The contemplated Fund's principal investment strategy would be to hold a diversified, all-era portfolio of Pokémon trading cards: the most measurable collectibles market in existence, with standardized card identities, public grading-population data, and deep third-party transaction records. The Fund is designed as an access vehicle, providing institutional custody, honest monthly marks, and full trade transparency for an asset class that today has no investable index. Strict grading floors, a $100 minimum card price, and hard diversification covenants would screen out the market's illiquid and condition-impaired tail.
| Status | Concept in design; not formed |
| Expense Ratio* | ~4.0% (est., under study) |
| Fund Type | Private placement (Del. LP) |
| Offering | Private placement to accredited investors; exemption not yet determined |
| Investor Type | Accredited (verified) |
| Minimum Initial Investment | $25,000 |
| Subscriptions | Monthly |
| Redemptions** | Monthly at NAV, subject to tentative gates: 5% of AUM/mo · 12.5%/qtr |
| Distributions | N/A |
| Taxation | Pass-through partnership; K-1s prepared for investors. U.S. long-term collectibles gains taxed up to 28% |
| Benchmark | Proprietary NM high-volume card index (methodology published) |
* Working estimate covering the management fee plus custody, insurance, administration, audit, and grading costs; to be fixed after third-party quotes. At small fund sizes the expense burden is material.
** Worst-case full exit under the gates is approximately two years. An initial lockup period is under consideration. Any redemption program may be modified, in which case investors may not be able to redeem.
| Sponsor | Cards Capital LLC (to be formed) |
| Custody | Two insured, climate-controlled vaults, to be appointed |
| Audit | To be appointed |
| Tax | To be appointed |
| Legal Counsel | To be appointed |
| Fund Administrator | To be appointed |
Access to a hard-to-reach asset class. Pokémon cards are a $10–15B collectibles market with two decades of collector history. The Fund would provide diversified exposure through a single subscription, with no sourcing, authentication, grading, or storage burden.
Diversified by covenant, not by promise. Hard caps of no more than 10% of assets in any set, 1% in any card, and 10% in any single Pokémon, enforced across all three collecting eras plus a dedicated cash sleeve for redemptions.
Radical transparency. Every buy and sell would be published monthly. NAV would be marked to third-party sales data, never manager estimates. The grading-program hit rate would be published, and the benchmark methodology would be public and mechanical.
| Vintage (WOTC)Base Set through Neo, Southern Islands, WOTC Black Star Promos (1999–2003) | 35–45% |
| Mid EraEX era through pre–Sword & Shield (2004–2019), incl. Gold Stars | 25–35% |
| ModernSword & Shield onward, incl. Scarlet & Violet and Mega Evolution | 20–30% |
| CashRedemption liquidity and fund expenses | 2–8% |
Allocations are target ranges and subject to change.
| Single set, max share of AUM | ≤ 10% |
| Single card, max share of AUM | ≤ 1% |
| Single Pokémon, max share of AUM† | ≤ 10% |
| English-language cards, min | ≥ 70% |
| Japanese ≤ 20% · other languages | ≤ 10% |
| Minimum card price at acquisition | $100 |
† Aggregated across all cards featuring the Pokémon; multi-Pokémon (e.g., tag-team) cards weighted pro-rata. All allocation and diversification covenants apply above $1M AUM; de minimis relief below that threshold during ramp-up and wind-down.
This document is a generic solicitation of interest made under Securities Act Rule 241 (17 C.F.R. § 230.241):
Cards Capital is a concept-stage manager built around a single conviction: trading cards are the first collectibles market measurable enough to support an honestly marked, fully transparent fund. The 151 Fund, named for the original Pokédex of 151 Pokémon, grows out of the founder's documented personal Pokémon portfolio (a two-track vintage-and-modern collection run with written acquisition rules, published condition standards, and cost-basis records) and a career in institutional markets spanning structured credit, treasury management, and digital assets.
The design borrows deliberately from the vehicles that came before it: the private-placement access model of crypto index funds, the repurchase discipline of registered interval funds, and the lesson of the first sports-card funds: that in collectibles, verifiable transparency is the product. Every design choice on page one exists to make the Fund auditable: third-party marks, published trades, a mechanical benchmark, and covenant-enforced diversification.
| Raw cards | Near Mint only, all eras |
| Vintage (WOTC) | PSA 6 or better, or equivalent |
| Mid era | PSA 8 or better, or equivalent |
| Modern | PSA 10 only, or equivalent |
| Accepted graders | PSA · TAG · BGS · CGC only |
| Grading program | The manager may submit raw cards where conviction supports a vintage PSA 6+ or modern PSA 10 outcome; cards at graders are carried at cost until the grade returns, and program results are published monthly |
| Storage | Minimum two active vaults at all times, temperature- and humidity-controlled; locations undisclosed except to auditors |
| Insurance | Theft and fire at each facility; transit coverage between vaults, graders, and marketplaces |
| Valuation | Monthly NAV marked to recent arm's-length sales on eBay and TCGplayer, cross-checked against Collectr and PriceCharting; staleness haircuts applied |
| Disclosure | All purchases and sales published monthly on a short lag; grading-program results published |
WOTC: Wizards of the Coast, publisher of English Pokémon cards 1999–2003; the hobby's vintage foundation.
PSA / TAG / BGS / CGC: the four professional grading companies whose encapsulated grades the Fund accepts. Grades run 1–10; PSA 10 ("Gem Mint") is the top grade.
NM (Near Mint): the highest common raw-card condition tier; the Fund's minimum for any ungraded card.
Redemption gate: a limit on aggregate investor withdrawals (tentatively 5% of assets monthly, 12.5% quarterly) that protects remaining investors from forced selling.
Gold Star: a 27-card 2004–2007 rarity class; the mid era's marquee collectible category.
Grading arbitrage: buying a raw card below the value implied by its likely professional grade and crystallizing the premium through submission.
This document describes a concept-stage product. No fund exists, no offering is being made, and no subscription can be accepted. This fact sheet is a discussion draft provided for informational purposes only, is illustrative, and is subject to change in every respect. It is neither an offer to sell nor a solicitation of an offer to buy any security. Any offering, if ever made, would be made solely to verified accredited investors through definitive offering documents (a confidential private placement memorandum, limited partnership agreement, and subscription documents) containing full risk factors, conflicts of interest, and terms, and only after formation of the fund and completion of legal, tax, and regulatory work. Any such offering would be made in reliance on exemptions from registration under the Securities Act of 1933; the fund's securities would not be registered with or approved by the SEC or any state regulator.
Principal risks (non-exhaustive). Collectibles are speculative and volatile and can lose most or all of their value. The trading-card market is illiquid, bid-ask spreads are wide, and forced sales may realize substantially less than carrying marks. Monthly NAV relies on third-party sales data that may be thin, stale, or unrepresentative for particular cards. Redemption gates can extend a full exit to approximately two years, and any lockup would extend it further. Physical assets bear loss, damage, theft, authenticity, and insurance-coverage risk. Grading outcomes are uncertain; a card submitted for grading may return below the Fund's holding bands and be sold at a loss.
The fee and expense burden is material, particularly at small fund sizes, and estimated figures shown are not committed terms. The manager has no operating history managing a pooled investment vehicle. Diversification covenants are managed guidelines and do not protect against market risk; diversification does not ensure a profit or protect against loss in a declining market. U.S. long-term capital gains on collectibles are taxed at rates up to 28%, higher than standard long-term capital-gains rates; investors would receive K-1s and should consult their own tax advisers.
No performance is presented. The fund does not exist and has no performance history. Nothing in this document is a representation of achievable returns, and no past performance of the trading-card category, any index, or any individual card is presented or implied. Past performance of a category would not be indicative of future results in any event.
No affiliation. Cards Capital is an independent concept and is not affiliated with, endorsed by, or sponsored by Nintendo, Creatures Inc., Game Freak, or The Pokémon Company International. "Pokémon" and all related marks are trademarks of their respective owners, referenced solely to describe the assets in which the fund concept would invest. PSA, TAG, BGS, CGC, eBay, TCGplayer, Collectr, and PriceCharting are trademarks of their respective owners; none has reviewed or endorsed this document.