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.
| Client type | Clients | Assets |
|---|---|---|
| Pooled investment vehicles | 100% | 100% |
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| Pooled investment vehicles | 4 | $245M | 100.0% | $61.2M |
| Total | 4 | $245M | 100% | $61.2M |
- 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
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.
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 McPhersonChief Financial Officer & Chief Compliance Officer
- Dunyelle RosenGeneral Counsel & Chief Operating Officer
- Kristov PaulusManaging Partner & CIO
Staff
- 12 employees
- 5 in advisory functions
- 1 soliciting firm
- Owns 75% or more of Kultura Capital Management LP
Kristov Paulus
Control person · since April 2023
- Owns 25% to 50% 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
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.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| May 2026 | $245M | 4 | 12 | 1 |
| June 2025 | $119M | 4 | 11 | 1 |
Besides its headquarters, Kultura Capital Management has 0 offices, with 1 listed address in Utah.
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
- Website
- kulturacap.com
- Phone
- 248-228-2875
- @kultura-capital
- SEC file
- 801-134057
- Structure
- Delaware limited partnership
- Fiscal year end
- December
Kultura Capital Management has custody of $245M in client assets for 4 clients.
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
- Invesco Qqq TR · Unit Ser 1Put15.0%
- Vaneck ETF Trust · Semiconductr ETFPut6.4%
- Intel Corp.5.2%
- Microsoft Corp.Call3.6%
- Broadcom Inc.Call3.3%
- Nokia Corp. · Sponsored ADRCall3.1%
- Applied Matls Inc.3.0%
- Super Micro Computer Inc.Put2.7%
- Roundhill ETF Trust · Memory ETFPut2.6%
- Sandisk Corp.2.5%
Together, the ten largest are 47.5% of reported value.
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.