This policy governs the due diligence, approval, and
supervision of products that offer periodic redemption opportunities (limited
liquidity)
This policy applies to two specific categories of products. Type
A – Limited Liquidity Funds (Interval Funds): Registered '40 Act funds that
continuously offer shares and conduct periodic offers for repurchase and Type B
- Non-Traded Alternatives: Unlisted REITs, BDCs, or other funds sold via a
prospectus and a subscription document, which provide liquidity through a share
repurchase plan
Concentration Limits
Concentration Limit: Total household investment across
all
Limited Liquidity Products (Type A and B) shall not exceed 10% of the client's household
AUM. Should the investment grow more than 10% and the client wish to continue
holding the position the following document must signed acknowledging the risk
of the higher concentration.
Over-Concentration
Holdings Acknowledgment
Due Diligence & Approval Process
Traded limited liquidity products do not require preapproval
Advisor Knowledge
Prior to recommending any investment with limited liquidity
or alternative features, advisors must conduct reasonable diligence to fully
understand its structure, risks, costs, and limitations. This diligence is
fundamental to meeting your Care Obligation under Regulation Best Interest and
your fiduciary duty as an Investment Adviser Representative. Advisors must be
able to clearly articulate how the product's specific characteristics align
with the client's investment profile and objectives