Investment adviser · CRD 313323

SHRUG, LLC

Exempt reporting adviser (ERA)

Exempt reporting advisers use a shorter Form ADV report. Some adviser-level figures are not reported; fund disclosures appear below when available.

· Form ADV filed Apr 12, 2026

Adviser-level assets, account counts and staffing figures are unavailable in this filing. View the reported fund disclosures below →

Private funds & service providers

11 Private funds

The count excludes feeder funds. Funds in the latest filing appear first, ordered by reported gross assets. Earlier funds retain their last reported values.

SHRUG IV, L.P.Venture Capital Fund · Last reported Apr 12, 2026$51MGross asset value
Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Auditor FRANK, RIMERMAN & CO. LLP SAN JOSE, California, United States
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Provider details
Annual audit
Yes
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
No

FRANK, RIMERMAN & CO. LLP
PCAOB 1596

Fund details & source
Fund ID
805-8708081402
Reported beneficial owners
104
Minimum commitment
$25K
Form D file number
021-421204

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

SHRUG IV-A, L.P.Venture Capital Fund · Last reported Apr 12, 2026$26.6MGross asset value
Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Auditor FRANK, RIMERMAN & CO. LLP SAN JOSE, California, United States
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Provider details
Annual audit
Yes
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
No

FRANK, RIMERMAN & CO. LLP
PCAOB 1596

Fund details & source
Fund ID
805-5107023447
Reported beneficial owners
44
Minimum commitment
$25K
Form D file number
021-421204

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

SHRUG III, L.P.Venture Capital Fund · Last reported Apr 12, 2026$25.5MGross asset value

Form D fundraising filings

Shrug III, L.P.

Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Provider details
Annual audit
No
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
No
Fund details & source
Fund ID
805-9126468036
Reported beneficial owners
101
Minimum commitment
$1K
Form D file number
021-379226

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

SHRUG II, L.P.Venture Capital Fund · Last reported Apr 12, 2026$24MGross asset value

Form D fundraising filings

Shrug II, L.P.

Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Provider details
Annual audit
No
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
No
Fund details & source
Fund ID
805-8142871112
Reported beneficial owners
98
Minimum commitment
$50K
Form D file number
021-331087

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

SHRUG OPPORTUNITIES II - FEASTABLES, LPVenture Capital Fund · Last reported Apr 12, 2026$10MGross asset value

Form D fundraising filings

SHRUG OPPORTUNITIES II - Feastables, LP

Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Marketer AL ADVISORS MANAGEMENT, INC SAN FRANCISCO, California, United States Related to adviser: No
Provider details
Annual audit
No
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
Yes
Fund details & source
Fund ID
805-7685704762
Reported beneficial owners
17
Minimum commitment
$500K
Form D file number
021-510778

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

SPV FUND I, A SERIES OF SHRUG CAPITAL X, LPVenture Capital Fund · Last reported Apr 12, 2026$2.38MGross asset value
Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Marketer AL ADVISORS MANAGEMENT, INC SAN FRANCISCO, California, United States Related to adviser: No
Provider details
Annual audit
No
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
Yes
Fund details & source
Fund ID
805-2798296349
Reported beneficial owners
80
Minimum commitment
$5K
Form D file number
021-454701

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

NI FUND, A SERIES OF SHRUG OPPORTUNITIES, LPVenture Capital Fund · Last reported Apr 12, 2026$903KGross asset value

Form D fundraising filings

NI Fund, a Series of Shrug Opportunities, LP

Fund administrator BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Investor statements: No (provided to no investors) Related to adviser: No
Custodian BELLTOWER FUND GROUP, LTD SEATTLE, Washington, United States Related to adviser: No
Marketer AL ADVISORS MANAGEMENT, INC SAN FRANCISCO, California, United States Related to adviser: No
Provider details
Annual audit
No
Prime brokers
No
Custodians
Yes
Administrator other than the adviser
Yes
External marketing
Yes
Fund details & source
Fund ID
805-3377295810
Reported beneficial owners
7
Minimum commitment
$1K
Form D file number
021-540208

Form ADV 2093494 · Apr 12, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

Services & filing details

Most recent filing: Apr 12, 2026. View historical filings

Reported services

Not reported in these imported fields

Compensation

Not reported in these imported fields

Principal office

CRD 313323

Filing source

Form ADV 2093494 · Apr 12, 2026 · Items 1 & 5

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.