Acm: investment adviser

Asymmetric Capital Management, LLC (“ACM”) is an investment advisory firm providing discretionary and non-discretionary investment management services to individuals, high net worth individuals, institutions, family offices, pension plans, foundations, and other sophisticated investors. ACM was formed as a limited liability company and is owned and managed by Lorenzo Paloscia. Advisory Services Offered • Discretionary portfolio management • Non-discretionary investment consulting • Asset allocation and portfolio construction • Risk management and hedging strategies • Systematic rebalancing strategies • Derivatives and overlay strategies • Concentrated position management • Third-party manager selection and monitoring Discretionary vs.

Asymmetric Capital Management, LLC (“ACM”) is compensated for its advisory services through asset-based advisory fees. Fees are negotiable and may vary based on account size, complexity of services, and investment strategy utilized. Asset-Based Fees ACM typically charges an annual advisory fee based on a percentage of assets under management. The annual fee generally ranges from 0.20% to 1.00% of assets under management. The specific fee is agreed upon in advance and documented in the client’s investment advisory agreement. Fees are typically billed quarterly in arrears based on the value of assets under management. In certain cases, fees may be billed quarterly in advance as agreed with the client. Performance-Based Fees ACM may charge performance-based fees for qualified clients.

Asymmetric Capital Management, LLC (“ACM”) may enter into arrangements to receive performance-based fees for certain qualified clients. Performance-based fees are based on a share of capital gains on, or capital appreciation of, client assets. Performance-based fee arrangements are only offered to clients who meet the definition of a qualified client under Rule 205-3 of the Investment Advisers Act of 1940. Conflicts of Interest Performance-based fee arrangements create a potential conflict of interest because ACM has an incentive to favor accounts that pay performance-based fees over those that pay only asset-based fees. ACM also has an incentive to take greater risks in accounts subject to performance-based compensation.

Asymmetric Capital Management, LLC (“ACM”) provides investment advisory services to a variety of client types. These clients may include: • Individuals (including non-high-net-worth individuals) • High net worth individuals • Family offices • Institutional investors • Pension and profit-sharing plans • Endowments and foundations • Corporations and business entities • Religious organizations and nonprofit institutions • Other investment advisers Account Minimums ACM does not impose a strict minimum account size. However, ACM generally seeks to work with clients whose account size is sufficient to allow for proper diversification and efficient implementation of investment strategies. ACM reserves the right to waive or modify minimum account size requirements at its discretion.

Asymmetric Capital Management, LLC (“ACM”) utilizes a combination of quantitative, technical, and fundamental methods of analysis in managing client portfolios. These approaches are designed to evaluate market conditions, asset allocation, and portfolio risk. Methods of Analysis ACM may use the following methods of analysis: • Quantitative analysis, including systematic models and statistical evaluation • Technical analysis, including trend and volatility evaluation • Fundamental analysis, including economic and market condition review Each method of analysis involves inherent limitations and may not accurately predict future market performance.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of Asymmetric Capital Management, LLC (“ACM”) or the integrity of its management. Asymmetric Capital Management, LLC has no legal or disciplinary events to disclose that are material to a client’s or prospective client’s evaluation of the firm or the integrity of its management.

Lorenzo Paloscia, the principal owner of Asymmetric Capital Management, LLC (“ACM”), is affiliated with DNA Capital, where he serves as an associated person of an introducing broker. DNA Capital operates as an introducing broker that facilitates client access to futures commission merchants, brokerage firms, and other execution platforms. In this role, Mr. Paloscia may assist clients in establishing brokerage relationships and executing transactions. Conflicts of Interest This affiliation creates potential conflicts of interest. Mr. Paloscia may recommend brokerage firms or execution venues with which DNA Capital has a relationship. DNA Capital may receive compensation related to brokerage services, including commissions or other transaction-based fees. This creates an incentive for Mr.

Trading Asymmetric Capital Management, LLC (“ACM”) has adopted a Code of Ethics designed to ensure that the firm and its supervised persons act in the best interests of clients and comply with applicable federal securities laws. The Code of Ethics addresses standards of business conduct, fiduciary obligations, and personal trading practices. Clients or prospective clients may request a copy of ACM’s Code of Ethics by contacting the firm. Fiduciary Duty ACM is a fiduciary and has an obligation to act in the best interests of its clients. This duty requires ACM to place client interests ahead of its own and to disclose material conflicts of interest. Personal Trading ACM and its supervised persons may buy or sell securities for their own accounts that are also recommended to clients.

Asymmetric Capital Management, LLC (“ACM”) selects brokers and dealers for client transactions consistent with its duty to seek best execution. Best execution is the combination of price and execution quality that results in the most favorable overall outcome for the client. In selecting brokers, ACM may consider factors including execution capability, commission rates, financial stability, responsiveness, and the ability to handle complex investment strategies. Directed Brokerage Clients may direct ACM to use a specific broker or custodian. When clients direct brokerage, ACM may not be able to obtain best execution and clients may pay higher transaction costs. Directed brokerage may also prevent ACM from aggregating trades across client accounts.

Asymmetric Capital Management, LLC (“ACM”) reviews client accounts on a periodic basis to ensure that portfolios remain consistent with client objectives, risk tolerance, and investment guidelines. Frequency of Reviews Client accounts are typically reviewed on a quarterly basis. Accounts may also be reviewed upon significant market movements, changes in client objectives, cash flows, or when rebalancing is required. Who Conducts Reviews Account reviews are conducted by Lorenzo Paloscia, Principal and Portfolio Manager of Asymmetric Capital Management, LLC. Client Reporting Clients receive account statements directly from their custodian at least quarterly. These statements include holdings, transactions, and account balances.

Asymmetric Capital Management, LLC (“ACM”) may enter into referral arrangements with third parties who refer clients to ACM. In such cases, ACM may compensate the referring party for the introduction. Any referral compensation will be paid in accordance with applicable regulatory requirements. Clients will receive disclosure of any material referral arrangement prior to or at the time of entering into an advisory agreement. Referral Compensation Referral compensation, if any, is typically based on a portion of the advisory fee paid by the client. The client will not pay additional fees as a result of such arrangements. Other Compensation As disclosed in Item 10, Lorenzo Paloscia is affiliated with DNA Capital, an introducing broker.

Asymmetric Capital Management, LLC (“ACM”) does not maintain custody of client funds or securities. Client assets are held by independent qualified custodians. Clients receive account statements directly from their custodian at least quarterly. These statements include holdings, transactions, and account balances. Fee Deduction Authority ACM may be authorized to deduct advisory fees directly from client accounts. This authority is granted in writing by the client and documented in the investment advisory agreement. When fee deduction authority is granted, the custodian sends account statements directly to the client, and ACM provides an invoice showing the calculation of the advisory fee. The ability to deduct fees from client accounts is deemed to be custody under applicable regulations.

Asymmetric Capital Management, LLC (“ACM”) generally provides investment advisory services on a discretionary basis. When discretionary authority is granted, ACM is authorized to make investment decisions on behalf of the client without obtaining prior approval for each transaction. Discretionary authority typically includes the ability to determine the securities to be purchased or sold, the amount of securities, the timing of transactions, and the selection of brokers or dealers, unless otherwise directed by the client. Grant of Discretion Discretionary authority is granted by the client through the execution of an investment advisory agreement and, where applicable, through account documentation with the custodian.

Asymmetric Capital Management, LLC (“ACM”) does not vote proxies on behalf of clients. Clients retain responsibility for voting proxies and for responding to other corporate actions related to securities held in their accounts. Proxy materials and related information are sent directly to clients by the custodian or issuer. Clients should contact the custodian directly with questions regarding proxy materials. Corporate Actions ACM does not take action with respect to tender offers, mergers, reorganizations, or other corporate actions. Clients are responsible for making all decisions regarding such matters. Clients may contact ACM for general information; however, ACM does not provide formal proxy voting services.

Asymmetric Capital Management, LLC (“ACM”) does not require or solicit prepayment of advisory fees six months or more in advance and in excess of $1,200. Accordingly, ACM is not required to include a balance sheet. Financial Condition ACM has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Bankruptcy ACM has not been the subject of a bankruptcy petition at any time.