
June 2025$119M4111

Offices and registration details

Besides its headquarters, Kultura Capital Management has 0 offices, with 1 listed address in Utah.

Listed office addresses in Utah
Park City

Utah · 1 listed address

  • 1389 Center Drive, Suite 200, Park CityHQ

Contact and registration details

Legal name
Kultura Capital Management LP
Headquarters
1389 Center Drive, Suite 200, Park City, UT 84098
SEC file
801-134057
Structure
Delaware limited partnership
Fiscal year end
December

Custodians

Kultura Capital Management has custody of $245M in client assets for 4 clients.

Investments and reported holdings

Kultura Capital Management’s reported 13F holdings for the quarter ended 30 June 2026 total $553M across 66 positions; the largest are Invesco Qqq TR (put option) (15.0%), Vaneck ETF Trust (put option) (6.4%) and Intel Corp. (5.2%).

Reported 13F holdings

$553M
Reported 13F value
66
Positions
47.5%
In the 10 largest
−13.2%
Value vs. prior quarter
Ten largest positions, share of reported value
  1. Invesco Qqq TR · Unit Ser 1Put15.0%
  2. Vaneck ETF Trust · Semiconductr ETFPut6.4%
  3. Intel Corp.5.2%
  4. Microsoft Corp.Call3.6%
  5. Broadcom Inc.Call3.3%
  6. Nokia Corp. · Sponsored ADRCall3.1%
  7. Applied Matls Inc.3.0%
  8. Super Micro Computer Inc.Put2.7%
  9. Roundhill ETF Trust · Memory ETFPut2.6%
  10. Sandisk Corp.2.5%

Together, the ten largest are 47.5% of reported value.

The 50 largest positions and quarterly changesQuarter ended 30 June 2026 · filed 14 August 2026

Common questions

How many clients does Kultura Capital Management have?

Kultura Capital Management has 4 clients and manages $245 million for them, as of May 2026. They include 4 pooled investment vehicles.

Source: Form ADV Part 1A, Items 5.D and 5.F, filed 6 May 2026

What services does Kultura Capital Management offer?

Kultura Capital Management provides portfolio management for pooled vehicles.

Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file

How many financial advisors does Kultura Capital Management have?

Kultura Capital Management has 0 investment adviser representatives registered with state securities authorities, out of 12 employees, and 5 perform investment advisory functions. None are registered representatives of a broker-dealer or licensed insurance agents.

Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file

Who owns Kultura Capital Management?

Kultura Capital Management’s direct owners are Kristov Paulus (75% or more), Dunyelle Rosen (25% to 50%) and Christopher Conforti (25% to 50%).

Source: Form ADV Part 1A, Schedules A and B, filed 6 May 2026

How does Kultura Capital Management get paid?

Kultura Capital Management is paid through a percentage of assets under management and performance-based fees. Its Form ADV lists no commissions among how it is paid.

Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file

How do I contact Kultura Capital Management?

Kultura Capital Management’s main office is at 1389 Center Drive, Suite 200, Park City, UT 84098. Its phone number is 248-228-2875. Its website is kulturacap.com.

Source: Form ADV Part 1A, Item 1.F, filed 6 May 2026

Sources and methodology

  1. Form ADV Part 1A, amendment filed 6 May 2026. Items 1, 5, 9, 11 and Schedules A, B and D.
  2. IAPD firm record, CRD 327510.
  3. SEC registered adviser data, annual Form ADV amendments filed 30 June 2025 to 6 May 2026. Items 1.F and 5.
  4. Form 13F-HR, filed 14 August 2026 for the quarter ended 30 June 2026.

Retrieved 15 October 2026. All are published by the SEC and may have been amended since. Disciplinary history is not yet shown here. The SEC publishes the complete record, including any disciplinary events, and it is the authoritative place to check one.

Download source data (JSON)How this directory is compiledReport a correction