Apogem Capital LLC: Manager Rating and Record

Why Apogem Capital LLC has two stars

Apogem runs USD 44 billion of regulatory assets and has been registered with the SEC since 2020. Its Form ADV lists seven matters. One concerns Apogem Capital itself, brought by the SEC in 2026; the others concern other companies in its group or individuals and count for less. Its one rated insurance-dedicated fund has three stars.

The rating looks only at the areas below, which matter to a family holding this manager's funds through a private placement policy. Past returns play no part: these funds do not report them in their SEC filings, and they say little about what a policy will earn.

Conduct and regulatory record

What regulators and courts have recorded against the manager, and for platform series against the platform, as the advisers report it to the SEC. Several proceedings on one set of facts count as one matter. Recent and serious matters count most, matters of other companies in the group count for less, matters of individuals are weighed by the person's role and their bearing on the business, and the size of the firm is taken into account.

Reported controls

What the adviser reports to the SEC for the fund: whether the accounts are audited every year by an accountant registered with the PCAOB and subject to its regular inspection, whether audited statements go to investors and what the audit opinion says, whether the administrator and custodian are outside the adviser's group, and what share of the assets was valued last year by a person not related to the adviser.

Depth and experience of the manager

The assets the manager runs, its investment staff and how long it has been registered with the SEC.

PPLI.comManager Rating

Investor experience. What policyholders, insurers and advisers tell us is shown separately and never changes the stars. A factual point they raise is checked against the filings, and if it holds, the data is corrected. We never publish names. Tell us about yours

The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the fund or its manager, not a credit rating, not a forecast of returns and not investment advice. Read about the rating.

Registration and size

Identity

Legal nameApogem Capital LLC

SEC registrationRegistered investment adviser, 801-118844 IAPD

CRD number309234

Latest Form ADV16 October 2026 ADV

Registered with the SEC since3 June 2020

Assets and staff, as filed

Regulatory assets under managementUSD 43,819,000,000

Of which discretionaryUSD 41,359,000,000

Employees259

Of which investment advisory staff127

Private funds listed in Schedule D114

Regulatory assets are calculated under the SEC's Form ADV instructions and include all funds and accounts the adviser manages, not only those open to insurers. Figures come from the SEC's adviser files of November 2026.

Regulatory and legal record

What the adviser itself discloses in Item 11 of its Form ADV, summarised from the disclosure pages, with a link to the filing. Item 11 is filed for the adviser as a whole, so under each matter the fund it concerns is read from the disclosure itself.

202625 February 2026

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

The SEC found that between March 2020 and May 2020, when the coronavirus pandemic disrupted the U.S. Financial Markets, Madison Capital funding LLC ("Madison Capital"), a predecessor firm to Apogem Capital, did not price principal trades made with Funds it advised at fair Market value, contrary to its representations to investors. Without admitting or denying the SEC'S findings, Madison Capital agreed to pay a civil money penalty in the amount of $900,000 and consented to a cease and desist order that included a censure.

US Securities and Exchange Commission · Order 25 February 2026 · USD 900,000 · Concerns the adviser itself · Form ADV, Item 11 disclosure

20257 August 2025