What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and
what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the
same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these
conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what
• All investment advisers face conflicts of interest which are inherent in the business. Our primary source of compensation is
through asset based fees. Therefore, we are incentivized to acquire new clients and to increase assets under
management. Other conflicts of interest result from other business activities we engage in and relationships we have with
business partners and third parties, or affiliations we have established with other financial institutions.
• We are the general partner and or manager of a private fund (e.g., hedge fund) that we may recommend to you. If you
invest in these proprietary private funds, we will receive management fees and/or performance based fees from the fund.
This creates a conflict of interest because we have an incentive to recommend the fund over other investments. While our
firm is accountable to you and the fund as a fiduciary and, consequently, must exercise good faith and integrity in handling
both your and the fund’s business, you should be aware of the potential for conflicts of interest. Investors in the fund
should refer to the offering documents of the fund for detailed disclosures. We will not charge you an additional asset
management fee for the portion of your portfolio that is invested in the fund(s).
• We may recommend that you use a third party advisor (TPA) and we will share in the compensation received by the TPA
for managing your account. The compensation arrangement presents a conflict of interest due to a financial incentive to
recommend the services of the third party advisor. You are not required to use the services of any TPA we recommend.