PRISMA FOCUS FUND SEC REVIEW 2026
INDEPENDENT VERDICT
Prisma Focus Fund is best understood as a long-running two-vehicle hedge-fund structure rather than a single new private offering. On September 18, 2026, both Prisma Focus Fund LP and Prisma Focus Fund Ltd filed Form D amendments. The U.S. vehicle, Prisma Focus Fund LP, is a Delaware limited partnership with SEC CIK 0001507908 and reports an indefinite Rule 506(b) offering, a first sale on October 1, 2010, $163,416,500 cumulatively sold and 77 investors. The offshore vehicle, Prisma Focus Fund Ltd, is a Cayman Islands corporation with SEC CIK 0001507909, the same October 1, 2010 first-sale date, an indefinite Rule 506(b) offering, $50,544,000 cumulatively sold and 20 investors. Both rely on Section 3(c)(7), both are classified as hedge funds, and both now use the same 660 Newport Center Drive, Suite 930, Newport Beach address. The two latest cumulative Form D figures total approximately $213.96 million when viewed together, but that arithmetic should be treated only as a parallel-vehicle capital reference. It is not proof that the two entities constitute a single master-feeder pool, and it is not current combined NAV. The SEC filings verify two legally separate issuers with a common manager and common launch date.
The management chain is unusually detailed. The 2026 U.S. filing identifies Prisma Capital Partners LLC as General Partner, Prisma Capital Partners I, LP as Managing Member of the General Partner, Prisma Capital Partners I, LLC as General Partner of that managing member, and Prisma Capital Partners LP as Investment Manager. The Cayman filing separately identifies Prisma Capital Partners LP as Investment Manager and names Wilson Tran, Scott P. Lennon and Alan Milgate as directors, with Lennon associated with 19 Degrees North Fund Services in Grand Cayman. This structure provides stronger evidence than a generic fund name because the manager can be followed through both Form D and investment-adviser records. Prisma Capital Partners LP, CRD 131467 / SEC file 801-63152, is no longer separately SEC registered; the SEC's Investment Adviser Public Disclosure system states that it transitioned to relying-adviser status on March 28, 2019. Current PAAMCO Prisma materials explain that Prisma operates as a relying adviser of PAAMCO Prisma, LLC, the SEC-registered filing adviser, and that the combined enterprise conducts a single advisory business under the PAAMCO Prisma name.
Prisma also has an unusually important ownership history. It was founded in the early 2000s as a specialist in customized hedge-fund portfolios and hedge fund-of-funds. KKR agreed to acquire Prisma in 2012, when Prisma reported approximately $7.8 billion of AUM and more than 90% of its assets were institutional. After the acquisition, KKR described KKR Prisma as its hedge-fund solutions platform, constructing customized portfolios across equity, credit, opportunistic and lower-volatility strategies. By year-end 2016, KKR reported that KKR Prisma managed approximately $9.9 billion. In June 2017, KKR combined Prisma with Pacific Alternative Asset Management Company to create PAAMCO Prisma Holdings. KKR's SEC filings describe PAAMCO Prisma as operating independently from KKR, with KKR initially holding 39.9% and management-related entities holding 60.1%. Current PAAMCO Prisma disclosures continue to describe Prisma Capital Partners LP as a wholly owned subsidiary of PAAMCO Prisma Holdings and a relying adviser within the combined advisory business. That history is directly relevant to Prisma Focus Fund because the fund survived the transition from independent Prisma, through KKR Prisma, into the PAAMCO Prisma structure without changing its SEC CIK or 2010 first-sale date.
The fund's strategy should nevertheless be handled carefully. Historic KKR disclosures describe Prisma as a hedge-fund solutions manager that built diversified portfolios using external specialist managers, quantitative portfolio construction and integrated risk management, while also operating some direct hedge-fund strategies. The very name "Focus Fund" suggests a more concentrated mandate than a broad low-volatility fund-of-funds, but the current Form D does not disclose the underlying managers, asset classes, gross or net exposure, liquidity, leverage or portfolio concentration. The two legal wrappers also have different subscription characteristics: the Cayman Ltd filing reports a $100,000 minimum investment, while the U.S. LP reports a $0 Form D minimum. Neither figure should be assumed to be the practical current subscription threshold without the PPM. Investors should also avoid treating historical KKR Prisma AUM, PAAMCO Prisma enterprise AUM or the $213.96 million combined cumulative Form D sales as the same metric. All three represent different levels of the structure.
There is also material litigation history at the manager level that belongs in a serious diligence review. Prisma Capital Partners LP and PAAMCO Prisma have been parties to long-running Kentucky pension litigation concerning alternative-investment mandates for Kentucky retirement systems. In January 2025, Kentucky announced a proposed $227.5 million settlement involving KKR, Prisma, PAAMCO and Blackstone-related defendants, with approximately $145 million of assets then held in a Prisma-controlled Daniel Boone Fund reserve potentially forming part of the recovery. However, KKR's June 2026 SEC filing states that the Kentucky trial court declined to approve the proposed settlement on May 12, 2025, causing that settlement agreement to terminate. The defendants continue to deny liability, wrongdoing and damages, and related proceedings remained active in 2026, including Kentucky Supreme Court oral argument in June. This litigation is manager-level history rather than evidence of misconduct by Prisma Focus Fund itself, and it should not be described as an SEC enforcement action. For a current investor, the core questions remain fund-level performance, manager allocation, liquidity, fees, valuation and whether the LP and Ltd wrappers participate in the same economic portfolio on identical terms.
SEC SNAPSHOT — U.S. VEHICLE
SEC FILE NUMBER: 021-155791 LATEST FORM D/A: September 18, 2026 FUND CLASSIFICATION: Hedge Fund FEDERAL EXEMPTION: Rule 506(b) OFFERING DURATION: More than one year LATEST CUMULATIVE AMOUNT SOLD: $163,416,500 LATEST REPORTED INVESTORS: 77 FORM D MINIMUM INVESTMENT: $0 SALES COMMISSIONS: $0 FINDERS' FEES: $0 RELATED-PERSON USE OF PROCEEDS: $0 CURRENT NAV: Declined to disclose FORM D SIGNER: Michael Levin SIGNER TITLE: Authorized Signatory
SEC SNAPSHOT — CAYMAN VEHICLE
SEC FILE NUMBER: 021-155790 LATEST FORM D/A: September 18, 2026 PRINCIPAL U.S. CONTACT ADDRESS: 660 Newport Center Drive, Suite 930, Newport Beach, CA 92660 FUND CLASSIFICATION: Hedge Fund FEDERAL EXEMPTION: Rule 506(b) OFFERING DURATION: More than one year LATEST CUMULATIVE AMOUNT SOLD: $50,544,000 LATEST REPORTED INVESTORS: 20 FORM D MINIMUM INVESTMENT: $100,000 SALES COMMISSIONS: $0 FINDERS' FEES: $0 RELATED-PERSON USE OF PROCEEDS: $0 CURRENT NAV: Declined to disclose FORM D SIGNER: Michael Levin SIGNER TITLE: Authorized Signatory
PARALLEL-VEHICLE CAPITAL
U.S. LP CUMULATIVE SOLD: $163,416,500 CAYMAN LTD CUMULATIVE SOLD: $50,544,000 ARITHMETIC COMBINED FIGURE: $213,960,500 IMPORTANT: The $213.96M figure is the arithmetic sum of two current cumulative Form D disclosures IMPORTANT: It is not verified combined current NAV IMPORTANT: It is not PAAMCO Prisma AUM IMPORTANT: It should not be described as a single fund's current assets unless governing documents establish a common economic pool IMPORTANT: Historical amendments must not be added to current amendments
U.S. MANAGEMENT CHAIN
MANAGING MEMBER OF GENERAL PARTNER: Prisma Capital Partners I, LP GENERAL PARTNER OF MANAGING MEMBER: Prisma Capital Partners I, LLC INVESTMENT MANAGER: Prisma Capital Partners LP MANAGER ADDRESS: 660 Newport Center Drive, Suite 930, Newport Beach, CA 92660 LEGAL CHAIN DEPTH: Explicitly disclosed in 2026 Form D
CAYMAN GOVERNANCE
INVESTMENT MANAGER: Prisma Capital Partners LP DIRECTOR: Wilson Tran DIRECTOR: Scott P. Lennon DIRECTOR: Alan Milgate SCOTT LENNON AFFILIATION SHOWN IN FORM D: 19 Degrees North Fund Services, Ltd. GRAND CAYMAN ADDRESS: Regatta Office Park CAYMAN ADMINISTRATIVE / DIRECTOR INFRASTRUCTURE: PUBLICLY VISIBLE EXACT CURRENT FUND ADMINISTRATOR: REQUIRES FUND DOCUMENTS EXACT CURRENT AUDITOR: REQUIRES FUND DOCUMENTS EXACT CURRENT PRIME BROKERS: NOT PUBLICLY DISCLOSED
ADVISER REGULATORY STATUS
LEGAL ADVISER NAME: Prisma Capital Partners LP SEC FILE NUMBER: 801-63152 FORMER / ALTERNATE NAMES: Prisma; KKR Prisma; PAAMCO Prisma CURRENT SEPARATE SEC REGISTRATION STATUS: Not separately registered STATUS CHANGE: Transitioned to relying adviser EFFECTIVE DATE OF RELYING-ADVISER STATUS: March 28, 2019 FILING ADVISER: PAAMCO Prisma, LLC CURRENT ADVISORY BRAND: PAAMCO Prisma CURRENT BUSINESS MODEL: Combined advisory enterprise IMPORTANT: "Not separately registered" does not mean Prisma operates without an SEC-registered adviser structure; it operates as a relying adviser under the filing adviser
PRISMA CORPORATE HISTORY
PRISMA FOUNDING PERIOD: Early 2000s FORMER CORE BUSINESS: Customized hedge fund portfolios and hedge fund-of-funds KKR ACQUISITION AGREEMENT: June 2012 KKR ACQUISITION COMPLETION: October 1, 2012 PRISMA AUM AROUND APRIL 2012: Approximately $7.8 billion INSTITUTIONAL SHARE OF AUM IN 2012: More than 90% KKR PRISMA 2014 HEDGE-FUND-OF-FUNDS AUM: Approximately $10.2 billion KKR PRISMA 2016 AUM: Approximately $9.9 billion PAAMCO / PRISMA COMBINATION: June 1, 2017 NEW HOLDING COMPANY: PAAMCO Prisma Holdings, LLC AUM / AUA AT 2017 COMBINATION: More than $30 billion KKR INITIAL OWNERSHIP OF HOLDING COMPANY: 39.9% OTHER HOLDING-COMPANY OWNERSHIP: 60.1% management-related ownership disclosed at formation OPERATING STATUS AFTER 2017: Independent from KKR according to KKR SEC filings CURRENT PRISMA RELATIONSHIP: Wholly owned subsidiary of PAAMCO Prisma Holdings according to current adviser materials
HISTORICAL STRATEGY EVIDENCE
CORE PRISMA MODEL: Customized hedge fund portfolios COMMON STRUCTURE: Hedge fund-of-funds MANAGER SELECTION: External specialist hedge fund managers PORTFOLIO CONSTRUCTION: Integrated quantitative and qualitative framework HISTORICAL STRATEGY CATEGORIES: Low volatility; Equity; Credit; Opportunistic CLIENT TYPES: Institutional investors; pooled vehicles; separate accounts HISTORICAL KKR DESCRIPTION: Specialist manager-selection approach DIRECT HEDGE FUND STRATEGIES: Historically also operated by Prisma FOCUS FUND EXACT CURRENT STRATEGY: NOT PUBLICLY DISCLOSED IN FORM D FOCUS FUND EXACT UNDERLYING MANAGERS: NOT PUBLICLY DISCLOSED FOCUS FUND EXACT LONG / SHORT EXPOSURE: NOT PUBLICLY DISCLOSED FOCUS FUND EXACT ASSET-CLASS MIX: NOT PUBLICLY DISCLOSED
ADDRESS / OPERATING HISTORY
2010-ERA ADDRESS: One Penn Plaza, Suite 3515, New York, NY 10119 LATER NEW YORK ADDRESS: 9 West 57th Street, New York, NY 10019 CURRENT ADDRESS: 660 Newport Center Drive, Suite 930, Newport Beach, CA 92660 CURRENT PHONE: (949) 261-4900 INTERPRETATION: Address changes are consistent with Prisma's ownership and PAAMCO Prisma organizational evolution IMPORTANT: Address changes do not imply a new fund because CIK and first-sale history remain continuous
ENTITY STRUCTURE — DO NOT MERGE
PRISMA FOCUS FUND LP: Delaware U.S. private hedge fund PRISMA FOCUS FUND LTD: Cayman Islands offshore hedge fund vehicle PRISMA CAPITAL PARTNERS LLC: General Partner of U.S. LP PRISMA CAPITAL PARTNERS I, LP: Managing Member of U.S. General Partner PRISMA CAPITAL PARTNERS I, LLC: GP of that managing-member entity PRISMA CAPITAL PARTNERS LP: Investment Manager / relying adviser PAAMCO PRISMA, LLC: SEC-registered filing adviser PAAMCO PRISMA HOLDINGS, LLC: Holding company KKR: Historical owner of Prisma and continuing minority economic owner of PAAMCO Prisma Holdings structure disclosed in adviser materials IMPORTANT: Similar names do not make these entities interchangeable
MASTER-FEEDER QUESTION
COMMON FIRST SALE DATE: October 1, 2010 COMMON MANAGER: Prisma Capital Partners LP COMMON CURRENT ADDRESS: CONFIRMED PARALLEL U.S. / CAYMAN STRUCTURE: CONFIRMED MASTER-FEEDER STATUS: NOT ESTABLISHED BY CURRENT FORM D ECONOMIC PARALLELISM: PLAUSIBLE BUT REQUIRES PPM / ADV PRIVATE-FUND SCHEDULE CONFIRMATION CURRENT ASSET CROSS-OWNERSHIP: NOT PUBLICLY ESTABLISHED IMPORTANT: Do not describe LP and Ltd as master and feeder solely from naming and timing
WEBSITE / ENTITY PENETRATION
Prisma Focus Fund LP SEC issuer — CONFIRMED Prisma Focus Fund Ltd SEC issuer — CONFIRMED U.S. CIK 0001507908 — CONFIRMED Cayman CIK 0001507909 — CONFIRMED September 18, 2026 amendments — CONFIRMED October 1, 2010 first sale for both — CONFIRMED U.S. LP $163.4165M cumulative sales — CONFIRMED Cayman Ltd $50.544M cumulative sales — CONFIRMED U.S. LP 77 investors — CONFIRMED Cayman Ltd 20 investors — CONFIRMED Rule 506(b) — CONFIRMED Section 3(c)(7) — CONFIRMED Prisma Capital Partners LP investment manager — CONFIRMED Prisma Capital Partners LLC GP — CONFIRMED PAAMCO Prisma filing-adviser relationship — CONFIRMED Prisma relying-adviser status — CONFIRMED Historical KKR ownership — CONFIRMED 2017 PAAMCO Prisma combination — CONFIRMED Current PAAMCO Prisma website — CONFIRMED Current fund NAV — NOT PUBLICLY DISCLOSED Current gross exposure — NOT PUBLICLY DISCLOSED Current underlying managers — NOT PUBLICLY DISCLOSED Current management fee rate — REQUIRES OFFERING DOCUMENTS Current incentive allocation — REQUIRES OFFERING DOCUMENTS Current redemption terms — REQUIRES OFFERING DOCUMENTS Current lockup — REQUIRES OFFERING DOCUMENTS Current auditor — REQUIRES OFFERING DOCUMENTS Current administrator — REQUIRES OFFERING DOCUMENTS Current prime brokers — REQUIRES OFFERING DOCUMENTS
KENTUCKY PENSION LITIGATION CONTEXT
PARTY: Prisma Capital Partners LP RELATED PARTY: PAAMCO Prisma, LLC OTHER DEFENDANTS HAVE INCLUDED: KKR-related and Blackstone-related parties SUBJECT: Kentucky public pension alternative-investment mandates and related contractual / fiduciary allegations 2017 ACTION: Earlier private-plaintiff action ultimately affected by Kentucky standing rulings 2020 / 2024 ACTIONS: Commonwealth-related litigation continued PROPOSED SETTLEMENT ANNOUNCED: January 8, 2025 PROPOSED AGGREGATE RECOVERY: $227.5 million PRISMA-CONTROLLED DANIEL BOONE FUND RESERVE REFERENCED: Approximately $145 million at time of proposed settlement COURT APPROVAL: NOT OBTAINED TRIAL COURT ACTION: Declined proposed settlement order on May 12, 2025 SETTLEMENT STATUS: Terminated because approval condition failed 2026 STATUS: Related litigation remained active KENTUCKY SUPREME COURT ORAL ARGUMENT: June 17, 2026 DEFENDANTS' POSITION: Deny liability, wrongdoing and damages SEC ENFORCEMENT ACTION AGAINST PRISMA FOCUS FUND: NONE IDENTIFIED IN SOURCES REVIEWED IMPORTANT: Litigation allegations are not adjudicated findings against Prisma Focus Fund IMPORTANT: Proposed settlement should not be described as completed or effective
CAPITAL INTERPRETATION
$163.4165M: Latest cumulative Form D sales for U.S. LP $50.544M: Latest cumulative Form D sales for Cayman Ltd $213.9605M: Arithmetic total of current cumulative sales figures $213.9605M IS NOT: Verified current combined NAV $213.9605M IS NOT: PAAMCO Prisma AUM $7.8B: Historical Prisma firm AUM around 2012 $9.9B: Historical KKR Prisma AUM at year-end 2016 $30B+: Historical combined PAAMCO Prisma AUM / advisement scale at 2017 formation NONE OF THOSE MANAGER FIGURES: Establish current Focus Fund NAV REDEMPTIONS: Not captured by cumulative amount sold PORTFOLIO PROFITS / LOSSES: Not reflected in Form D sales PARALLEL INVESTOR OVERLAP: Unknown
CORE INVESTOR QUESTIONS
Are Prisma Focus Fund LP and Prisma Focus Fund Ltd economically parallel vehicles Do both invest in the same master portfolio Is either vehicle a feeder If not, how do their portfolios differ Why does the Cayman vehicle require $100,000 in Form D while the U.S. LP reports $0 What is the actual current minimum subscription for each vehicle What is current NAV of the U.S. LP What is current NAV of the Cayman Ltd What is current combined strategy AUM How many investors remain active today How much capital has been redeemed since 2010 What is annualized net return since inception What is annualized volatility What is maximum drawdown What was the longest recovery period What was performance in 2011 What was performance in 2015-2016 What was performance in March 2020 What was performance in 2022 What was performance in 2025-2026 How many external hedge-fund managers are currently used What percentage is allocated to the five largest managers What is the largest single-manager allocation How much exposure is to equity long/short How much is credit How much is macro How much is relative value How much is event-driven How much is quantitative Does the fund allocate to multi-strategy platforms Can it make direct investments Can it use managed accounts instead of commingled third-party funds What percentage of underlying assets have monthly liquidity What percentage have quarterly liquidity What percentage are subject to gates What percentage are side-pocketed What is the look-through gross exposure What is the look-through net exposure What is the look-through leverage What percentage is exposed to crowded trades What valuation policy applies to illiquid underlying funds Who independently verifies underlying manager valuations How are manager-level gates treated in the Focus Fund NAV Can Prisma suspend redemptions Can it create side pockets What management fee does Prisma charge What incentive fee does Prisma charge How much underlying-manager fee layering exists Are underlying incentive fees netted before Prisma-level fees Does a high-water mark apply What redemption notice applies Is there an initial lockup What investor-level gates apply Who is the current administrator Who is the auditor Who are the prime brokers or custodians What role does 19 Degrees North currently perform How does PAAMCO Prisma allocate opportunities across Prisma Focus and other client accounts What conflicts arise from managed accounts versus commingled funds What economic interest does KKR currently retain in PAAMCO Prisma Holdings Does the Kentucky litigation create any fund-level indemnification or expense exposure Are Prisma Focus assets legally segregated from Daniel Boone Fund assets
CORE RISKS
Multi-manager hedge-fund risk; fund-of-funds fee layering; underlying-manager selection risk; manager concentration; style drift; hidden leverage; look-through leverage; liquidity mismatch; redemption gates; side pockets; underlying-fund suspension risk; valuation uncertainty; derivative exposure; counterparty risk; short-selling risk; macro risk; equity risk; credit risk; event-driven risk; operational dependence on external managers; fraud risk at an underlying manager; limited transparency; correlation spikes; crowded trades; long investment history does not guarantee future performance; cumulative subscriptions do not equal current NAV; U.S. and Cayman vehicles may have different tax and liquidity terms; manager-level litigation risk; ongoing Kentucky proceedings; historical KKR affiliation should not be confused with current KKR control.
PRIMARY EVIDENCE REVIEWED
U.S. SECURITIES AND EXCHANGE COMMISSION Prisma Focus Fund LP CIK 0001507908 Form D/A September 18, 2026
U.S. SECURITIES AND EXCHANGE COMMISSION Prisma Focus Fund Ltd CIK 0001507909 Form D/A September 18, 2026
U.S. SECURITIES AND EXCHANGE COMMISSION Historical Prisma Focus Fund filings 2010-2026 Used to establish first-sale date, manager continuity and address history
SEC INVESTMENT ADVISER PUBLIC DISCLOSURE Prisma CRD 131467 SEC File 801-63152 Relying-adviser status
PAAMCO PRISMA Official website Terms of Use Adviser structure Prisma relying-adviser relationship
KKR SEC FILINGS 2012 Prisma acquisition Historical KKR Prisma AUM 2017 PAAMCO Prisma combination 39.9% KKR ownership disclosure Independent operating structure
KENTUCKY COURT OF JUSTICE 2026 Supreme Court oral-argument docket PAAMCO Prisma and related proceedings
KKR 2026 SEC QUARTERLY REPORT Kentucky litigation status Failed 2025 settlement approval Continuing denial of liability and wrongdoing
IMPORTANT FORM D NOTICE
Form D is a notice of an exempt securities offering.
It does not mean that the SEC has approved Prisma Focus Fund, Prisma Capital Partners, PAAMCO Prisma, any underlying hedge-fund manager or any investment strategy.
The September 18, 2026 amendments report $163.4165 million cumulatively sold by the U.S. LP and $50.544 million cumulatively sold by the Cayman Ltd vehicle.
Those figures demonstrate substantial historical subscription activity.
They do not establish current NAV.
They should not be added to historical amendments.
And the two current figures should not be represented as one verified fund balance unless the governing documents establish a common economic portfolio.
INDEPENDENT ASSESSMENT
Prisma Focus Fund has a particularly strong regulatory-history story.
Both the Delaware and Cayman vehicles date their first sale to October 1, 2010.
Both continue filing in 2026.
Both are tied directly to Prisma Capital Partners.
And Prisma itself can be traced from an independent hedge-fund solutions manager, through KKR ownership, into today's PAAMCO Prisma relying-adviser structure.
That makes basic entity verification relatively strong.
The more important issue is structural and economic transparency.
The current SEC filings show two issuers with approximately $163.4 million and $50.5 million cumulatively sold, but they do not establish whether those vehicles feed the same portfolio, hold exactly the same managers or provide identical liquidity and fee economics.
That distinction matters more than simply adding the two amounts.
The Kentucky pension litigation also deserves disclosure because Prisma Capital Partners is directly involved.
But it must be described accurately.
A $227.5 million settlement was proposed in 2025, the required court approval was not obtained, and the agreement terminated.
The defendants continue to deny liability and the related litigation remained active in 2026.
That is litigation history, not an SEC finding against Prisma Focus Fund.
For a prospective investor, the highest-value diligence documents are therefore the current PPMs, audited financial statements, current NAV statements, manager-allocation schedule, look-through exposure report, redemption terms, fee schedule and confirmation of the legal relationship between the U.S. and Cayman vehicles.
The fund's existence is well documented.
The manager's history is unusually traceable.
The remaining investment question is what the portfolio owns today, what investors actually pay and how the strategy has performed after all layers of fees.