INDEPENDENT VERDICT
Epigram Capital Partners Fund I is a relatively small but highly differentiated public-equity hedge fund built around one manager's research process rather than a large multi-team institutional platform. The September 8, 2026 Form D/A reports $12,291,750 sold to 21 investors, a $500,000 minimum investment, an indefinite Rule 506(b) offering and reliance on Investment Company Act Section 3(c)(1). Epigram Capital LLC is named directly as Investment Manager, Epigram Capital Partners Fund I GP LLC is General Partner and Daniel David Walker is identified as Manager of the Investment Manager. Epigram's own website independently describes a boutique Omaha investment firm specializing in small- and mid-cap equities and says it deliberately looks within the smallest roughly 20% of public companies for mispriced opportunities, often in mundane industries that attract limited investor attention. The strongest feature of this fund is therefore strategy clarity; the largest diligence gaps are actual portfolio holdings, realized performance, liquidity, concentration and how much of the investment process depends on Walker personally.
THE CAPITAL HISTORY SHOWS A REAL FUND LAUNCH RATHER THAN A PAPER VEHICLE
Epigram Capital Partners Fund I was formed in Delaware in 2024 and filed its first Form D in August of that year before its first sale. The latest amendment identifies October 15, 2024 as the first-sale date. By October 2025, the fund had reported approximately $11.34 million sold, and the September 2026 amendment increased cumulative subscriptions to $12.29175 million. The latest increase is therefore $950,000 rather than a new $12.3 million fundraise. Twenty-one investors are now reported, with a $500,000 minimum investment. The fund reports no sales commissions and no finder's fees, but Item 16 estimates $35,800 of gross proceeds for payments to related persons. The filing explains that organizational expenses will be reimbursed to the General Partner and Investment Manager and that the Investment Manager will receive a management fee under the offering documents.
That $35,800 is only about 0.29% of the current cumulative amount sold, but it should not be interpreted as the total fee burden. Form D does not disclose the management-fee percentage, incentive allocation, audit expense, administration, tax preparation, legal costs or trading expenses. Investors therefore need the limited partnership agreement and audited statements to understand the actual all-in expense ratio.
EPIGRAM IS BUILT AROUND THE PART OF THE STOCK MARKET MOST LARGE MANAGERS OFTEN IGNORE
Epigram's public investment thesis is unusually specific. The firm says it focuses on the smallest approximately 20% of public companies and searches for mispricing in businesses that often receive little attention from institutional investors or Wall Street analysts. Many of the target companies operate in ordinary or obscure industries rather than fashionable technology themes. The manager explicitly argues that deep knowledge of obscure securities is research intensive but can produce differentiated returns when fewer professional investors are competing for the same information.
This creates a very different opportunity set from a conventional S&P 500-oriented long-only manager. Small-cap and lower-mid-cap stocks can have limited analyst coverage, fewer institutional shareholders, lower trading volumes and more company-specific complexity. Those conditions can create inefficiencies, but they also increase liquidity and information risk. A manager may uncover a genuinely mispriced business, but exiting a meaningful position can become difficult during market stress if daily volume is limited.
Epigram also states that its objective is to generate idiosyncratic returns that are less dependent on a strong economy or rising stock market. That suggests the manager is seeking company-specific alpha rather than simply loading on small-cap beta. Form D, however, does not reveal whether the partnership is permitted to short securities, use options, hold cash aggressively or hedge market exposure. The actual portfolio construction rules must therefore be obtained from the offering documents.
DAN WALKER'S BACKGROUND IS THE CENTRAL UNDERWRITING FACTOR
Epigram identifies Dan Walker, CFA, as CEO. SEC filings use his full legal name, Daniel David Walker. His career is directly relevant to the fund's strategy. Epigram's biography states that Walker previously served as Director of Research at Bridges Trust, a large Omaha-based adviser, where he was department head and portfolio lead on three strategies. The firm biography describes Bridges at roughly $10 billion of AUM during Walker's tenure, while a 2026 Omaha Community Foundation profile describes it as a roughly $12 billion adviser and states that Walker helped lead strategies representing more than $2 billion of assets.
Before Bridges, Walker worked as an equity analyst at Weitz Investment Management and Heartland Advisors. Both firms have long histories in fundamental equity investing, and Heartland in particular has significant small-cap and value-investing experience. Walker earned an MBA through the University of Wisconsin-Madison's Applied Security Analysis Program and holds the CFA charter.
That history provides a logical progression into Epigram: fundamental security research at established managers, responsibility for institutional portfolios and then formation of a boutique partnership focused on neglected public equities.
But the same structure creates key-person concentration. Public materials identify Walker as the central portfolio and research figure, while no similarly visible bench of multiple senior analysts or co-portfolio managers is disclosed. Investors should therefore understand what happens if Walker becomes unavailable and whether portfolio knowledge, valuation work and trading responsibility are documented sufficiently for another professional to operate the fund.
THE ADVISER IS NOT CURRENTLY PRESENTED AS A LARGE SEC-REGISTERED RIA
Epigram Capital LLC appears in investment-adviser records under CRD 332352. Reviewed regulatory records describe the firm as registered in Nebraska rather than as an SEC-registered investment adviser, and its Form ADV reports Epigram Capital Partners Fund I as its single private fund under private fund ID 805-2907134913.
This distinction matters.
The fact that Form ADV is accessible through IAPD does not by itself mean Epigram Capital is SEC registered. State-registered advisers also file Form ADV through the regulatory system. FilingDossier therefore does not label Epigram an SEC-registered RIA.
The fund itself remains a private Regulation D issuer and is not a registered investment company.
A 3(c)(1) structure also generally limits the number and type of beneficial owners compared with a conventional public investment product, which is consistent with Epigram's relatively small number of investors.
THE $12.3 MILLION FUND SIZE CAN BE BOTH AN ADVANTAGE AND A LIMITATION
Small-cap investing creates a capacity tradeoff.
At approximately $12.3 million of cumulative subscriptions, Epigram can potentially build meaningful positions in smaller public companies without requiring enormous trading volume. A $500,000 position, for example, would represent roughly 4% of a $12.3 million portfolio before accounting for redemptions or performance. That size can allow the fund to investigate businesses too small to matter for multibillion-dollar asset managers.
A larger manager with $10 billion might need to invest $100 million or more for a position to materially affect returns. Many sub-billion-dollar companies simply cannot absorb such buying without creating ownership or liquidity problems.
Epigram's small asset base can therefore expand its investable universe.
The disadvantage is operating leverage. Audit, legal, tax, administration, compliance and data expenses can consume a larger percentage of a $12 million fund than a $500 million fund. Investors should review whether the manager absorbs any expenses, whether there is an expense cap and how organizational and operating costs are allocated.
SMALL-CAP LIQUIDITY IS ONE OF THE MOST IMPORTANT RISKS
The smallest public companies can have very low average daily trading volume. A fund may own a security that appears liquid under normal conditions but becomes difficult to exit during a market shock, earnings disappointment or company-specific event.
This creates an important difference between reported market value and realizable liquidation value.
If Epigram holds concentrated positions in thinly traded stocks, an investor redemption can force the manager to choose among: selling the most liquid holdings first; accepting a large market-impact discount; temporarily increasing concentration; or imposing redemption restrictions if permitted by fund documents.
The fund's redemption terms therefore need to be evaluated alongside portfolio liquidity rather than separately.
Investors should request the percentage of NAV that could reasonably be liquidated within one, five, ten and thirty trading days under both normal and stressed market-volume assumptions.
OBSCURE SECURITIES ALSO CREATE INFORMATION ADVANTAGES AND INFORMATION RISKS
Epigram's strategy depends on doing more work than the market.
That can mean reading small-company filings, studying niche industries, speaking with competitors and customers, understanding capital allocation and building detailed valuation frameworks for businesses that may have little sell-side research.
This research intensity can create an informational advantage.
But thinly followed companies can also have weaker internal controls, less sophisticated investor relations, greater customer concentration and higher management-dependence than large-cap businesses. Earnings can be volatile, accounting judgments can have a larger impact and unexpected financing needs can produce severe dilution.
Investors should therefore understand not only how Epigram finds companies but also how it identifies fraud, accounting risk, governance problems and permanent capital loss.
THE MANAGER'S OWN WRITING SHOWS A LONG-HORIZON, EXPECTATIONS-BASED PHILOSOPHY
Walker publishes investment commentary through Epigram's website. His 2026 writing on realistic expectations explicitly discusses long-term return assumptions and uses the Russell 2000's historical ten-year return experience as a reference point for how investors think about expected returns. The broader theme is skepticism toward precise forecasting and a preference for realistic long-term expectations rather than promotional short-term targets.
That communication style fits Epigram's stated strategy of deep research into less-followed companies.
It is useful qualitative evidence about investment philosophy, but it is not a substitute for audited performance.
An investor still needs actual monthly and annual returns since October 2024.
PERFORMANCE IS THE LARGEST MISSING PUBLIC DATA SET
Neither Form D nor Epigram's public site provides enough independently verified information to establish the partnership's realized track record.
Public records reviewed for this article do not establish: 2024 net return; 2025 net return; 2026 year-to-date return; maximum drawdown; volatility; Sharpe ratio; Russell 2000 alpha; gross exposure; net exposure; cash allocation; portfolio turnover; or realized versus unrealized contribution.
This is particularly important because Epigram explicitly positions itself as a source of differentiated returns.
Differentiation should be measured, not assumed.
Investors should compare the fund against an appropriate small-/mid-cap benchmark over a full market cycle and examine whether any outperformance is attributable to stock selection, sector bets, market timing or factor exposures such as value, quality, size and illiquidity.
THE 21-INVESTOR BASE IS STILL CONCENTRATED
At $12.29175 million sold across 21 investors, the simple arithmetic average is approximately $585,000 per investor, although actual allocations may differ substantially.
That average sits only modestly above the $500,000 stated minimum.
This could indicate a relatively evenly distributed LP base, but Form D does not disclose individual commitments.
A small number of larger LPs could still represent a significant percentage of assets.
Investor concentration matters because a single multimillion-dollar redemption could force material portfolio changes in a strategy focused on less-liquid securities.
FINAL ASSESSMENT
Epigram Capital Partners Fund I has a clear and unusually coherent public identity. SEC records directly connect the partnership, Epigram Capital Partners Fund I GP LLC, Epigram Capital LLC and Daniel David Walker. Form ADV independently identifies the fund as Epigram Capital's private fund, and Epigram's official website describes a strategy that closely fits the hedge-fund vehicle: concentrated research into overlooked small- and mid-cap public companies, particularly obscure businesses and industries where limited investor attention may create mispricing.
The fund has also achieved meaningful but controlled capital formation. From a pre-sale Form D in 2024, cumulative subscriptions reached approximately $11.34 million by 2025 and $12.29 million by September 2026. The latest structure remains small enough to potentially exploit lower-capacity opportunities that cannot meaningfully affect large institutional portfolios.
The primary diligence questions are performance, portfolio concentration and liquidity. Investors should not infer successful stock selection merely from Walker's institutional background or Epigram's differentiated philosophy. Audited net returns, drawdowns, position-level liquidity, expense ratios and key-person protections are required to determine whether the research advantage described publicly has translated into investor returns.
KEY FINDINGS
Epigram Capital Partners Fund I LP was formed in Delaware in 2024.
CIK: 0002032582.
Private fund ID: 805-2907134913.
First sale: October 15, 2024.
Latest Form D/A: September 8, 2026.
Latest amount sold: $12,291,750.
Latest investors: 21.
Minimum investment: $500,000.
Offering: Indefinite.
Exemption: Rule 506(b).
Investment Company Act exclusion: Section 3(c)(1).
SEC classification: Hedge Fund.
Sales commissions: $0.
Finder's fees: $0.
Estimated related-person proceeds: $35,800.
General Partner: Epigram Capital Partners Fund I GP, LLC.
Investment Manager: Epigram Capital, LLC.
Manager: Daniel David Walker.
Public name: Dan Walker, CFA.
Official domain: epigramcapital.com.
Epigram specializes in small- and mid-cap public equities.
The firm says it focuses particularly on the smallest approximately 20% of public companies.
The strategy emphasizes overlooked, research-intensive securities and ordinary industries with limited investor attention.
Epigram Capital appears under CRD 332352.
Reviewed adviser records describe Epigram as Nebraska registered rather than as an SEC-registered RIA.
FORM D CAPITAL HISTORY
August 13, 2024 New Form D. Amount sold: $0. First sale had not yet occurred at filing.
First sale: October 15, 2024.
October 16, 2025 Cumulative amount sold: $11,341,750.
September 8, 2026 Cumulative amount sold: $12,291,750.
2026 increase: $950,000.
Latest investor count: 21.
Minimum investment: $500,000.
Do not add annual cumulative Form D amounts together.
MANAGEMENT STRUCTURE
Issuer: Epigram Capital Partners Fund I, LP
General Partner: Epigram Capital Partners Fund I GP, LLC
Investment Manager: Epigram Capital, LLC
Manager of Investment Manager: Daniel David Walker
Official public manager name: Dan Walker, CFA
All use the same Omaha management ecosystem.
DAN WALKER BACKGROUND
Current: CEO, Epigram Capital
Prior: Director of Research, Bridges Trust
Epigram biography describes Bridges as a roughly $10B adviser during his tenure.
Independent Omaha Community Foundation biography describes Bridges as approximately $12B AUM and states Walker served as portfolio lead on three strategies representing more than $2B.
Prior: Equity Analyst, Weitz Investment Management
Prior: Equity Analyst, Heartland Advisors
Education: MBA, Applied Security Analysis Program University of Wisconsin-Madison
Professional designation: CFA Charterholder
The prior firms are historical employers and do not sponsor or endorse Epigram Capital Partners Fund I.
EPIGRAM INVESTMENT PHILOSOPHY
Primary universe: Small-cap equities Mid-cap equities
Publicly stated focus: Smallest approximately 20% of listed companies
Manager preference: Underfollowed securities Obscure businesses Mundane industries Research-intensive opportunities
Primary objective: Capital appreciation Compelling risk-adjusted returns Idiosyncratic returns Lower dependence on broad economic or equity-market strength
The precise long/short, hedging and leverage permissions of the fund should be verified from the offering documents.
WHY SMALL SIZE MAY MATTER
Potential advantages: Larger investable universe among small companies Ability to build meaningful positions without requiring institutional-scale liquidity Potentially lower market impact Ability to exploit research-intensive opportunities too small for large managers Greater portfolio flexibility
Potential disadvantages: Higher fixed expenses as a percentage of assets Investor concentration Key-person dependence Limited internal team scale Potential difficulty absorbing large redemptions Thin trading liquidity in underlying positions
RELATED-PERSON PROCEEDS
Latest estimated amount: $35,800.
Form D explanation: Organizational expenses will be reimbursed to the General Partner and Investment Manager.
The filing additionally states: A management fee will be paid to the Investment Manager in accordance with the Issuer's offering documents.
The $35,800 is not the complete management-fee disclosure and should not be treated as total fund expenses.
WEBSITE / ENTITY PENETRATION
Epigram Capital Partners Fund I: Confirmed.
CIK: Confirmed.
Private Fund ID: Confirmed through Form ADV.
Epigram Capital Partners Fund I GP: Confirmed.
Epigram Capital LLC: Confirmed.
Dan / Daniel Walker relationship: Confirmed.
Omaha location: Confirmed.
1514 S. 106th Street: Confirmed through regulatory filings.
Official domain: epigramcapital.com.
Small-/mid-cap strategy: Confirmed.
Smallest-20%-of-market investment focus: Confirmed.
Bridges Trust background: Confirmed.
Weitz background: Confirmed.
Heartland background: Confirmed.
CFA designation: Confirmed.
Current exact portfolio: Not publicly disclosed.
Largest positions: Not publicly disclosed.
Number of holdings: Not publicly disclosed.
Gross exposure: Not publicly disclosed.
Net exposure: Not publicly disclosed.
Short exposure: Not established from Form D.
Derivatives exposure: Not established.
Current NAV: Not publicly established.
Audited performance: Not publicly established.
Management fee percentage: Not disclosed in Form D.
Incentive fee: Not disclosed in Form D.
Current auditor: Not established from reviewed public Form D.
Current administrator: Not established from reviewed public Form D.
Current prime broker / custodian: Not sufficiently established from reviewed public sources.
CORE INVESTOR QUESTIONS
What is current fund NAV
How does NAV compare with $12.29175M cumulative Form D subscriptions
How much capital has been redeemed since launch
What were net returns in 2024, 2025 and 2026
What is cumulative return since October 2024
What is maximum drawdown
What is annualized volatility
What is Sharpe ratio
What is alpha versus the Russell 2000
What is alpha versus an appropriate small-cap value benchmark
How many positions does the fund normally hold
What is the largest permitted position
What percentage of NAV is in the ten largest positions
What is weighted-average market capitalization
What percentage is invested below $500M market capitalization
What percentage is micro-cap
What percentage of portfolio can be liquidated within five trading days
Does the fund short securities
Can it use options or derivatives
Can it borrow on margin
What gross exposure limit applies
What net exposure limit applies
What management fee applies
What incentive allocation applies
Is there a high-water mark
Is there a hurdle rate
What is the annual operating expense ratio
Does the manager absorb or cap expenses
Who is the auditor
Who is the fund administrator
Who holds custody of securities
What redemption notice applies
Are there gates
Can redemptions be suspended
What percentage of NAV is represented by the largest investor
What succession plan applies if Dan Walker is unavailable
Does Epigram employ additional investment analysts
How are research conclusions independently challenged
CORE RISKS
Small-cap market risk Micro-cap risk if applicable Liquidity risk Bid-ask spread risk Company-specific concentration Limited analyst coverage Accounting and governance risk Management-quality risk Key-person dependence Investor redemption concentration Small fund operating-cost burden Private fund illiquidity Valuation risk in thinly traded securities Potential style-factor concentration Economic sensitivity of smaller companies Limited public performance information Risk of assuming manager pedigree guarantees investment performance
SEC SNAPSHOT
Issuer: Epigram Capital Partners Fund I, LP
CIK: 0002032582
Latest Form: D/A
Filed: September 8, 2026
First Sale: October 15, 2024
Formation: Delaware, 2024
Address: 1514 S. 106th Street Omaha, Nebraska 68124
Phone: 414-255-5454
Industry: Pooled Investment Fund / Hedge Fund
Security: Pooled Investment Fund Interests
Exemption: Rule 506(b)
Investment Company Act exclusion: Section 3(c)(1)
Offering: Indefinite
Amount Sold: $12,291,750
Investors: 21
Minimum Investment: $500,000
Offering longer than one year: Yes
Sales Commissions: $0
Finder's Fees: $0
Estimated Related-Person Proceeds: $35,800
General Partner: Epigram Capital Partners Fund I GP, LLC
Investment Manager: Epigram Capital, LLC
Manager: Daniel David Walker
PRIMARY EVIDENCE REVIEWED
SEC Form D — Epigram Capital Partners Fund I LP, August 13, 2024 SEC Form D/A — Epigram Capital Partners Fund I LP, October 16, 2025 SEC Form D/A — Epigram Capital Partners Fund I LP, September 8, 2026 Form ADV — Epigram Capital LLC, CRD 332352 Form ADV private fund schedule — Epigram Capital Partners Fund I LP Epigram Capital — official website Epigram Capital — official About page Epigram Capital — official Manager Biography Epigram Capital — published investment commentary Omaha Community Foundation — 2026 Dan Walker professional biography
IMPORTANT FORM D NOTICE
Form D is a notice of an exempt securities offering. Filing with the SEC does not mean the SEC has approved, endorsed, audited or verified Epigram Capital Partners Fund I, Epigram Capital, Dan Walker, any portfolio security, investment strategy, historical performance or expected return.
Epigram Capital's appearance in IAPD does not by itself mean it is an SEC-registered adviser; reviewed records describe it as a Nebraska-registered advisory firm. The latest $12.29175 million Form D amount sold represents cumulative securities sold and should not automatically be treated as current fund NAV.
Investors should independently review audited financial statements, portfolio concentration, position liquidity, management and incentive fees, redemption terms, expense allocation, custody, service providers and realized performance before investing.