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CAMBRIDGE ASSOCIATES, LLC
BROCHURE
MARCH 31, 2025
Cambridge Associates, LLC
115 Federal Street, Suite 2600
Boston, Massachusetts 02110-2112
Telephone: 617-457-7500
Fax: 617-457-7501
www.cambridgeassociates.com
This Brochure provides information about the qualifications and business
practices of Cambridge Associates, LLC. If you have any questions about the
contents of this Brochure, please contact:
Sean F. Hanna
Chief Compliance Officer and Senior Counsel
Telephone: 617-457-7518
Email: shanna@cambridgeassociates.com
The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (SEC) or by any state
securities authority.
Additional information about Cambridge Associates, LLC is also available
on the SEC’s website at IAPD.
Registration with the SEC does not mean that the SEC or any other agency
of the United States government has reviewed or approved of the registered
investment adviser’s abilities or qualifications nor does it imply a certain
level of skill or training.
CAMBRIDGE ASSOCIATES, LLC
ITEM 2 – MATERIAL CHANGES
Item 5 has been amended to reflect changes in the Firm’s billing policies.
CAMBRIDGE ASSOCIATES, LLC
TABLE OF CONTENTS
ITEM 1 – COVER PAGE ........................................................................................................................................................................................... 1
ITEM 2 – MATERIAL CHANGES .......................................................................................................................................................................... 2
ITEM 3 – TABLE OF CONTENTS........................................................................................................................................................................ 3
ITEM 4 – ADVISORY BUSINESS ......................................................................................................................................................................... 4
ITEM 5 - FEES AND COMPENSATION .............................................................................................................................................................. 7
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................................................... 9
ITEM 7 - TYPES OF CLIENTS ............................................................................................................................................................................. 11
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................................................... 11
ITEM 9 - DISCIPLINARY INFORMATION ....................................................................................................................................................... 15
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................................... 15
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ... 16
ITEM 12 - BROKERAGE PRACTICES ............................................................................................................................................................... 18
ITEM 13 - REVIEW OF ACCOUNTS ................................................................................................................................................................. 18
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ............................................................................................................ 18
ITEM 15 - CUSTODY ............................................................................................................................................................................................. 19
ITEM 16 - INVESTMENT DISCRETION ............................................................................................................................................................ 19
ITEM 17 - VOTING CLIENT SECURITIES ....................................................................................................................................................... 20
ITEM 18 - FINANCIAL INFORMATION ........................................................................................................................................................... 20
CAMBRIDGE ASSOCIATES, LLC
ITEM 4 – ADVISORY BUSINESS
SUMMARY
Cambridge Associates, LLC is a privately held investment advisory firm (the “Firm”) principally owned
by employees and clients.
OUR MISSION STATEMENT
We partner with endowments, foundations, pension plans, corporations and private clients to implement
and manage custom portfolios to generate outperformance so they can maximize their impact on the
world.
THE FIRM
The Firm has eight global subsidiary affiliates collectively providing investment management, investment
advisory, research and performance reporting services.
NAME
LOCATION
LEGAL STRUCTURE
Cambridge Associates Limited
London, England
Limited Company in England and Wales
(Authorized and regulated by the U.K.
Financial Conduct Authority)
Cambridge Associates Asia Pte Ltd
Singapore
Singapore Corporation (Registered and
regulated by the Monetary Authority of
Singapore)
Cambridge Associates Limited, LLC Boston, Massachusetts U.S.A. and
Sydney, Australia
Massachusetts Limited Liability Company
(Registered with the U.S. Securities and
Exchange Commission, subject to oversight by
the Australian Securities and Investment
Commission and registered as an Investment
Fund Manager and Portfolio Manager in the
Canadian provinces of Ontario, Quebec, Nova
Scotia and British Columbia)
Cambridge Associates GmbH
Munich, Germany
German Limited Liability Company
(Registered and regulated by Bundesanstalt für
Finanzdienstleistungsaufsicht (BaFin))
Hong Kong, China
Cambridge Associates Hong Kong
Private Limited
Hong Kong Private Limited Company
(Licensed with the Securities and Futures
Commission of Hong Kong)
Beijing, China
Cambridge Associates Investment
Consultancy (Beijing) Ltd.
People’s Republic of China Limited Liability
Company
Cambridge Associates AG
Zurich, Switzerland
Swiss Limited Company (Authorized and
supervised by the Swiss Financial Market
Supervisory Authority (FINMA))
Dubai, United Arab Emirates
Cambridge Associates (DIFC)
Limited
DIFC Company (Regulated by the Dubai
Financial Services Authority (DFSA))
In addition to the entities listed above, the Firm and its affiliates have established various entities to serve
as general partners and/or managing members for the Firm’s Single Investor Funds and commingled
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funds including Single Manager Funds1. The Firm and its affiliates are under common ownership and
control. Cambridge Associates, LLC is not affiliated with any broker/dealers, other investment managers,
solicitors or placement agents, and we do not receive any compensation from third parties for
recommending or using their investment products or services for our clients.
The Firm provides its clients with a wide range of services designed to help maximize portfolio returns
within the context of their governance and risk framework. For clients with limited in-house resources
and an investment committee that seeks to delegate portfolio implementation, we offer discretionary
investment management or Outsourced Chief Investment Officer services (OCIO). For those that seek a
similar level of support but wish to retain approval rights on manager hiring and firing, we offer non-
discretionary portfolio management services. The Firm provides these services for a total portfolio or for
specific asset classes.
For clients that have fully built-out investment offices, we offer staff extension services which are
customized to complement such clients’ in-house resources and needs. Typically, this includes our acting
as a sounding board as well as providing alternative asset expertise, manager due diligence and research
tools.
We also offer services to clients that seek specialized advice and guidance. These services are typically
tailored to the client and most often include strategic and tactical asset allocation advice as well as
manager selection, participation in committee meetings, access to research services and performance
reporting.
We also provide investment services relating to socially responsible investing, ESG and impact investing
and have dedicated resources researching managers and working with clients to align their investing
with their missions. These service offerings are quite differentiated and not consistent across our client
base as they are driven by clients’ specific frameworks, interpretations and reporting needs.
In addition, we provide expertise and guidance regarding the selection of diverse managers through
dedicated resources seeking to find and diligence non-traditional, institutional quality managers.
Generally, the Firm does not engage in individual stock selection but rather assists clients in selecting
and investing with institutional quality, external investment managers. The Firm does, however, provide
advice to clients on co-investment opportunities in individual companies, exchange traded funds (ETFs),
equity and bond futures and secondary market offerings of privately placed investment funds
(secondaries).
With respect to co-investments, clients that seek to invest can either (1) obtain exposure through
commingled funds, whether sponsored by the Firm or third-party investment managers, or (2) directly
via the Firm’s co-investment advisory service platform. Interested clients will need to expressly opt-in to
receive co-investment advisory services, and the fees for the service will be negotiable depending on the
size and complexity of a client’s co-investment program and overall relationship with the Firm.
The Firm has dedicated substantial resources in conducting due diligence on and investing in alternative
asset classes including hedge funds, private investments (private equity/venture capital), private credit,
real estate, timber and other natural resources.
To focus on the specific needs of various groups of clients, we have formed practice areas specializing on
the needs of endowments and foundations, private clients and pensions. These practice areas seek to
expand our knowledge of the investment requirements of each type of client and maximize our ability to
better serve those clients.
1 Please refer to page 6 of this Brochure for more information relating to our Single Investor and Single Manager Funds.
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We have created vehicles to provide administrative ease and improve access to managers. These include:
SINGLE INVESTOR FUNDS
Although we typically service discretionary clients through separately managed accounts, we have
established and offer “Single Investor Funds” (SIFs) for clients seeking a portfolio of alternative
investment assets without the associated administrative burdens. We establish a separate SIF for each
client, and we act as the investment manager to that SIF in a discretionary capacity. We outsource
investment accounting and administration, tax preparation, annual audits and custody/banking to
qualified third-party service providers. Unless otherwise instructed by a client, we take responsibility for
the management of these external relationships, effectively relieving a client of the administration
associated with the investment program. Due to regulatory requirements in specific jurisdictions, SIFs
may not be offered for all clients.
SINGLE MANAGER FUNDS
We have established several “Single Manager Funds” (SMFs) to aggregate assets from multiple clients for
investment in alternative assets whose high minimums or other access restrictions would have otherwise
prevented these clients from investing or to obtain more favorable fees or terms from managers. When
clients express enough interest to warrant the use of an SMF, we may establish a separate fund for each
alternative investment or manager for which we are pooling assets, including for co-investments and
secondaries. Due to regulatory requirements in specific jurisdictions, SMFs may not be offered to all
clients.
COMMINGLED INVESTMENT FUNDS
Although we do not utilize proprietary, diversified commingled investment funds as total portfolio
solutions, we have and may form commingled vehicles to access certain, niche asset classes when we
believe a fund vehicle improves investing efficiency for our clients. Commingled fund offering
documents contain specific conflicts of interest and risk disclosures. Due to regulatory requirements in
specific jurisdictions, commingled funds may not be offered to all clients.
REGULATORY ASSETS UNDER MANAGEMENT
NUMBER OF ACCOUNTS
ASSETS AS OF DECEMBER 31, 2024
Discretionary
213
101,131,000,000
Non-Discretionary
362
212,415,000,000
Total
575
313,546,000,000
These figures above (rounded to the nearest $100,000) are based on the net asset values of our clients’
securities (including hedge funds and private investments) as reported to us by the investment managers.
The value of private investments is reported with at least a one-quarter lag. Where we advise or manage
assets that are also invested in one of the Firm’s investment vehicles, we count those assets only once for
the purposes of Regulatory Assets under Management.
In addition to our Regulatory Assets under Management, we also maintain relationships with many of
our clients where we engage in proactive and ongoing leadership of the client’s investment program on a
non-discretionary basis, however, not all such assets are considered Regulatory Assets under
Management by the U.S. Securities and Exchange Commission.
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INDUSTRY PARTNERSHIPS
We have been selected to provide data and/or analysis as well as to develop and maintain customized
industry benchmarks for several prominent industry associations, including, but not limited to:
Australian Investment Council (AIC)
China Venture Capital and Private Equity Association (CVCA)
The Global Private Capital Association (formerly EMPEA)
Institutional Limited Partners Association (ILPA)
Invest Europe (IE)
Singapore Private Equity & Venture Capital Association (SVCA)
We have also entered into various distribution and licensing agreements with third parties to supply
firms and data platforms with anonymous and aggregated private equity, venture capital, real estate, and
other private investments fund performance data and statistics.
Through these agreements, we provide aggregated fund performance information to entities whose
members or clients include investment management firms. This results in the Firm receiving indirect
compensation from investment managers, some of whom we may evaluate and recommend to our
clients. We take steps to mitigate this potential conflict, including requiring our distribution partners to
be the primary interface with their investment manager members and subscribers and asking them to
shield the identity of any such members/subscribers from our research and investment professionals.
Despite these efforts, it is possible that our investment professionals could become aware of the identity
of these investment managers and favor them over others.
We have also entered into benchmark licensing agreements with unaffiliated investment managers
where our licensing fees are based on assets raised in investment products sponsored and/or managed by
such investment managers. In those instances, we acknowledge that a conflict of interest exists if we
recommend or invest our clients in such investment products and will provide prior disclosure regarding
our compensation arrangements if a recommendation or investment is made. Due to rules in the
Employee Retirement Income Security Act of 1974 (“ERISA”), we will not recommend or invest assets of
plans subject to ERISA in products where this conflict of interest exists.
ITEM 5 - FEES AND COMPENSATION
The Firm does not receive compensation from investment managers in connection with the purchase or
sale of their securities. The fees we charge clients and the services we offer are described below and are
based on our current fee schedules but are negotiable. Certain legacy clients pay different fees. Our fees
vary based on the scale and complexity of the mandate.
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CONTRACT TYPE
DESCRIPTION OF SERVICES
FEE RANGES
We direct and monitor the investment
portfolio.
Portfolio
Management
Services
The fee depends on the type of client, the asset
classes under advisement, the complexity of the
portfolio and other factors.
This may be provided on a non-
discretionary or discretionary basis.
Fees may be higher or lower depending on asset
level breakpoints, and fees or a portion of fees may
be contingent on meeting performance hurdles.
Fees range from 2 to 60 basis points on the net
asset value of the investment assets (or on
commitments to private investments) and are
generally subject to a minimum annual fee.
Fees for co-investment advisory services are
negotiable depending on the size and complexity
of a client’s co-investment program and overall
relationship with CA.
Fees for discretionary mandates specifically
focused on secondaries and/or co-investments may
include carried interest and a management fee.
The fee depends on the client’s in-house resources
Staff Extension
Services
and the specific set of services desired by the
client.
Typically, these are fixed fee arrangements, subject
Depending on a client’s specific needs, we
build a custom relationship, typically
acting as a sounding board, leveraging our
research platform and supplementing the
client’s internal capabilities.
to a minimum annual fee.
Often our work focuses on alternative
assets.
We generally customize our services based on each individual client’s needs, therefore, our fees are
dependent on a client’s total asset size, governance structure and service requirements, portfolio
complexity and asset mix, whether the relationship is discretionary, client domicile, longevity of a
relationship with us, type of institution (e.g., a nonprofit organization, a corporation, a public pension
plan, a private client, etc.).
PAYMENT SCHEDULES
Depending on the agreement, we invoice clients quarterly, semi-annually, up-front or according to an
agreed upon schedule depending on the scope of services provided and whether fees are asset value-
based or fixed. Where our fees or a portion of fees are contingent on meeting performance hurdles, we
invoice in the quarter after the performance period ends. We will not, however, enter into any
agreements with clients that allow for prepayment of fees six months or more in advance of providing
services.
If applicable, out-of-pocket reimbursable expenses such as our expenses (at cost) for travel, printing,
postage and delivery of documents are billed monthly.
Unless otherwise agreed upon, we only value securities for our commingled investment funds, SIFs and
SMFs that are subject to a financial audit. For all other relationships, we are not responsible for valuing
client securities. For purposes of calculating fees payable to the Firm for relationships for which fees are
based upon a rate applied to asset values in the portfolio, the Firm relies on values reported by third
parties including managers, custodians, brokers, and in limited instances, clients, which include market
value, net asset value or value of committed capital (as applicable) of underlying investments. When
values are preliminary or reporting is delayed, the Firm may exclude such values from a current invoice
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and adjust a subsequent invoice to reflect a final reported value of an underlying investment fund. Some
clients have made arrangements with the Firm to use different asset value sources than described above.
For audited commingled investment vehicles, SIFs and SMFs, we are responsible for valuing securities
held within the vehicles and have a valuation policy and procedures in place to review and price the
value of those investments. As such, the value of investments reported by the Firm and used for billing
purposes can differ for clients holding assets through commingled investment vehicles, SIFs or SMFs as
opposed to holding such investments directly.
With respect to the SIFs, our general practice is to deduct our management fee from the assets of each
fund quarterly in advance, however, specific billing practices differ depending on specific client
requirements. Organizational and operational expenses of the SIFs are generally the responsibility of the
investor, although some of these expenses are, in some instances, borne by the Firm rather than the
investor. These expenses are typically paid out of the SIF’s assets, although investors can pay these
expenses directly. The terms of each SIF can be negotiated and are governed by the limited partnership
agreement or its equivalent.
Clients invested through our SMFs generally pay their advisory fees outside of the fund, however,
specific billing practices differ depending on specific client requirements. Operational expenses incurred
by the SMFs are allocated to investors on a pro rata basis. For discretionary mandates specifically focused
on secondaries, the manner of calculation and application of the management fee and the carried
interest allocations, if applicable, are disclosed in the investment management agreement for each client.
For each commingled investment fund in which a client is invested, clients will be charged in
accordance with the fund’s offering documents. Non-Firm clients may be permitted to invest in our
commingled investment funds.
TERMINATION PROVISIONS
Many of our contracts have an initial one-year term, with automatic renewal for subsequent years
assuming no change in services and/or fees. Our clients may terminate their relationship immediately or
following a notice period specified in their contract, typically between 30 to 90 days. Upon termination,
we will adjust any fees payable to us or paid in advance by the client on a pro rata basis from the effective
date of the contract, including contracts for project work, through the date of termination.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge performance-based fees for our non-discretionary investment advisory services. We do,
however, recommend investment managers to our clients that charge performance-based fees. With
respect to proprietary commingled funds, depending on the fund, we may charge management and/or
performance fees within the investment vehicle. For some clients, those fees may be more than what is
paid for their advisory or investment management services. Any recommendation by the Firm to invest
in a Firm commingled investment vehicle should be viewed with this conflict in mind. Discretionary
clients of the Firm will be provided notice of proposed investments in the Firm’s commingled investment
vehicle where such conflict exists and an opportunity to elect not to invest.
Although we do not typically offer performance-based fees for discretionary services, we do charge
performance-based fees for mandates involving certain asset classes and/or where a client is interested in
this type of fee structure. Depending on the nature of the client and the investment mandate, the Firm
may commit its own capital and invest alongside such client.
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Certain conflicts of interests and risks exist in situations where we charge performance-based fees. For
example, depending on client portfolio performance, performance-based fees could create an incentive
for the Firm to make investments that are riskier or more speculative than would be the case if such fee
arrangements were not in effect. Similarly, certain risks exist when the Firm commits its own capital
alongside a client insofar as doing so may cause the Firm to manage the portfolio in a manner
inconsistent with such client’s interest.
We charge fees that vary from client to client. Different fee arrangements may incentivize investment
teams to dedicate increased resources and allocate more profitable investment opportunities or ideas to
clients whose fee arrangements with the Firm are more profitable for the Firm. Investment teams
compensated by client portfolio performance are also incentivized to allocate investment opportunities
to, and among, clients who either pay carried interest or performance-based fees.
We seek to mitigate the above risks by mutually agreeing upon investment guidelines and restrictions
with discretionary clients and putting policies and procedures in place to adhere to those guidelines. We
also seek to mitigate the conflicts with the adoption of allocation policies and procedures designed to
treat clients fairly.
INVESTMENT ALLOCATIONS
Due to the nature of the services we provide, we do not generally have direct responsibility for the
allocation of investment opportunities among our clients. We provide investment managers with lists of
those clients who may be interested in a potential investment, and we may facilitate an introductory
meeting. In those situations, all decisions to accept an investor into a particular fund or investment
opportunity are the responsibility of the fund manager or other applicable third party. However, in some
instances, we source investments specifically to meet the needs of individual clients, and such
opportunities may not be offered broadly to our clients as a whole. In rare cases, we may be required to
allocate investments to our clients and have policies and procedures to do so in a fair and equitable
manner.
SECONDARIES INVESTMENT ALLOCATIONS
The Firm has created an allocation framework that gives preference to certain clients that have hired us
specifically to build and manage secondary-focused portfolios. Under the allocation framework, the Firm
will first allocate secondaries to such clients before making them available to others. For allocation
purposes, secondaries include, but are not limited to, secondary market offerings of privately placed
investment funds, continuation funds, certain secondaries made alongside managers which may or may
not be contained in a special purpose vehicle or fund structure, and primary funds where investment is
required to access specific secondaries opportunities (“stapled” transactions). Given the multitude of
ways transactions can be structured, the Firm, in its discretion, will assess investment opportunities to
determine asset class and the applicable allocation framework.
To the extent possible, allocations will generally be on a pro rata basis depending on the specific
circumstances of each investment and parameters of clients’ investment guidelines. Some of the factors
that are taken into consideration when determining allocation are suitability, exposure, size of the
transaction, availability of cash in a client’s portfolio, legal and tax considerations, whether the
transaction requires consent from a third party, and client investment restrictions. In certain instances
where pro rata allocation is not possible or where we determine it infeasible, the allocation decision will
be made by random selection.
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We have also established an Allocation Committee that, among other things, reviews the actions taken by
the Firm’s allocation operations and resolves conflicts that cannot be easily resolved by application of the
policy, including questions relating to client investment guidelines. The Allocation Committee is also
responsible for reviewing the Firm’s Allocation Policy to ensure that it treats clients fairly and mitigates
the conflicts of interest described above.
ITEM 7 - TYPES OF CLIENTS
Nearly all of our clients are Accredited Investors and Qualified Purchasers2. Our clients include colleges
and universities, foundations and other non-profit institutions, including, but not limited to, museums
and libraries, independent schools, religious institutions, professional and research institutions, service
organizations and performing arts institutions. We also act as an investment adviser to private clients,
family offices, corporations, healthcare institutions, insurance groups, pension plans and ERISA pools
and public and government-related groups.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
We typically work with our clients to identify and refine their investment objectives, risk parameters and
spending needs to determine an appropriate asset allocation and manager structure designed to achieve
financial goals. We utilize a number of analytical models to determine the appropriate asset allocation
and manager structure, and we seek to match strategies and managers that we recommend or select with
our clients’ objectives.
Our investment manager due diligence is based on qualitative and quantitative analyses briefly described
below.
Qualitative factors we generally consider during our initial due diligence and ongoing monitoring
include:
History of the organization and management team additions and departures
Experience, quality and capacity of current investment team
Organizational strength and cohesiveness
Attractiveness of track record and relevance to stated strategy
Attractiveness and consistency of investment strategy and philosophy
Deal origination and structuring capability
Investment due diligence skills
Ability to add value to deals
Partnership or transaction terms, from a business perspective
Investment environment
Competitive landscape
2 “Accredited Investor” and “Qualified Purchaser” are defined in Rule 501 of Regulation D and Section 2(a)(51) of the
Investment Company Act of 1940, respectively.
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CAMBRIDGE ASSOCIATES, LLC
For traditional marketable managers, we typically obtain their current holdings data and run a series of
historical analyses. We generally examine the product, team, organization, performance and fees.
For hedge fund managers, we emphasize a qualitative evaluation of how their portfolios are likely to
perform in different market environments. We favor strategies where managers look for inefficiency at
the security level and exhibit a degree of transparency that enables us to understand the depth of the
manager’s fundamental analysis and approach to risk control. We focus on the manager’s research
process, historical security selection skill and portfolio structuring capabilities.
For private investment managers, our quantitative review generally includes the manager’s track record
and financial performance assessed on an absolute basis and on a relative basis versus our own
proprietary vintage year benchmarks. When available, we also conduct performance attribution analysis
at the company level to ascertain which investments and sectors drive the manager’s performance. We
also conduct reference checks on managers by interviewing knowledgeable market participants
including employees of underlying portfolio companies.
Our investment directors rely primarily on the manager due diligence conducted or led by the Firm’s
senior investment and research professionals to identify managers that are aligned with a particular
client’s needs and objectives but also rely on their own research in making recommendations to their
clients. In some cases, the recommended managers and funds have neither undergone the Firm’s full due
diligence process nor will they be the subject of ongoing monitoring. This includes, but is not limited to,
index funds, ETFs, money market funds and other passive investment strategies, spin-offs from existing
managers, co-investments, niche managers and customized separate accounts.
We generally do not recommend direct investments in individual securities due to our focus on
investment managers and their funds or products. Such direct investments are not subject to the due
diligence process described above.
Depending on the investment mandate and type of client, we also recommend and invest client assets
with third-party managers to gain synthetic exposures using derivatives, primarily futures. We are not,
however, a futures commission merchant and do not trade derivatives directly. Although we do not
engage in direct borrowing or leverage in client portfolios, a high degree of leverage is often obtainable in
futures trading because of small margin requirements. We opportunistically use this investment strategy
to maintain exposures, either during portfolio transitions or as a result of market fluctuations, and to
hedge portfolio liabilities. For these types of managers, we focus on operational infrastructure and
personnel to determine whether a manager is sufficiently resourced to efficiently trade and execute
transactions in accordance with a particular mandate.
In discussions with investment managers regarding terms contained in partnership documents,
investment management agreements or other investment documentation, we generally take positions
that we believe to be in the common interest of all our clients. In certain circumstances, however, a
member of our advisory staff will take a position on behalf of a particular client that is intended to serve
the interests of that client, without regard to the interests of other clients. For example, an investment
professional may advise a client to take a certain position on an amendment to a partnership document
that advantages that client and may communicate that position to the investment manager. It is possible
that other Firm investment professionals that serve other clients with differing interests may not take a
position on the amendment or may recommend that a client take the opposite position on the same
amendment.
Our investment professionals may provide different investment advice regarding the same investment
manager, product or transaction to different clients. This difference arises primarily from the unique
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nature of each client’s situation and the judgment of the investment professional assigned to that client.
For example, one investment professional may advise a client to redeem from an investment, while
another investment professional may advise a client to invest in the same fund. This difference also arises
in our discretionary portfolios. In addition, we may advise clients, or cause discretionary client
portfolios, to participate in a co-investment alongside a private investment fund in which one or more
other clients of ours hold interests.
Clients may be eligible for reduced fees and preferential terms with respect to certain investments under
various arrangements negotiated by us on behalf of all or a subset of our clients. The fees and/or terms
may be based on the aggregation of our clients’ investments in a fund or with a manager. Therefore, the
fees charged or terms offered by underlying investments may change without notice for a number of
reasons including, but not limited to, the investment decisions of other clients or investment teams,
subsequent changes to negotiated arrangements between the underlying investments and the Firm, or
client terminations of our advisory agreements. When we recommend and invest clients in funds or
managers that offer preferential terms or fees contingent on a certain aggregate amount of our clients’
capital being invested, the investment decision or recommendation is based solely on the specific client’s
best interests and does not take into consideration any potential fee impact on other clients.
RISK OF LOSS
The following risk factors are not intended to be a full or complete listing of all the risks involved in
investing, and clients should engage in their own evaluation of such risks.
Past performance of any recommended managers or funds or the success of a manager in any similar
venture is no assurance of future success. Investing in securities involves a risk of loss, including the
possible loss of more than the entire amount invested. There can be no assurance that clients will not
incur losses, and clients should be prepared to accept losses as part of their investment program.
The success of any investment activity is affected by multiple factors, including national and
international political or economic conditions, general market conditions, and trade tensions stemming
from the threat or imposition of protectionist trade measures such as tariffs, which may affect the
volatility of financial markets and interest rates. Success is also affected by the extent and timing of
investor participation in the markets. Future events may impact investments in unforeseen ways.
Unexpected volatility or illiquidity in the markets could cause clients to incur losses. Politics, recession,
inflation, employment levels, trade policies, international events, war, terrorist activity, acts of civil or
international hostility, natural disasters, pandemics and other unforeseen events can also have a
significant impact upon the prices of securities and potentially disproportionate impacts to certain
industries or sectors.
In trading public securities, there are consequences for trading on insider information, and we expect
that investment managers use only public information in their investment process. Investment
managers, however, may be charged with misuse of confidential information, and if that were the case,
the performance records of these investment managers could be misleading. Furthermore, if an
investment manager or entity with which clients invest has engaged in the past or engages in the future
in such misuse, clients could be exposed to losses.
Clients also face the risk of loss associated with the possibility of personnel of an investment manager
misappropriating client securities and/or funds.
When investing in certain funds, clients may not be given access to information regarding the actual
investments made by the investment manager. Neither the Firm nor our clients will be able to control
the activities of external fund managers or be able to monitor their investment activities daily. At any
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given time, clients may not know the composition of investment managers’ portfolios with respect to the
degrees of hedged or directional positions or the extent of concentration risk or exposure to specific
markets. Similarly, clients may not learn of significant structural events, such as personnel changes,
major asset withdrawals or substantial capital growth until after the fact. A lack of transparency may
cause clients to incur losses as a result of reduced diversification and/or over-exposure to sectors, regions
or individual securities.
Investing in alternative assets such as hedge funds and private investment funds is associated with
greater risk than investing in traditional marketable securities, including but not limited to illiquidity
risk, manager-specific risk and valuation risk. Clients should consider the following factors in
determining whether investing in alternative assets is appropriate.
PRIVATE INVESTMENT ASSETS, E.G., U.S. AND INTERNATIONAL PRIVATE EQUITY FUNDS, VENTURE CAPITAL FUNDS, CO-
INVESTMENTS, PRIVATE CREDIT, SECONDARIES, REAL ESTATE, ENERGY, TIMBER AND NATURAL RESOURCES
Investments in private investment funds are highly illiquid and the underlying company investments of
these funds are also generally illiquid. Generally, neither the interests in these funds nor their
investment managers are registered with any state or federal regulators, and no readily available markets
exist for interests in these funds. Clients should expect to hold such investments for the entire life of
these funds.
Historically returns have varied greatly over time depending on the conditions at the time investments
were made and when investments were exited by funds. In addition, access to high-quality private
investment opportunities may be limited and there is no assurance that such opportunities will be
available during the desired investment period.
A strategy that invests a higher percentage of its assets in any one issuer, such as one involving co-
investments in individual issuers, could increase the risk of loss and volatility because the value of
holdings would be more susceptible to adverse events affecting that issuer. In addition, the value of an
investment in any particular issuer can be more volatile than the market as a whole and such investment
can perform differently from the value of the market as a whole.
When conducting due diligence on co-investment opportunities, the co-investor may be required to rely
on the limited resources available, and due to the timing constraints inherent to the co-investment
process, the scope of due diligence performed in connection with a co-investment is typically narrower
than the scope performed by a lead investor. There can be no assurance that due diligence investigations
reveal all relevant information or result in a co-investment’s success. In addition, to obtain access to due
diligence prepared by third parties, a co-investor may be required to agree to limit its rights to bring legal
actions against such third parties relating to reliance on such due diligence. Therefore, if third-party due
diligence relied upon is inadequate, there may be no recourse against the provider of such due diligence.
In connection with the purchase of an interest in a private investment fund from an existing investor of
the fund, where the seller previously received distributions from such fund and, subsequently, such fund
recalls distributions, the purchaser may be obligated to return cash to the fund. While the purchaser may
have a valid claim against the seller of such interest for any such returned amounts, there can be no
assurances that the purchaser will be able to collect on such claim.
There is no liquid market for secondary market offerings of private investment funds. As the demand for
secondaries increases, it is possible that competition for opportunities may reduce the number and
attractiveness of investment opportunities available, and there can be no assurance that the Firm will be
able to identify sufficient investment opportunities or acquire such opportunities on attractive terms.
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CAMBRIDGE ASSOCIATES, LLC
HEDGE FUNDS, E.G., ABSOLUTE RETURN, LONG/SHORT EQUITY, RISK ARBITRAGE, GLOBAL MACRO AND DISTRESSED FUNDS
The risks inherent in investing in hedge funds include limited regulatory oversight, illiquidity, use of
possibly speculative trading techniques, use of leverage or derivatives, short selling and hedging
techniques. Substantial risks are involved in investing in funds trading in equity securities, options and
other derivatives. Despite the hedging tactics used by hedge fund managers to mitigate risk, investments
held in hedge funds are susceptible to market movements that can be volatile and difficult to predict. The
activities of governments can influence interest rates which, in turn, affect securities, options and
derivatives prices as well as the liquidity of such markets.
Additionally, hedge funds are subject to limited withdrawal rights and early redemption fees. A fund may
be unable to liquidate certain investments to pay withdrawals in a timely manner. Realization of value
from the interests in a hedge fund may be difficult in the short-term or may have to be made at a
substantial discount compared to other freely tradable investments. Interests in these funds are not
registered under the Securities Act of 1933 or any federal or state securities law, and certain hedge fund
managers may not be registered with either a state or federal regulator. In the event of the early
termination of a hedge fund as the result of certain events, the fund may distribute to the limited
partners their interest in the assets of the fund. Certain assets held or distributed by the fund may be
highly illiquid and may have little or no ascertainable market value.
DERIVATIVES, E.G., FUTURES AND FUTURES OVERLAY MANAGERS
Transactions in futures carry a high degree of risk. The amount of initial margin is small relative to the
value of the futures contract. A relatively small market movement will have a proportionately larger
impact on funds deposited for margin. Clients may sustain a total loss of initial margin funds and any
additional funds deposited to maintain a futures position. If the market moves against a client’s position
or margin levels are increased, such clients may be called upon to pay substantial additional funds on
short notice to maintain a position. Failure to satisfy a request for additional funds within the time
prescribed could result in a position being liquidated at a loss, and clients would be liable for any
resulting deficit.
ITEM 9 - DISCIPLINARY INFORMATION
Not applicable.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
The Firm is registered as a commodity trading advisor (CTA) with the U.S. Commodity Futures Trading
Commission and is a member of the National Futures Association (NFA). Management persons and
those in charge of soliciting funds on behalf of the Firm are registered as Associated Persons with the
NFA.
We have several affiliates that are described in Item 4, but we do not believe that those affiliations create
a material conflict of interest with clients. We do not have other financial industry activities or
affiliations where compensation is derived from investing or recommending investment of client assets.
We invest or recommend investment of clients’ assets with other investment advisers; however, the Firm
will not accept compensation from those investment managers for the recommendation or investment.
Together with our affiliates, we have private clients affiliated with some of the investment managers
whom we recommend to our clients. In those instances, we will only contract to provide investment
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CAMBRIDGE ASSOCIATES, LLC
advice on their familial or personal assets. We have instituted various controls to notify and disclose to
clients the scope and nature of these relationships if such a manager is recommended. Similarly, our
clients may have interests in investment managers whose products we recommend or in which we invest
discretionary assets, however, the decision to make such a recommendation or investment would only
take into consideration the investing client’s specific interests.
Similarly, some of our client organizations have individuals serving on their boards and committees who
are affiliated with investment managers whom we recommend to our clients. This creates an incentive
for us to favor those individuals’ investment managers over those with no affiliation to our clients, as
such individuals are in a position to influence the selection or retention of the Firm as an investment
adviser. We have adopted various controls and policies designed to promote objective investment
recommendations to our clients, such as a standardized research process for investment products
undergoing full investment evaluation, disclosure policies for products recommended without full
investment evaluation and compliance and ethics training for all our staff.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
CODE OF ETHICS (THE “CODE”)
We have a Code of Ethics that all our employees must agree to honor in writing annually as a condition
of their employment. We will provide a copy of the Code to clients and prospective clients upon request.
Key elements of the Code include:
Expected standards of conduct
Disclosure of material outside business activities and personal relationships with investment
managers and custodial banks that the Firm may evaluate or recommend to its clients. Should
such relationships exist, the Firm has adopted policies and controls to ensure any potential
conflicts of interest are mitigated.
The Firm’s Gift Policy
Confidential treatment of client data
Restrictions on personal investments
Restrictions on political contributions
Employees may not engage in any act, practice or course of conduct that is fraudulent, deceptive,
manipulative, or potentially misleading.
GIFTS AND ENTERTAINMENT
With limited exceptions, our employees may not accept gifts from any person or entity that does or is
seeking to do business with the Firm or from any investment managers the Firm considers for clients
without the prior permission of the Chief Compliance Officer.
PERSONAL TRADING
All employees must contact the Firm’s Compliance Department to pre-clear the purchase of any
securities that are not publicly traded, as well as investments in initial public offerings. Permission will
generally be granted provided that the investment would not impede the ability of our clients to invest in
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CAMBRIDGE ASSOCIATES, LLC
the security to the extent that they desire to do so. From time to time, managers may show preference to
investors in prior funds when capacity is limited in subsequently raised funds. In those instances, the
employees will be permitted to make an investment notwithstanding interested clients that did not have
exposure to the manager’s most recent prior fund.
All employees must provide the Compliance Department with a securities holdings report within their
first ten days of employment and annually thereafter. Employees are also required to certify their
personal securities transactions within thirty days after the end of each calendar quarter. Reports of
personal securities transactions are reviewed to identify trading that potentially violates securities laws
and/or the Firm’s written policies and procedures.
Our employees may not purchase securities from or sell securities to any client without the prior written
approval of our Board of Managers. If approval is granted, we must receive a communication signed by
the client acknowledging and approving the transaction.
All employees must certify annually that they have read and understood the Firm’s Code of Ethics, our
Compliance Manual, and that they have complied with the required personal securities reporting.
THE CAMBRIDGE ASSOCIATES EMPLOYEE INVESTMENT FUND
The Firm’s managing directors and partners are able to obtain exposure to primarily private equity,
venture capital, co-investment and secondary opportunities through an employee investment vehicle
(the Employee Fund). The Firm will restrict the Employee Fund and employees from making
investments with terms more preferential than what are offered to our clients with respect to access,
liquidity or fees. Therefore, the Employee Fund and employees will only be able to pursue opportunities
with preferential terms where the Firm has secured such terms for the Employee Fund, employees and
the Firm’s clients. From time to time, managers may show preference to investors in prior funds when
capacity is limited in subsequently raised funds. In those instances, the Employee Fund will be permitted
to make an investment notwithstanding interested clients that did not have exposure to the manager’s
most recent prior fund. When this situation occurs, the combined total commitment of the Employee
Fund and employees’ personal investments will not exceed the lesser of $10 million USD or 3% of a
fund’s hard cap (or target if no hard cap is specified). Clients may request a list of investments held by
the Employee Fund by contacting us via email at EmployeeFundInvestments@cambridgeassociates.com.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Our employees may purchase or sell publicly-traded securities that are owned by our clients unless that
security is on the Firm’s Restricted List or the transaction would otherwise violate our trading policies or
any applicable laws.
Employees must notify the clients they advise in advance if they recommend a private placement to a
client they are considering for themselves or that they already own. Our employees must also notify their
clients in advance if they decide to withdraw from a private investment that they have recommended
that is also held by their clients. Our Chief Investment Officers who oversee discretionary portfolios
other than ERISA accounts may, with notice to clients, invest in privately offered, commitment-based,
drawdown vehicles also held within the accounts they manage.
The Firm does not conduct proprietary trading for its own accounts and generally does not invest in the
same securities that are recommended to clients, however, the Firm’s assets may be held in U.S.
Treasuries, U.S. Treasury funds, or money market funds. We also make de minimis investments in our
SIFs to satisfy requirements of an investment vehicle’s legal or tax structure and may commit its own
17
CAMBRIDGE ASSOCIATES, LLC
capital and invest alongside a client depending on the nature of the client and the investment mandate
(refer to Item 6 for more information).
POLITICAL CONTRIBUTIONS
All members of the Board of Managers, executive officers and any other employees (and their
supervisors) whose activities could encompass the solicitation of government clients are required to pre-
clear all political contributions to local, state or federal candidates, state and local political parties, or
political action committees. This requirement also extends to such employees’ spouses and dependent
children.
ITEM 12 - BROKERAGE PRACTICES
We have no broker/dealer affiliations. We are an independent investment advisory firm. We do not
receive any commissions, research or other products or services in connection with our clients’
brokerage transactions. For those clients where we select brokerage firms, we review the reasonableness
of their compensation and the reputation of the broker as part of the selection process; however, we do
not receive any research or other soft dollar benefits from these relationships.
Clients may use commission credits from directed brokerage towards payment of our fees, however,
clients should make their own decisions regarding the use of these programs. Standard brokerage fees
can be considerably less than the fees associated with commission recapture programs, and it may not be
advantageous to utilize these commission credits to pay all or part of any expenses including the payment
of our fees, the fees of investment managers, custodians, etc.
ITEM 13 - REVIEW OF ACCOUNTS
Client relationships are assigned to a varying number of investment professionals depending on the
service level. These investment professionals are responsible for reviewing client accounts on an
ongoing, monthly, quarterly, semi-annual, or annual basis depending on the level of client services. The
reviews may be more or less detailed depending on the scope of the services provided and may include a
review of performance, asset allocation and the investment funds held in a client’s portfolio.
Clients who subscribe to our performance reporting services typically receive written reports containing
detailed quarterly and cumulative information on portfolio holdings and performance. Subscribers who
also receive non-discretionary advisory services are informed annually whether full due diligence or its
equivalent has or has not been completed for a fund/manager in their portfolio. If we become aware of a
materially adverse issue with an investment manager represented in clients’ portfolios where we provide
performance reporting, an automated notification is sent to the members of the relevant investment
team and to each client invested with that manager, recommending a review of that holding.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Other than in certain jurisdictions where the Firm is not licensed to distribute commingled investment
funds, we do not compensate any person for client or investor referrals, and we do not receive
compensation from investment managers for recommending their products. In addition, we have
adopted a Gift Policy for all employees generally prohibiting the acceptance of gifts other than those of
de minimis value.
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CAMBRIDGE ASSOCIATES, LLC
ITEM 15 - CUSTODY
Depending on the type of agreement a client has with us, we may have custody of a client’s investment
assets. In certain instances, we may open separate bank accounts or money market accounts to hold any
cash balances, or brokerage accounts to hold ETFs and mutual funds. For clients invested in a SIF, we
generally provide quarterly investment performance reports, monthly account statements based on the
reports we receive from the third-party fund administrator and an annual audited financial statement.
In those instances where we have custody outside of the SIF context, clients receive quarterly account
statements from us and their independent custodian, and surprise examinations are conducted in
accordance with Rule 206(4)-2 of the Investment Advisers Act of 1940. Where we have custody, clients
should compare the values shown on our performance reports with the statements sent directly from
custodians, administrators or investment managers.
ITEM 16 - INVESTMENT DISCRETION
We will enter into discretionary investment management relationships with our clients. Our
discretionary authority to act on behalf of a client is described in the discretionary Investment
Management Agreement between the Firm and our client or, for our SIFs, in the SIF’s limited
partnership agreement or its equivalent. We manage discretionary portfolios in line with clients’
investment guidelines and restrictions agreed upon in advance, and we have established pre- and post-
trade compliance procedures for discretionary portfolios to help ensure consistency with clients’
investment guidelines and Firm policies. Given the nature of our client portfolios, our pre- and post-
trade compliance reviews are based on best available net asset values which include proxied estimates
and most recently reported values.
TRADE ERRORS
The Firm has policies and procedures that address the identification and correction of errors that may
occur while providing services to our clients, consistent with the standard of care in our client
agreements or in our offering documents, as applicable. Generally, our policies do not require perfect
implementation of oftentimes complex processes relating to investment decision making, portfolio
construction, trading, transaction processing as well as the other functions for which the Firm carries
out on behalf of its clients. Unintended events occur, some of which cause losses in our clients’
portfolios, however, not all unintended events are errors. We make determinations regarding errors on a
case-by-case-basis pursuant to our policies and procedures and in our discretion.
When evaluating an event, we consider a variety of factors when making an error determination. We
attempt to resolve similar situations in a consistent manner, subject to evolving industry practice, and
our view as to whether we have met our standard of care may change over time.
Investment decisions involve analysis and judgment, and the consequences of such decisions in
retrospect are not typically considered errors. Similarly, unintended events resulting from following an
established process for investment implementation are typically not considered errors as long there is
not a violation of a client’s investment guidelines. Furthermore, mistakes of third parties are generally
not considered Firm errors regardless of whether we seek compensation from a third party for a client or
a client’s account.
With respect to discretionary mandates, portfolios may temporarily move above or below ranges,
thresholds or targets set out in investment guidelines when moving capital between paired trades, and
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CAMBRIDGE ASSOCIATES, LLC
such temporal deviations are not typically considered errors. Where third-party derivative managers are
used to maintain asset class and/or currency exposures, temporal, incidental leverage and exposure
mismatch can take place for a variety of reasons including the timing of reporting used by those third-
party managers to implement changes, and such occurrences are also not typically considered errors.
If we determine that an error has occurred in a client’s account for which reimbursement is appropriate,
we will typically compensate the client for the loss as determined solely in our discretion. Unless
prohibited by applicable regulation or a specific agreement with the client, we net the client’s gains and
losses from the error (or a series of related errors with the same root cause) and compensate the client
for the net loss, if any. Compensation is generally limited to direct and actual out-of-pocket monetary
losses and does not include amounts that, in our judgment, are speculative, including any lost
opportunity costs or other consequential or indirect losses. We notify clients as soon as practical of any
errors including the details of the causal event, however, we generally do not notify clients about events
we have determined not to constitute errors or errors that have not caused financial loss.
ITEM 17 - VOTING CLIENT SECURITIES
For non-discretionary relationships, the Firm typically does not have authority to vote proxies on behalf
of our clients. Furthermore, because our clients generally invest through private funds rather than
directly in individual securities, they are rarely solicited to vote proxies. The managers of those funds, to
the extent they invest in equity securities, generally will have proxy voting authority and will vote
portfolio securities in accordance with their own proxy voting policies.
In cases where we have been delegated proxy voting authority, we seek to vote our client’s securities in
the economic best interests of such client. We generally vote with management on routine matters,
evaluate non-routine matters in the context of the specific interests of the account or client that
beneficially owns the security and abstain on social matters unless a direct economic benefit is tied to the
proposal. Clients that have delegated voting authority to us may impose additional guidelines or policies
relating to the way their securities are voted. As such it is possible that we may vote securities differently
from client to client depending on the specific circumstances of the investment mandate. If we identify a
potential material conflict between our interests and those of a client with respect to a proxy solicitation,
we will vote only in accordance with such client’s interest and/or instructions.
When the Firm does not have voting authority, clients may receive proxy solicitations directly from the
issuer, from their custodian, from a transfer agent or, in some cases, from us. Upon request, we will
provide our advisory clients guidance regarding these proxy solicitations. Questions about specific proxy
solicitations should be directed to a client’s investment team.
Upon request, we will provide clients with copies of our proxy voting policies and will inform those
clients for whom we have proxy voting authority as to how we voted on their behalf.
ITEM 18 - FINANCIAL INFORMATION
The Cambridge Associates, LLC and Subsidiary Consolidated Balance Sheet is attached.
20
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Consolidated Balance Sheet
December 31, 2024
(With Report of Independent Auditors Thereon)
Report of Independent Auditors
To the Management of Cambridge Associates, LLC
Opinion
We have audited the accompanying consolidated balance sheet of Cambridge Associates, LLC and its
subsidiaries (the “Company”) as of December 31, 2024, including the related notes (referred to as the
“consolidated balance sheet”).
In our opinion, the accompanying consolidated balance sheet presents fairly, in all material respects, the
financial position of the Company as of December 31, 2024 in accordance with accounting principles
generally accepted in the United States of America.
Basis for Opinion
We conducted our audit in accordance with auditing standards generally accepted in the United States of
America (US GAAS). Our responsibilities under those standards are further described in the Auditors’
Responsibilities for the Audit of the Consolidated Balance Sheet section of our report. We are required to
be independent of the Company and to meet our other ethical responsibilities, in accordance with the
relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is
sufficient and appropriate to provide a basis for our audit opinion.
Responsibilities of Management for the Consolidated Balance Sheet
Management is responsible for the preparation and fair presentation of the consolidated balance sheet in
accordance with accounting principles generally accepted in the United States of America, and for the
design, implementation, and maintenance of internal control relevant to the preparation and fair
presentation of a consolidated balance sheet that is free from material misstatement, whether due to fraud
or error.
In preparing the consolidated balance sheet, management is required to evaluate whether there are
conditions or events, considered in the aggregate, that raise substantial doubt about the Company’s ability
to continue as a going concern for one year after the date the balance sheet is available to be issued.
Auditors’ Responsibilities for the Audit of the Consolidated Balance Sheet
Our objectives are to obtain reasonable assurance about whether the consolidated balance sheet as a whole
is free from material misstatement, whether due to fraud or error, and to issue an auditors’ report that
includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and
therefore is not a guarantee that an audit conducted in accordance with US GAAS will always detect a
material misstatement when it exists. The risk of not detecting a material misstatement resulting from
fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control. Misstatements are considered material
if there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment
made by a reasonable user based on the consolidated balance sheet.
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617) 530 5000, www.pwc.com/us
In performing an audit in accordance with US GAAS, we:
● Exercise professional judgment and maintain professional skepticism throughout the audit.
● Identify and assess the risks of material misstatement of the consolidated balance sheet, whether
due to fraud or error, and design and perform audit procedures responsive to those risks. Such
procedures include examining, on a test basis, evidence regarding the amounts and disclosures in
the consolidated balance sheet.
● Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Company's internal control. Accordingly, no such opinion is
expressed.
● Evaluate the appropriateness of accounting policies used and the reasonableness of significant
accounting estimates made by management, as well as evaluate the overall presentation of the
consolidated balance sheet.
● Conclude whether, in our judgment, there are conditions or events, considered in the aggregate,
that raise substantial doubt about the Company’s ability to continue as a going concern for a
reasonable period of time.
We are required to communicate with those charged with governance regarding, among other matters, the
planned scope and timing of the audit, significant audit findings, and certain internal control-related
matters that we identified during the audit.
Boston, MA
March 27, 2025
2
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Consolidated Balance Sheet
December 31, 2024
(in thousands, except unit data, unless otherwise noted)
Assets:
Current assets:
$
83,379
Cash and cash equivalents
Receivables,
Trade
Unbilled fees and expenses
Other
Prepaid expenses and other current assets
Total current assets
66,423
34,379
1,235
17,981
203,397
Operating lease right-of-use assets
Property and equipment, net
Other assets
Total assets
$
115,115
38,608
2,744
359,864
Liabilities and Members’ Deficit:
Current liabilities:
$
Accrued compensation and benefits
Accounts payable and accrued expenses
Unearned revenue
Current portion of operating lease liabilities
Current portion of borrowings
Current portion of finance lease liabilities
Total current liabilities
83,314
23,057
20,304
14,547
11,900
207
153,329
Borrowings
Long-term portion of operating lease liabilities
Long-term portion of finance lease liabilities
Other liabilities
Total liabilities
Members’ deficit
Total liabilities and members’ deficit
$
294,196
101,517
253
8,028
557,323
(197,459)
359,864
See accompanying notes to the consolidated balance sheet.
3
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
1. Organization
Cambridge Associates, LLC is a Massachusetts limited liability company, formed on May 10, 2000 and
registered with the United States Securities and Exchange Commission (“SEC”) and United States Commodity
Futures Trading Commission as an investment adviser and commodity trading adviser, respectively. Cambridge
Associates, LLC, together, with its subsidiaries (“CA LLC” or “the Company”) provides investment
management services to endowments, foundations, pensions, private clients, family offices, healthcare systems,
and other investors in North America, Europe, the Middle East, Africa, and the Asia-Pacific region.
2. Acquisition
On November 1, 2024, CA LLC acquired SIGLO Capital Advisors (“SIGLO”), a Zurich-based alternatives
investment firm. The acquisition was accounted for as a business combination in accordance with Accounting
Standards Codification (ASC) 805, Business combinations. The contingent consideration has been excluded
from the purchase price and will be recognized as compensation expense over the respective period. The total
purchase price of $4,990 was allocated to the fair value of the assets acquired and liabilities assumed as follows:
$
Cash and cash equivalents
Intangible assets
Net other assets
$
3,753
398
839
4,990
Intangible assets consist of Licenses and Educational Content and are amortized on a straight-line basis over
their estimated useful lives of fifteen and five years, respectively. Net intangible assets are reported in Other
assets on the consolidated balance sheet.
Following the acquisition, SIGLO was renamed Cambridge Associates AG (“CA AG”). The assets and
liabilities of CA AG were consolidated into the Company’s consolidated balance sheet from the acquisition
date.
3. Summary of Significant Accounting Policies
Basis of Presentation
The accompanying consolidated balance sheet has been prepared in accordance with accounting principles
generally accepted in the United States of America (“US GAAP”) and include the accounts of CA LLC, and its
wholly owned subsidiaries. The preparation of consolidated balance sheet in conformity with US GAAP
requires management to make estimates, judgments and assumptions that affect the reported amounts of assets
and liabilities at the date of the consolidated balance sheet. Actual results could differ from those estimates. All
intercompany balances and transactions have been eliminated in consolidation.
Certain prior period presentations were reclassified to ensure comparability with current period classification.
Significant wholly owned operating subsidiaries include Cambridge Associates Limited LLC (“CA LTD
LLC”), Cambridge Associates Limited (“CA LTD”), Cambridge Associates GmbH (“CA GmbH, Cambridge
Associates Asia Pte Ltd (“CA Asia”), Cambridge Associates Hong King Private Limited (“CA Hong Kong”),
Cambridge Associates Investment Consultancy (Beijing) Ltd. (“CA Beijing”), and CA AG.
4
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
Variable Interest Entities
The Company is the general partner or managing member of various pooled and non-pooled investment vehicles
(“affiliated funds”). The Company's variable interests in such vehicles, including the investment advisory fees
and incentive fees earned, are evaluated at inception and thereafter, if there is a reconsideration event, in order
to determine whether the fund is a Variable Interest Entity (“VIE”).
A VIE is an entity in which either the equity investment at risk is not sufficient to permit the entity to finance
its own activities without additional financial support or the group of holders of the equity investment at risk
lack certain characteristics of a controlling financial interest. The primary beneficiary is the entity that has the
power to direct the activities of the VIE that most significantly affect its economic performance, and the
obligation to absorb losses of the entity or the right to receive benefits from the entity that could potentially be
significant to the VIE.
Affiliated funds are determined to be VIEs when the limited partners do not hold substantive kick-out or
participation rights. If the Company has a variable interest in an affiliated fund and such fund is a VIE, the
Company will assess whether it is the primary beneficiary and therefore, required to consolidate the fund. For
affiliated funds determined to be VIEs, the Company has determined it is not the primary beneficiary and
therefore, does not consolidate.
For affiliated funds that are not determined to be VIEs, the Company assesses whether it has control through a
majority voting interest to determine if consolidation is required.
The Company’s investments in affiliated funds were $600 at December 31, 2024 and are included in Other
assets on the consolidated balance sheet.
Cash, Cash Equivalents, and Restricted Cash
Cash and cash equivalents include cash on hand, non-interest bearing and interest-bearing deposits with
financial institutions, highly liquid debt instruments with original maturities of less than three months at the
purchase date, and money market funds. At December 31, 2024, the Company did not have any restricted cash
balances.
Fair Value
The Company uses a fair value hierarchy that prioritizes inputs to valuation approaches used to measure fair
value. The levels of the hierarchy are described below:
Level 1: Unadjusted quoted market prices for identical instruments in an active market.
Level 2: Quoted market prices for similar instruments and valuation models whose inputs are observable.
Level 3: Valuations derived from pricing models and discounted cash flow methodologies, or similar
techniques for which the significant inputs are not observable.
Money market funds of $52,418 at December 31, 2024 are recorded at fair value and classified Level 1 in the
fair value hierarchy. Money market funds are reported in Cash and cash equivalents on the consolidated balance
sheet.
5
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
Certain financial instruments are not carried at fair value, but their fair value is required to be disclosed. Refer
to the Note 6 for the carrying amounts and estimated fair values of the Company’s borrowings.
Receivables
Trade receivables are recorded at invoiced amounts and do not bear interest. Unbilled fees and expenses
represent receivables where the Company has an unconditional right to consideration under a contract but has
not yet issued an invoice. The Company performs a review of receivables on an ongoing basis in order to assess
collectability. At December 31, 2024, the allowance for doubtful accounts was $70, and reported net in Trade
receivables on the consolidated balance sheet.
Property and Equipment
Property and equipment are recorded at cost less accumulated depreciation. Depreciation is computed using the
straight-line method based on estimated useful life. Computer equipment is depreciated over a period of three
years. Furniture and equipment are depreciated over a period of five to ten years. Leasehold improvements and
equipment leased under finance leases are depreciated over the shorter of the useful life or the lease term.
Artwork has an indeterminable useful life and is measured for impairment loss. Disposals are recorded when
assets are retired, disposed, or impaired.
The Company capitalizes certain internal and external costs incurred in connection with developing or obtaining
software within property and equipment. Capitalized software costs are amortized over an estimated useful life
of three years beginning when the project is complete and the application is put into production.
Leases
The Company determines if a contract is a lease, or contains a lease, at inception and when the terms of an
existing contract are modified. Additionally, at contract inception, the Company will evaluate whether a lease
is an operating or finance lease.
Right-of-use (“ROU”) assets represent the Company’s right to use an underlying asset for the lease term and
lease liabilities represent the Company’s obligation to make lease payments arising from the lease. ROU assets
and the associated lease liabilities are recognized based on the present value of the future minimum lease
payments over the lease term at commencement date. The Company determines the present value using an
incremental borrowing rate based on information available at the commencement date. The ROU asset is
subsequently measured throughout the lease term at the amount of the remeasured lease liability (i.e., present
value of the remaining lease payments), plus unamortized initial direct costs, plus (minus) any prepaid (accrued)
lease payments, less the unamortized balance of lease incentives received, and any impairment recognized.
Lease costs are recognized on a straight-line basis over the lease term. Certain leases include lease and non-
lease components, which are accounted for as one single lease component. Leases with an initial term of 12
months or less are not recorded on the consolidated balance sheet.
6
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
Unearned Revenue
For certain clients, the Company collects fees or invoices in advance of performing services, recording the
amount as unearned revenue. Revenue is recognized as it is earned over the life of the contract.
Insurance Reserves
Reserves for self-insured medical benefits are based on the history of prior claims and any known individual
cases. Such liabilities are based on estimates and, while management believes that the amount is adequate, the
ultimate liability may be in excess or less than the amount provided. The methods for making such estimates
and for establishing the resulting liability are continually reviewed. See Note 8.
Income Taxes
CA LLC is organized as a limited liability company and treated as a partnership for US tax purposes; therefore,
it is not directly subject to income taxes apart from certain US state and local taxes where it conducts business
and foreign taxes attributable to its operations in foreign jurisdictions.
Deferred income taxes represent the future tax effects of temporary differences between taxable income for
financial statement purposes and income tax return purposes. A valuation allowance is established if the
Company believes it is more likely than not that a portion or an entire deferred asset balance will not be realized.
The Company evaluates tax positions taken or expected to be taken in the course of preparing an entity’s tax
returns to determine whether it is more likely than not that each tax position can be sustained upon examination,
including resolution of any related appeals or litigation processes. See Note 10.
Foreign Currency
Foreign currency transactions are recorded at the exchange rates prevailing on the dates of transactions.
Monetary assets and liabilities that are denominated in foreign currencies are subsequently remeasured into the
functional currencies of the Company’s subsidiaries at the rates prevailing at the consolidated balance sheet
date.
Assets and liabilities of foreign subsidiaries that operate in a local currency environment, where the local
currency is the functional currency, are translated into US dollars at exchange rates in effect on the consolidated
balance sheet date. Equity accounts are translated at historical rates, except for the change in retained earnings
during the year which is the result of the income statement translation process.
Other Comprehensive Income/(Loss)
Members’ deficit includes cumulative translation adjustments of ($8,461) as of December 31, 2024.
7
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
Concentration of Credit Risk
Financial instruments that potentially subject the Company to concentrations of credit risk consist primarily of
cash, cash equivalents, and restricted cash. The Company maintains cash and cash equivalents with various
financial institutions. The Company is subject to credit risk should these financial institutions be unable to fulfill
their obligations. Cash deposits maintained at a financial institution may exceed the federally insured limit.
4. Property and Equipment
Property and equipment consist of the following at December 31, 2024:
$
Computer equipment and software
Furniture and equipment
Leasehold improvements
Equipment leased under finance leases
Artwork
Less: accumulated depreciation and amortization
$
145,756
17,621
16,095
2,102
600
182,174
(143,566)
38,608
During 2024, the Company disposed of property and equipment with a cost and related accumulated
depreciation of approximately $458.
5. Leases
The Company’s leases primarily consist of operating leases for office space globally. These leases expire on
various dates through 2039, some of which include options to extend for an additional term and some of which
include an option to terminate. The Company maintains letters of credit (see Note 6), bank guarantees and cash
deposits as security for leases.
Maturities of operating lease liabilities as of December 31, 2024 were as follows:
Amounts
$
$
2025
2026
2027
2028
2029
Thereafter
Total undiscounted lease payments
Less: imputed interest
Total operating lease liabilities
$
15,526
13,138
12,345
11,723
12,262
84,791
149,785
(33,721)
116,064
As of December 31, 2024, the Company’s finance lease liabilities totaled $460.
8
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
5. Leases, continued
The Company entered into a lease agreement for office space located in Arlington, Virginia in October 2023,
which will commence in February 2025. The lease has a fifteen year term, including a noncancellable period
of nine years. A one-time termination option is available for years ten to fifteen, requiring a payment of
approximately $7.2 million. Total lease payments over the lease term are expected to be approximately $38
million. The Company will recognize a ROU asset and corresponding lease liability on commencement date.
6. Borrowings
Senior Notes
On August 28, 2018, the Company issued $200 million of Senior Notes at a fixed interest rate of 4.91% with a
10-year term to lenders. Interest is payable semi-annually and the principal is due at maturity on August 3,
2028. At December 31, 2024, the carrying value of the Senior Notes was $200,000. At December 31, 2024, the
estimated fair market value of the Senior Notes was $195,532, which was determined using a discounted cash
flow valuation model. At December 31, 2024, the discount rate was 5.61%.
Term Loan
On May 18, 2022, the Company entered into a $110 million unsecured 10-year term loan at a fixed interest rate
of 3.64%. Interest and principal is payable monthly with the remaining principal balance due at maturity on
May 18, 2032. At December 31, 2024, the carrying value of the Term Loan was $98,596. At December 31,
2024, the estimated fair value of the Term Loan was $87,515, which was determined using a discounted cash
flow valuation model. At December 31, 2024, the discount rate was 5.94%.
Credit Facility
On December 18, 2024, the Company entered into an amended and restated senior unsecured revolving credit
facility (“Credit Facility”). The Credit Facility’s has a 5-year term with a maximum borrowing capacity of $40
million during the period of January 1st through April 30th each year and a maximum borrowing capacity of $30
million during the period of May 1st through December 31st each year. The amount outstanding under the Credit
Facility bears interest at a variable rate, at the Company’s election, either at: i) the Base Rate (as defined) plus
the Applicable Rate (as defined in the Credit Facility) or ii) the Secured Overnight Federal Rate (”SOFR”) Rate
(as defined in the Credit Facility) plus the Applicable Rate (as defined in the Credit Facility).
Borrowings under the Credit Facility may be used for working capital and other general corporate purposes.
Pursuant to the terms of the Credit Facility, the Company may issue letters of credit under the Credit Facility.
At December 31, 2024, the Company provided security deposits in the form of a letter of credit for certain
operating leases totaling $3,927. At December 31, 2024, there was $7,500 outstanding under the Credit Facility.
As a result, the available borrowing capacity under the Credit Facility was $18,573 at December 31, 2024.
The Company’s Borrowings contain certain affirmative, negative and financial covenants. At December 31,
2024, the Company was in compliance with these covenants.
As a result of Borrowings, the consolidated balance sheet reflected an excess of liabilities over assets of
$197,459.
9
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
7. Unit-Based Compensation
Profits Interests
In 2018, the Company’s Board of Managers approved a new equity plan authorizing Cambridge Associates
Partners LP (“CAP LP”), a newly formed affiliate, to grant profits interests (the “profits interests”) to the CA
LLC’s US partners. Each grant of profits interests in CAP LP corresponds to profits interests in CA LLC. The
profits interests are intended to constitute “profits interests” within the meaning of Internal Revenue Code
guidance or other amendments that supplement or supersede the foregoing guidance. The profits interests are
granted at fair value as determined by the Company’s Board of Managers and generally vest ratably over seven
years. Unvested profits interests are forfeited at termination.
A summary of profits interests at December 31, 2024, and activity for the year then ended is presented below:
Units
Weighted
Average
Remaining
Contractual
Term (in years)
Outstanding at December 31, 2023
Granted
Repurchased
Cancelled/Forfeited
Outstanding at December 31, 2024
Vested at December 31, 2024
13,087
480
(1,534)
(329)
11,704
8,304
1.45
1.00
A summary of the status of the Company’s nonvested profits interests at December 31, 2024, and activity for
the year then ended is presented below:
Units
Nonvested at December 31, 2023
Weighted
Average
Grant-Date Fair
Value
$
Granted
Vested
Forfeited
Nonvested at December 31, 2024
4,470
480
(1,221)
(329)
3,400
$
6,436
8,779
5,889
5,947
7,010
10
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
7. Unit-Based Compensation, continued
Unit Options
The Company’s unit option plan permits the grant of nonstatutory, nondesignated options to non-US partners
and certain employees. Unit options are granted with an exercise price equal to fair value as determined by the
Company’s Board of Managers at the time of issuance. Unit options generally vest ratably over seven years.
Unvested unit options are forfeited at termination.
The Black-Scholes model was developed for use in estimating the fair value of traded options, incorporating
assumptions as to estimated volatility, estimated dividend rate, expected term and risk-free rate. Many of these
assumptions require management’s judgment. CA LLC’s estimated volatility assumption is based on the
average historical volatility of daily share prices for peer companies that are publicly traded over a period equal
to the expected term of the options. The Company uses historical data to estimate the expected term of options
granted. The risk-free rate for periods within the contractual term of the unit option is based on the US Treasury
yield curve in effect at the time of grant.
Valuation assumptions for the years ended December 31, 2024 are as follows:
Estimated volatility
Estimated dividend-price ratio
Expected term (in years)
Risk-free rate
January 1, 2024
38.10%
7.75%
15
4.60%
A summary of options at December 31, 2024, and activity for the year then ended is presented below:
Units
Weighted
Average
Remaining
Contractual
Term (in years)
Outstanding at December 31, 2023
Granted
Exercised/Repurchased
Cancelled/Forfeited
Outstanding at December 31, 2024
Exercisable at December 31, 2024
2,884
145
(103)
-
2,926
2,330
Weighted
Average
Exercise Price
$
9,051
13,045
9,274
-
9,241
8,504
$
$
1.18
1.00
11
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
7. Unit-Based Compensation, continued
Unit Options
A summary of the status of the Company’s nonvested options at December 31, 2024 and activity for the year
then ended is presented below:
Units
Weighted
Average
Exercise Price
Nonvested at December 31, 2023
Weighted
Average
Grant-Date Fair
Value
$
Granted
Vested
Forfeited
Nonvested at December 31, 2024
619
145
(168)
-
596
$
1,722
1,752
1,988
-
1,654
$
12,124
The total fair value of options that vested during the years ended December 31, 2024 was $334.
8. Self-Insurance
CA LLC maintains a contributory, self-insured medical care plan which provides health and dental benefits to
eligible employees (and their dependents). The cost of such benefits is provided through contributions by
participating employees and CA LLC. At December 31, 2024, CA LLC’s accrued estimated reserves of $2,017
for claims incurred but not paid, were included in Accounts payable and accrued expenses on the consolidated
balance sheet.
9. Employee Benefit Plans
CA LLC sponsors a defined contribution 401(k) plan for US employees who meet the plan’s eligibility
requirements and CA LLC is required to make basic and supplemental matching contributions, as defined by
the plan document.
CA LTD LLC also sponsors a defined contribution pension plan for non-US employees who meet the plan’s
eligibility requirements and is required to make a basic contribution and a matching contribution, as defined by
the plan document.
12
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
10. Income Taxes
The significant components of deferred income taxes at December 31, 2024 are as follows:
Deferred tax assets:
$
Difference in tax provision
Difference in operating lease liabilities
Gross deferred tax assets
27
3,774
3,801
Deferred tax liabilities:
$
Differences in fixed asset bases
Difference in right-of-use asset
Gross deferred tax liabilities
Net deferred tax asset (liabilities)
$
$
132
3,774
3,906
(105)
Net deferred tax assets are included in Other assets on the consolidated balance sheet while net deferred tax
liabilities are included in Other liabilities on the consolidated balance sheet.
At December 31, 2024, the Company had no net operating loss carryforwards.
At December 31, 2024, the Company’s accrued taxes, interest and penalties associated with uncertain tax
positions was $234 and is reported in Accounts payable and accrued expenses on the consolidated balance sheet.
The Company files income tax returns with federal, state, local, and foreign jurisdictions. The Company’s
federal and state tax returns are open from 2020 through 2024. For all foreign jurisdictions, 2018 through 2024
are subject to future examinations.
11. Related Party Transactions
The Company serves as general partner or managing member to the affiliated funds. Fees receivable from
affiliated funds were $1,293 at December 31, 2024, and are included in Trade receivables on the consolidated
balance sheet.
The Company is also reimbursed for ordinary operating expenses paid on behalf of certain affiliated funds.
Amounts due from affiliated funds for such expenses were $1,048 at December 31, 2024, and are included in
Other receivables on the consolidated balance sheet.
12. Capital Reserves
The Company is required to maintain net capital in certain regulated subsidiaries within a number of
jurisdictions. Such requirements may limit the Company’s ability to make withdrawals of capital from these
subsidiaries.
CA LTD is subject to regulation by the United Kingdom’s Financial Conduct Authority (“FCA”). CA LTD
complies with the FCA’s capital adequacy requirements under the Investment Firms Prudential Regime
(“IFPR”). At December 31, 2024, CA LTD holds regulatory capital of approximately £11,201 ($14,013),
exceeding the minimum requirements.
13
CAMBRIDGE ASSOCIATES, LLC AND SUBSIDIARIES
Notes to the Consolidated Balance Sheet
(in thousands, except unit data, unless otherwise noted)
At December 31, 2024, the Company was required to maintain net capital in certain other regulated subsidiaries.
The Company was in compliance with all applicable regulatory minimum net capital requirements.
13. Commitments and Contingencies
From time to time, the Company may be subject to legal or regulatory proceedings arising out of the ordinary
course of its business. Management believes that any losses resulting from the resolution of such proceedings
would not have a material adverse effect on the Company’s consolidated balance sheet.
14. Risks and Uncertainties
Geopolitical risks, including those arising from trade tension and/or the imposition of trade tariffs, terrorist
activity or acts of civil or international hostility, and military conflicts could adversely affect the global economy
or specific markets. Strategic competition between the US and other countries and resulting tensions, could also
contribute to uncertainty in the geopolitical and regulatory landscapes.
Such events and responses, including regulatory developments, may cause 1) significant volatility and declines
in the global markets, 2) disproportionate impacts to certain industries or sectors, 3) disruptions to commerce
(including to economic activity, travel and supply chains), and 4) loss of life and property damage. These risks
and potential impacts could adversely affect the Company’s products, operations, clients, vendors and
employees, which may cause revenue and earnings to decline.
15. Subsequent Events
On January 27, 2025, the Company entered into an uncommitted note purchase and private shelf agreement.
This agreement allows the Company to issue senior notes from time to time in an aggregate principal amount
not to exceed $100 million. Each series of senior notes shall specify the principal amounts, final maturities (no
more than 12 years from the date of issuance), principal prepayment dates and amounts (average life of no more
than 12 years) and interest payment periods of the notes covered thereby.
There have been no other material subsequent events occurring after December 31, 2024, through March 27,
2025, which would require recognition or disclosure in the consolidated balance sheet.
14