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FORM ADV, PART 2A
THE BROCHURE
OF
EAST END ADVISORS, LLC
610 FIFTH AVENUE
3rd Floor
NEW YORK, NEW YORK 10020
TELEPHONE: (212) 396-5900
March 28, 2025
This Brochure provides information about the qualifications and business practices of East End Advisors, LLC. If you have
any questions about the contents of this Brochure, please contact us at 212-396-5900 The information in this Brochure has
not been approved or verified by the United States Securities and Exchange Commission or any state securities authority.
Additional information about East End Advisors, LLC also is available on the Securities and Exchange Commission's
website at www.adviserinfo.sec.gov.
East End Advisors, LLC (“East End”, “we” or the “Adviser”) is an investment adviser registered with the Securities and
Exchange Commission; this registration does not imply that the Adviser or any of its employees has any particular level of
skill or training.
In accordance with the rules of the SEC, we use this Brochure as our disclosure document for prospective clients as well as
current clients. We deliver the Brochure to prospective clients no later than at the time when the advisory contract is entered
into. Each year we send our current clients the annually-updated Brochure, or a separate summary of material changes
together with information on how to obtain the complete Brochure and how to obtain information about us through the SEC
website.
In addition, we will send our clients any interim updates of the Brochure to the extent the SEC’s rules require or if we
believe it is appropriate.
Item 2
MATERIAL CHANGES
The Adviser does not consider any of the information contained in this version of the Brochure to
represent a material change from the information contained in its most recent, previous version
dated July 17, 2024.
Our current and prospective investors are encouraged to read this Brochure, as well as all of the
governing documents applicable to their current or prospective investment, in their entirety. To
receive an additional current copy of this Brochure free of charge, please contact Whitney Fogle
Lewis, Chief Legal Officer, US and Chief Compliance Officer, at (214) 855-2202 or
whitney.lewis@AlTi-Global.com.
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Item 3
TABLE OF CONTENTS
Page
Item 1. Cover Page……………………………………………………………… Cover
Item 2. Material Changes………………………………………………………
2
Item 3. Table of Contents………………………………………………………
3
Item 4. Advisory Business……………………………………………………..
4
Item 5. Fees and Compensation………………………………………………..
6
Item 6. Performance-Based Fees and Side-By-Side Management…………….
7
Item 7. Types of Clients………………………………………………………..
8
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss……….. 9
Item 9. Disciplinary Information……………………………………………… 11
Item 10. Other Financial Industry Activities and Affiliations…………………... 12
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading………………………………………………………………………….. 14
Item 12. Brokerage Practices……………………………………………………....17
Item 13. Review of Accounts……………………………………………………....18
Item 14. Client Referrals and Other Compensation……………………………… 19
Item 15. Custody……………………………………………………………….…. 20
Item 16. Investment Discretion…………………………………………………….21
Item 17. Voting Client Securities…………………………………………………. 22
Item 18. Financial Information……………………………………………………..23
PLEASE NOTE: THIS BROCHURE MOSTLY REFERS TO THE ADVISER’S “EMPLOYEES” RATHER
THAN THE LEGAL TERMS CONTAINED IN THE INSTRUCTIONS FOR THE BROCHURE
BECAUSE, IN OUR CASE, “EMPLOYEES” COVER ALL OF
THE REQUIRED PERSONS.
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Item 4
ADVISORY BUSINESS
A. The Adviser
East End was formed in April 2008 as a New York limited liability company.
Effective April 3, 2024, 100% of the Adviser’s assets were acquired by an indirect
subsidiary of AlTi Global, Inc., a publicly traded company.
B. Types of Advisory Services & Client-Specific Services
East End assists clients in developing a customized, overall asset allocation strategy across all
asset classes and in setting investment goals and objectives. Then, as a manager-of-managers,
we provide advice regarding which external, third-party, unaffiliated investment managers
(“Investment Managers”) would be most appropriate to manage portions of each client’s assets
to achieve their objectives. Generally, East End will recommend Investment Managers that
manage investment funds including investment partnerships, private equity funds, separately
managed accounts, hedge funds and the like (“Investment Funds”). Accordingly, we assist
each of our clients with building broadly diversified investment portfolios.
We monitor the Investment Managers and their Investment Funds and use benchmarks and
other quantitative data as well as qualitative information to measure the relative performance
of the Investment Funds on behalf of clients. As part of this process, and as we deem
appropriate from time to time, we also consider potential changes to our clients’ rosters of
Investment Funds and Investment Managers.
As such, since the majority of our clients’ assets are invested in Investment Funds managed by
third-party Investment Managers, East End provides primarily non-discretionary advisory
services.
To the extent a portion of a client's short-term assets are pending deployment in an Investment
Fund, or to the extent a client has determined to maintain a permanent portion of their portfolio
outside of Investment Funds, East End provides advisory services on a discretionary basis. We
typically achieve this through investments in U.S. Government securities, although we may,
to a significantly lesser extent, use other investments from time to time at the client's request
or as we deem appropriate.
For our purposes, our clients’ portfolios (“Portfolios”) consist of their roster of Investment
Funds, their assets awaiting deployment and their assets not destined for Investment Funds.
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East End also provides general investment consultation to clients without supervisory
services for a fixed, flat, annual fee.
C. Wrap-Fee Program Participation
This item is not applicable because East End does not participate in any wrap fee
programs.
D. Client Assets Under Management
East End managed approximately $5.8 billion in client assets on a non-discretionary basis
as of December 31, 2024.
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Item 5
FEES AND COMPENSATION
A. Advisory Fee
All of East End’s clients are “qualified purchasers” (as defined in the Investment
Company Act of 1940). For advisory services, East End charges an annualized fee
based on the amount of Portfolio assets it manages and monitors for the particular
client. Such fee is typically paid quarterly. Our fee is based solely on the amount of
assets under management and East End does not charge performance-based fees. For
investment consultations without investment supervisory services East End charges a
flat fee for such services.
All fees and payment terms are negotiated individually with each client depending on
the full nature of services provided to such client and are subject to revision.
B. Frequency and Method of Advisory Fee Payment
We bill our clients for the fee for our investment advisory and investment consultation
services, which is generally payable in quarterly installments.
C. Other Fees or Expenses
In addition to paying East End’s advisory fees, our clients pay their own custodian fees.
East End clients also incur the cost of management fees, performance fees and
operating expenses related to their Investment Funds.
D. Timing of Advisory Fee Payments
East End’s fees are generally charged in advance. If an account is terminated, the client
is entitled to a pro rata refund of any amounts paid but not yet earned by East End.
E. Compensation for the Sale of Investment Products
This is not applicable, since neither the Adviser nor any of its employees accepts
compensation for the sale of securities or other investment products.
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Item 6
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
This item is not applicable because East End does not charge any performance-based fees to any
clients.
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Item 7
TYPES OF CLIENTS
East End provides investment advisory services to various high net worth individuals, families,
trusts and charitable institutions, foundations and endowments.
Generally, the minimum Portfolio size for an East End client is $500 million. However, we have
accepted clients with less than that amount.
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Item 8
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
A. Methods of Analysis and Investment Strategies
Our primary advisory service involves setting investment goals and objectives together with a
client and then formulating a customized asset allocation strategy including advice regarding
specific Investment Managers and Investment Funds, and assistance in building a broadly
diversified investment portfolio. We provide advice regarding change recommendations as
necessary.
The majority of East End's investment recommendations are long-term in nature and thus require
long-term investments with Investment Managers or in Investment Funds. We also use other
investment strategies, which could be long-term or short-term, as part of a client's overall asset
allocation strategy or on the portion of a client's Portfolio that is pending deployment in an
Investment Fund or that is designated by the client to be kept outside of Investment Funds. These
other investments primarily consist of investments in U.S. government securities.
The Adviser performs on-going reviews of Investment Managers, which include reviews of
various factors such as performance, quantitative measures, qualitative matters and periodic
meetings with and reports from Investment Managers. In addition, East End’s sources of
information for our investment ideas may originate through the membership of our managing
partners on external boards, investment committees or the like, or may come from financial
publications and research materials prepared by others. East End’s employees have also served,
and may continue to serve, on limited partner advisory committees or similar committees of
certain Investment Funds in which clients invest. These are committees formed by certain
Investment Managers, generally composed of fund investors or their representatives, to provide
fund investors a voice in and visibility into certain Investment Fund matters.
We also use various proprietary tools to assist in the analysis of specific Investment Funds and
the client's overall Portfolio. Additionally, East End uses Advent Axys Portfolio software as
the primary accounting/performance reporting system for client Portfolios and for pricing and
index information.
Clients should remember that investing in securities involves the risk of loss, which
they should be prepared to bear.
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B. General Material Risks & Security-Specific Material Risks
East End’s predominant investment strategy is the development of an asset allocation
strategy and the subsequent recommendation of Investment Funds to clients. The
material risks involved in this strategy are general market risks and risks specific to
such funds, including:
• Market Risk – The value of a client account will vary continuously as a result
of a variety of factors including macro-economic issues, global geo-political
issues and as a result of turbulence and volatility in the financial markets in
general.
• Lack of Transparency – Certain types of Investment Funds often have fewer
disclosure requirements as to their portfolio, strategies and/or risks.
• Conflict of Interest – Most of the Investment Funds East End recommends to
clients pay performance-based fees to their respective managers. By receiving
a performance fee, the manager of an Investment Fund has an incentive to
construct a riskier portfolio if it wants to increase the chances of a higher return
and therefore higher performance fees.
• Riskier Strategies – Investment Funds invest in securities. Certain Investment
Funds may use strategies that involve higher risk and volatility, such as
leverage, short-selling and/or trading on margin. Others may make investments
in riskier securities such as high yield bonds, distressed securities or
collateralized debt obligations. In addition, private equity funds invest directly
in businesses, ranging from young or emerging companies to existing mature
companies that require additional capital.
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Item 9
DISCIPLINARY INFORMATION
This item is not applicable because there are no legal or disciplinary events relating to the
Adviser or its employees.
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Item 10
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
The Adviser is under common ownership with various entities including companies that engage in
financial services activities around the world, including the entities described above and set out
below. The Adviser has adopted relevant policies and procedures that are designed to mitigate any
material conflicts that may arise with its Clients as a result from the below affiliations.
United States
• Tiedemann Advisors, LLC is a US investment adviser which is registered with the
U.S. Securities and Exchange Commission (CRD number 147189).
• TIG Advisors LLC is a US investment adviser which is registered with the U.S.
Securities and Exchange Commission (CRD number 138306).
• AlTi Wealth Management (US International), Inc., is a US investment adviser
which is registered with the U.S. Securities and Exchange Commission (CRD
number 152104).
Hong Kong
• AlTi Wealth Management (Hong Kong) Limited is an investment adviser which is
registered with and regulated by the Securities and Futures Commission of Hong
Kong, reference AJF298.
Portugal
• AlTi Wealth Management (Portugal) - Empresa De Investimento, S.A. is an
investment adviser which is registered and regulated by Comissão do Mercado de
Valores Mobiliários (CMVM) with registration number 311.
France
• AlTi Wealth Management (France) SAS is an investment adviser which is
authorized and regulated in France by the Autorité des Marchés Financiers (AMF)
(AMF No GP 00-037).
United Kingdom
• AlTi RE Limited is an investment adviser which is authorized and regulated by the
Financial Conduct Authority (FCA number 582903).
• AlTi Wealth Management (UK) Limited is an investment adviser which is
authorized and regulated by the Financial Conduct Authority (FCA number
541713).
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• Alvarium Fund Managers (UK) Limited is an authorized fund manager which is
authorized and regulated by the Financial Conduct Authority (FCA number
751355).
• Cresco Capital Advisers LLP (FCA number 728726) is an investment adviser
which is an appointed representative of AlTi RE Limited, which is authorized and
regulated by the Financial Conduct Authority.
• AlTi Strategic Advisory (UK) Limited (FCA number 824598) is an investment
adviser and corporate broker which is an appointed representative of AlTi RE
Limited, which is authorized and regulated by the Financial Conduct Authority.
• Holbein Partners LLP is an investment adviser which is authorized and regulated
by the Financial Conduct Authority (FCA number 529416).
• Social Housing Income Advisors Limited (FCA number 815126) is an investment
adviser which is an appointed representative of AlTi RE Limited, which is
authorized and regulated by the Financial Conduct Authority.
Singapore
• AlTi Wealth Management (Singapore) Pte Limited is an exempt financial adviser,
which is registered with the Monetary Authority of Singapore.
Switzerland
• AlTi Wealth Management (Switzerland) SA is a Swiss portfolio manager licensed
by the Swiss Financial Market Supervisory Authority (FINMA) and supervised by
the AOOS.
• AlTi Wealth Management (Switzerland-US) AG is an investment adviser
registered with the Swiss Financial Market Supervisory Authority.
The information in this Brochure is provided solely with respect to the Adviser. For more
information on any affiliated US investment advisers, please see such adviser’s Form ADV.
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Item 11
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
A. Code of Ethics
East End has adopted a Code of Ethics (the “Code”) for itself and all employees of the
Adviser describing its high standard of business conduct and fiduciary duty to its
Clients. The Code includes provisions relating to the confidentiality of Client
information, a prohibition on insider trading, restrictions on the acceptance of
significant gifts and the reporting of certain gifts and business entertainment items, and
personal securities trading procedures, among other things. All supervised persons at
the Adviser must acknowledge the terms of the Code annually, or as amended.
The Code requires reporting of personal trading information and pre-clearance of
transactions in private investment funds as well as certain other transactions. Employee
trading is continually monitored under the Code to reasonably prevent or mitigate
conflicts of interest between East End and its Clients.
We will provide a copy of our Code of Ethics to any client or prospective client, upon
request. Please contact Whitney Fogle Lewis at 214-855-2202.
B. Client Trades in Securities in which there is a Material Personal Financial Interest
As a matter of practice and as a general rule, neither the Adviser nor any of its
employees recommends to clients, or buys or sells for client accounts, any securities in
which the Adviser or any employee has a financial interest. However, certain
employees of the Adviser currently hold an interest which represents a de minimis
percentage of the equity of an unaffiliated Investment Manager that manages an
Investment Fund that the Adviser has recommended to certain clients. This represents
a conflict of interest because fees paid to the Investment Manager in respect of client
investments in the Investment Fund indirectly benefit the employees who hold an
interest in the Investment Manager. The Adviser addressed this conflict by providing
each client to whom the investment was recommended with full disclosure of the fact
that employees held an interest in the Investment Manager and of the resulting conflict
and proceeding with each client’s investment only where such client affirmatively
chose to invest after being informed of the conflict. The Adviser intends to take the
same approach in the unlikely event that any similar conflict should arise in the future.
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C. Personal Investments in the Same Securities that are Bought or Sold for Clients
East End employees may invest in Investment Funds recommended to clients at, or at
about, the same time as clients. In some cases, this practice enables employees to make
investments that would not otherwise be available to them because of, for example,
minimum investment thresholds. Although this practice would pose a conflict in cases
where employees’ investment interests differed from those of clients, the Adviser
believes that the interests of its employees and clients are nearly universally aligned
where they invest concurrently in the same Investment Fund. The Adviser addresses
this potential conflict by seeking to align clients’ and employees’ interests to the extent
possible by requiring that any employees invest on the same terms as clients that are
concurrently investing and without, for example, any discount on Investment Fund
management fees or any other terms or advantages not also afforded to such clients.
the Adviser believes employee
investment
Although
in Investment Funds
recommended to clients generally aligns the incentives of the Advisor’s employees
with those of the Advisor’s clients as described above, this practice also may present a
conflict of interest in that the employee or his or her related person could take an
investment opportunity away from a client if the investment opportunity is, or becomes,
limited. The Adviser addresses this conflict by requiring employees and their related
persons to obtain prior approval for investments in Investment Funds and by
prohibiting employees from making an investment in any case where there is not
sufficient availability to first satisfy the full allocation considered by the Adviser to be
appropriate for clients based on the considerations described below.
East End makes decisions to recommend, purchase, sell or hold investments for its
client accounts based on the specific investment objectives, guidelines, restrictions, risk
tolerances, asset allocation goals and circumstances of each client account. East End
allocates investment opportunities to each client over time on a fair and equitable basis
relative to its other clients. Where client accounts have competing interests in limited
investment opportunities, East End will allocate these investment opportunities based
on numerous considerations, including cash availability and/or liquidity requirements,
the time competing accounts have had funds available for investment or have had
investments available for sale, an account's participation in other or comparable
opportunities, tax considerations, the relative size of portfolio holdings of the same or
comparable investments, etc. In general, East End favors clients holding meaningful
investment weightings for their accounts. For example, East End believes that it is
generally more desirable for a smaller client to hold a meaningful position in a
particular investment, rather than for a larger client to hold an insignificant position.
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On certain occasions, East End may recommend that a client buy or sell a security that
is publicly traded. East End does not generally select or recommend broker-dealers for
such transactions. East End’s client will either use a broker-dealer they select to
execute transactions in the security, or direct East End to use a specific broker-dealer.
Whichever is the case, the client will negotiate terms and arrangements for the account
with that broker-dealer, and East End will not seek better execution services or prices
from other broker-dealers.
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Item 12
BROKERAGE PRACTICES
This Item is not applicable because East End does not select or recommend broker-dealers for
client transactions.
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Item 13
REVIEW OF ACCOUNTS
East End’s Managing Partners, along with East End’s team of investment professionals, review
client Portfolios on a weekly basis. We may also review Portfolios more frequently because of a
client’s investment strategy or objective, a client’s personal needs, the macro-economic
environment, changes in laws, the availability of new investment products and superior or inferior
performance by a previously recommended or available Investment Manager or Investment Fund.
We limit the number of clients we manage to ensure proper oversight and the performance of
regular and thorough reviews of client Portfolios.
East End generally provides clients with written Portfolio summary reports and performance
reports monthly. Performance is reported in absolute and relative terms. That is, the underlying
Investment Funds in client Portfolios are compared to the performance of agreed-upon indices
and/or other Investment Managers with a similar style and strategy.
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Item 14
CLIENT REFERRALS AND OTHER COMPENSATION
This item is not applicable because East End does not receive an economic benefit from anyone
other than a client for providing investment advice to our clients, nor does the firm directly or
indirectly compensate anyone for client referrals.
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Item 15
CUSTODY
East End has engaged Ashland Partners & Company LLP to conduct annual surprise examinations
of client accounts for which EEA maintains custody, in accordance with SEC requirements.
Following an examination, Ashland Partners & Company LLP will file a Form ADV-E with the
SEC as part of East End’s filing with the SEC. Additional information can be found at
www.adviserinfo.sec.gov.
East End’s clients should receive, at least quarterly, statements from the broker-dealer, bank or
other qualified custodian that holds and maintains their investment assets. East End urges clients
to review carefully such statements and compare such official custodial records to any statements
that East End may provide to them. East End’s statements may vary from the custodial statements
based on accounting procedures, reporting dates or valuation methodologies of certain securities.
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Item 16
INVESTMENT DISCRETION
East End provides non-discretionary advisory services. To the limited extent we have discretionary
authority over client accounts, a client’s objectives and guidelines may limit that authority. Before
we assume any discretionary authority over a client’s account, we ensure that there is proper
authorization in place.
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Item 17
VOTING CLIENT SECURITIES
This item is not applicable because East End does not accept authority to vote any client
securities.
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Item 18
FINANCIAL INFORMATION
A. Balance Sheet
This item is not applicable because East End does not require or solicit
prepayment of more than $1,200 in fees per client, six months or more in
advance.
Financial Condition
B.
East End has no financial conditions that are reasonably likely to impair our
ability to meet contractual commitments to our clients.
C. Bankruptcy
This item is not applicable because East End has never been the subject of a
bankruptcy petition.
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