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Lineage Point Capital LP: investment adviser
Lineage Point Capital LP is an investment adviser registered with the SEC (file 801-134454, CRD 338216). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $294.7M
- Discretionary
- 100%
- Accounts
- 1
- Employees
- 3
- In advisory roles
- 2
- Disclosures
- 0
Company page · SEC adviser record · Full Form ADV (PDF)
The firm reports no custody of client cash or securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| Private funds and other pooled vehicles | 1 | $294.7M | 100.0% |
How it is paid
- Fixed fees (other than subscription fees)
- Performance-based fees
- Other: Expense reimbursement
Services
- Portfolio management for pooled investment vehicles (other than investment companies)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Lawrence Michael Hurvich | Person | Limited partner and portfolio manager | C 25% to 50% | Jun 2025 | Yes | |
| Gerasomou Spiro Siliverdes | Person | Limited partner and portfolio manager | C 25% to 50% | Jun 2025 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| Lawrence Michael Hurvich | Lineage Point GP LLC | Person | D 50% to 75% | Yes | |
| Gerasomou Spiro Siliverdes | Lineage Point GP LLC | Person | D 50% to 75% | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
Lineage Point Capital LP_Brochure, filed Mar 4, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
Lineage Point Capital LP (“Lineage”, the “Adviser”, or the “Firm”) was formed in June 2025 as a Delaware limited partnership. The general partner of Lineage is Lineage Point GP LLC (“Lineage GP”), which is wholly owned and controlled by Lawrence Hurvich and Gerasomou Siliverdes (together, the “Members”). Any references to the “Firm”, “us,” “we,” or “our” in this Brochure refer to the Adviser. Lineage provides discretionary sub-advisory services to pooled investment vehicles (“Private Vehicles”) organized as private funds and typically managed on behalf of institutional investors. These Private Vehicles are offered and sponsored by unaffiliated registered investment advisers.
Read the rest of Item 4 (252 more words)
For purposes of this Brochure, each Private Vehicle is considered a “Client.” The Firm offers a specialized investment strategy designed to generate attractive risk-adjusted returns by investing in special purpose acquisition vehicles (“SPACs”) and related securities, including units, common shares, warrants, and rights. SPACs are publicly traded companies formed to raise capital through an initial public offering (“IPO”) for the purpose of acquiring or merging with a private company. These instruments may be acquired through IPO allocations or open market purchases. The strategy focuses on purchasing common shares at a discount to trust value and trading warrants and rights with low volatility. In certain completed SPAC transactions, the Firm may engage in short sales of common shares as a hedge against warrant positions. While the Firm does not currently participate in private investments in public equity (“PIPEs”), it may consider such investments in the future. The Firm does not utilize commodity-based derivatives. The Firm does not participate in wrap fee programs. Lineage tailors its advisory services based on each Client’s investment objectives, restrictions, and guidelines. However, Clients are generally not permitted to impose restrictions on investing in specific instruments or categories, unless otherwise agreed. The Firm’s investment strategy involves certain risks, including market, liquidity, and structural risks associated with SPAC securities. These risks are described in more detail in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. Lineage has registered as a large advisory firm with regulatory assets under management (“RAUM”) of $294,692,000 as of December 31, 2025.
Item 5. Fees and compensation
Lineage charges a fixed monthly management fee and a performance-based performance fee to its Clients. The fixed monthly management fee is payable in arrears and prorated for partial periods. In addition, the Firm receives a fixed amount of monthly Management Draw, which is offset against any performance fees earned. If the Management Draw exceeds the performance fee in a given period, the excess may be carried forward and offset against future performance fees. The amount of these fees and any applicable expense reimbursements is subject to negotiation between Lineage and its Client and is set out in the investment advisory agreement between Lineage and the applicable Client. The performance fees charged by Lineage are discussed in more detail in Item 6 – Performance Based Fees and Side-by-Side Management.
Read the rest of Item 5 (332 more words)
Lineage typically charges a fixed monthly management fee. For certain Clients, the fee may be calculated based on gross notional exposure or other negotiated metrics reflecting the full risk exposure of the account. While the specific fee rate and structure are subject to negotiation, fixed fees may approximate similar economics depending on account size, liquidity, and overall relationship terms. Management fees with respect to Clients are generally payable in arrears and are invoiced to the applicable Client on a monthly basis, unless otherwise agreed in writing. Certain Clients also pay a one-time or initial Set-Up Fee, which include pre-trading monthly payments and onboarding related costs. These fees are negotiated and disclosed in the applicable investment advisory agreement. Other Fees and Expenses Lineage’s Clients will incur other expenses in connection with the Firm’s advisory services. Lineage’s fees do not include transaction fees, brokerage commissions, custody fees and other related costs and expenses that will be incurred by a Client in connection with activity in their account. Clients will also bear the investment management or other fees charged by any mutual funds or ETFs in which the Client’s account may invest, as disclosed in the Client prospectus. Please see Item 12 – Brokerage Practices for a more detailed discussion of Lineage’s brokerage practices. Lineage will render its services to Clients at its own expense and will be responsible for its overhead expenses including office rent; utilities; furniture and fixtures; stationery; secretarial/internal administrative services; salaries and bonuses; entertainment expenses; employee insurance and payroll taxes. However, the Firm is eligible to receive additional reimbursement from a Client for out of pocket investment related expenses, including research, market data, and research-related travel to a negotiated annual cap. It is important that Clients refer to the documents governing their relationship with Lineage for a complete understanding of how the Adviser is compensated for its advisory services. The information contained herein is a summary only and is qualified in its entirety by the relevant documents governing the Client relationship.
Item 6. Performance-based fees and side-by-side management
Lineage is also eligible to receive performance-based compensation from its Clients, as agreed and set out in the investment advisory agreement between Lineage and the applicable Client. Generally, performance-based compensation payable to Lineage with respect to a Client is equal to 20% of the net profits attributable to the Client’s assets (including both realized and unrealized gains and losses) over the applicable measurement period, after recovery of any carryforward losses in prior measurement periods, and subject to variation based on additional performance-related criteria in certain cases and as qualified by the relevant documents governing the applicable Client relationship.
Read the rest of Item 6 (228 more words)
Performance-based fees are generally accrued monthly and paid at the end of each performance period, which may be annual or upon termination, unless otherwise agreed with a particular Client. Conflicts of Interest Related to Performance-Based Compensation
A significant percentage of the appreciation (if any) that would otherwise be allocated to Clients is paid to Lineage as performance-based fees or allocations. This performance-based compensation is based upon unrealized, as well as realized, gains, and such unrealized gains may never be recognized by the Client. Performance-based compensation may create an incentive for Lineage or its advisory affiliates to make investments that are riskier or more speculative than they might otherwise select. The amount of performance-based compensation (if any) that Lineage receives from a Client is expected to vary among the various Client accounts. This results in a potential conflict of interest, as it could provide Lineage with an incentive to favor the Clients from which Lineage receives substantial performance-based compensation over Clients from which Lineage receives only asset-based management fees, or a lesser amount of performance-based compensation. For example, seeking to allocate more profitable investment opportunities to the Clients for which Lineage receives greater amounts of performancebased compensation. However, Lineage generally intends to trade and invest in liquid, exchange-traded products, and uses an equitable allocation methodology when aggregating orders across Clients. See Item 12 – Brokerage Practices for more information.
Item 7. Types of clients
Lineage offers discretionary sub-advisory services to Private Vehicles, each of which are offered and sponsored by an unaffiliated registered investment adviser. Clients are generally subject to a minimum initial investment, unless such minimum is waived by Lineage in its sole discretion.
Item 8. Methods of analysis, investment strategies and risk of loss
All references to Clients in this Brochure, including, but not limited to, their investments and management strategies, are qualified in their entirety by reference to each Client’s respective investment advisory agreement. The following is a general discussion of the methods of analysis; investment strategies and the risk of loss associated with Lineage’s overall investment strategy. These risk factors may change over time. There can be no assurance that any Client will achieve its objectives or that it will not incur losses. Investors must be prepared to lose all or substantially all of their investment. Lineage’s investment strategy is focused on securities issued by SPACs and related instruments, including common shares, warrants, rights, and units.
Read the rest of Item 8 (3,738 more words)
These securities may be acquired through IPO allocations or open market purchases. The Firm may also engage in short sales of SPAC common shares as a hedge against warrant positions in completed deals. The investment strategy employed by the Firm involves significant risks. Investors must be prepared to bear the loss of their entire investment. The following summary of certain risks does not purport to be complete but includes some of the potential risks generally associated with Lineage’s investment strategy. SPAC-Specific Risks The Firm invests in SPACs, which are companies that may be unseasoned and lack trading or operational history, a track record of reporting to investors, and widely available research coverage; SPACs may be purchased through IPOs, which are often subject to extreme price volatility and speculative trading, and because SPACs have no operating history or ongoing business other than seeking acquisitions, the value of their securities is particularly dependent on the ability of the entity’s management to identify and
complete a profitable acquisition. There is no guarantee that the SPACs in which the Fund invests will complete an acquisition or that any acquisitions that are completed will be profitable. Investments in SPACs and SPAC-related securities involve unique risks, including deal uncertainty, dilution from warrants and rights, sponsor incentives that may not align with shareholder interests, and postmerger volatility. SPAC securities may trade at a discount or premium to trust value, and liquidity may vary significantly. The performance of SPAC securities may be adversely affected by failed mergers, regulatory scrutiny, or market sentiment. PIPE Transaction Risks While Lineage may evaluate participation in PIPEs as part of its broader investment universe, such investments are currently prohibited and are not part of the active strategy. Any future participation in PIPEs would require prior written consent from the Client and an amendment to the Investment Guidelines. General Economic and Market Conditions The success of Lineage’s investment activities may be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, climate change, local epidemics, global pandemics, national and international political circumstances (including wars, terrorist acts, and security operations), and changes in laws that could have a negative impact on the national, regional or global economy and business activity in any of the countries in which any Client may invest. These factors may adversely affect the performance of such Client’s investments. These factors may affect the level and volatility of securities prices and the liquidity of the Client’s investments. Unexpected volatility or illiquidity could impair the Client’s profitability or result in losses. Limited Operating History Lineage has a limited operating history. There can be no assurance that the Firm or its Clients will achieve their investment objectives. Any past performance of Lineage or its respective affiliates or other investment vehicles managed by any of them is not necessarily indicative of the future results of an investment with Lineage and should not be construed as an indication of the future results of any Client. Dependence Upon the Firm and the Portfolio Manager The Firm’s success may depend on the management of Lineage and on the skill and acumen of the Portfolio Manager. If the Portfolio Manager were to die, become incompetent or disabled or otherwise cease to participate in the Firm’s business, the Firm’s ability to select attractive investments and manage its portfolio could be severely impaired. Clients should be aware that they will not have the right to participate in the management of the Firm or the selection of its investments or strategies. By investing with Lineage, Clients are entrusting full discretion over investment decisions to the Firm. General Investment and Trading Risks All financial instrument investments present a risk of loss of capital. Such investments are subject to investment-specific price fluctuations as well as to macroeconomic, market and industry-specific conditions, including, but not limited to, national and international economic conditions, domestic and
international financial policies and performance, conditions affecting particular investments such as the financial viability, sales and product lines of corporate issuers, national and international politics and governmental events, and changes in income tax laws. No guarantee or representation is made that any Client’s investment program will be successful. The market price of financial instruments owned by the Client may go up or down, sometimes unpredictably. Limited Diversification Client portfolios may not be as diversified as other investment vehicles. Because Lineage may concentrate a Client’s investments in a limited number of industries or issuers and/or strategies, the Client’s performance may become more susceptible than a diversified portfolio to fluctuations in value or loss resulting from adverse economic or business conditions that affect those industries, issuers, or strategies. Accordingly, investors should expect that Client performance may be subject to high volatility. Turnover The capital of the Firm’s Clients may be invested on the basis of short-term market considerations. The portfolio turnover rate of those investments may be significant, potentially involving substantial brokerage commissions, mark-ups, and fees. These commissions and fees will reduce the Client’s profits. Market Risks and Illiquid Securities The Firm’s success may depend in part on the ability to correctly predict future price movements of various securities. There can be no assurance that the Firm will accurately predict such movements. While Lineage generally invests in liquid, exchange-traded securities, certain instruments, such as SPAC warrants or post-merger equities, may experience periods of reduced liquidity due to market conditions or issuer specific developments. This lack of liquidity, may adversely affect the Firm’s ability to execute trade orders at desired prices in rapidly moving markets. Increased Governmental and Regulatory Scrutiny; Litigation and Regulatory Risks. Governmental scrutiny of the financial services industry has increased significantly in recent years. Routine and targeted examinations of investment managers have increased and regulators have become increasingly willing to commence investigations and bring enforcement actions against industry participants. Responding to examinations, investigations, or enforcement actions is both time-consuming and expensive, and may divert the time and effort of the Firm’s senior management from managing Clients. In addition, the initiation of a lawsuit or regulatory proceeding involving a Client or the Firm, regardless of the eventual outcome, could adversely affect the reputation of both parties, and could result in the imposition of penalties or restrict the Firm’s ability to conduct business or a Client’s ability to offer interests in jurisdictions with so-called “bad actor” laws. The extent of the Firm’s and its Clients’ exposure to legal and regulatory matters is unpredictable. Equity Securities The Firm may trade in equity securities. Common stock and similar equity securities generally represent the most junior position in an issuer’s capital structure and, as such, generally entitle holders to an interest in the assets of the issuer, if any, remaining after all more senior claims to such assets have been satisfied. Holders of common stock generally are entitled to dividends only if and to the extent declared by the
governing body of the issuer out of income or other assets available after making interest, dividend, or any other required payments on more senior securities of the issuer. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic conditions. The Firm may acquire long and short positions in listed common equities of issuers domiciled in developed countries. The Firm may invest in equity securities regardless of market capitalization, including micro- and small-cap companies. The securities of smaller companies may involve more risk and their prices may be subject to greater volatility than those of larger, more established companies. Impact of Russia-Ukraine Conflict The European and global financial markets have experienced significant volatility and adverse trends due to concerns about acts of aggression in the region and related sanctions. These events may impact other countries in Europe and may affect the value of Client investments. On February 24, 2022, Russia launched a large-scale invasion of Ukraine. Following Russia’s invasion, various countries, including the U.S., Canada, the United Kingdom, Germany and France, as well as the European Union, issued broad-ranging economic sanctions against Russia and its high-ranking officials. As a result of the economic sanctions and the suspension of trading on the Moscow stock exchange, nonRussian investors may be prohibited or otherwise face difficulty in trading certain Russian securities and doing business with certain Russian corporate entities, financial institutions, officials and oligarchs (whose assets may be frozen). The sanctions include a commitment by certain countries and the European Union to remove selected Russian banks from the Society for Worldwide Interbank Financial Telecommunications, commonly known as “SWIFT,” which is the electronic network that connects banks globally. A large number of corporations and U.S. states have announced plans to divest interests or otherwise curtail business dealings with certain Russian businesses. The scope and severity of the sanctions are likely to evolve as the conflict continues. The conflict between Russia and Ukraine is currently unpredictable and has the potential to result in broadened military action. The extent and duration of the military action and resulting sanctions or future market disruptions in the region are impossible to anticipate, but could have significant negative effects on the region, the global economy, and markets for certain securities and commodities (such as oil, natural gas, and industrial minerals). These risks may result in increased market volatility, reduced liquidity, and losses in affected investments. While Lineage does not currently invest in Russian securities, broader market disruptions may indirectly affect the value of Client investments. Inflation Risk In 2022 and 2023, in light of increasing inflation, the U.S. Federal Reserve (the “Fed”) increased interest rates multiple times. Although interest rates decreased modestly in the latter half of 2023, inflation is still a concern and the Fed could raise interest rates again because of the current robust economy, which could create downward pressure on the value of certain investments held in Client portfolios. Further, the Firm may face difficulty in realizing value from investments due to sustained declines in equity market values driven by ongoing interest rate volatility. Inflation and rapid fluctuations in inflation rates have in the past had, and may in the future have, negative effects on economies and financial markets. In an attempt to stabilize inflation, governments have imposed wage and price controls and may intervene in the economy. Governmental efforts to curb inflation often have negative effects on the
level of economic activity. If inflation were to decrease at rates slower than those anticipated in underwriting investments, the effective rate of return on such investments may be reduced which could materially and adversely affect the performance of Client investments. Material Non-Public Information The Firm and its employees may come into possession of material non-public information in the ordinary course of operations. The purchase and sale of securities, or providing advice with respect to the purchase or sale, while possessing material non-public information, or “inside information,” relating to such securities, whether obtained in the course of research activities, through a Client relationship or otherwise and the communication of such information to others, is prohibited by state and federal law and is strictly prohibited by the Firm. The Firm has adopted an Insider Trading Policy as part of its policies and procedures to mitigate the misuse of such information. Cybersecurity Risks As part of its business, Lineage processes, stores, and transmits large amounts of electronic information, including information relating to the transactions of its Clients. Similarly, service providers of the Firm, especially its administrator, may process, store, and transmit such information. With dependence on computer systems to perform business and operational functions, the Firm and its Clients may be prone to operational and information security risks resulting from cyber-attacks and/or technological malfunctions. In general, cyber-attacks are deliberate, but unintentional events may have similar effects. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacturing or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to Lineage may be susceptible to compromise, leading to a breach of Lineage’s network. Lineage and its Clients rely on third-party service providers for many of their day-to-day operations and may be subject to the risk that the protections and protocols implemented by those service providers will be ineffective in preventing cyber-attacks or data breaches. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to Client transactions and personally identifiable information of investors may be lost or improperly accessed, used, or disclosed. The loss or improper access, use, or disclosure of Lineage’s or a Client’s proprietary information may cause Lineage or Clients to suffer, among other things, financial loss, disruption of business operations, liability to third parties, regulatory intervention, or reputational damage. Any of the foregoing events could have a material adverse effect on Lineage and its Clients. Conflicts of Interest Although Lineage will attempt to resolve such conflicts in a fair and equitable manner, there can be no assurance that these conflicts will be resolved to the benefit of the Client. The Firm may take on additional clients in the future that may create additional conflicts of interest with the current Clients. These may include allocation of investment opportunities, differing fee arrangements, or varying levels of performance-based compensation.
Social-Media-Related Trading Volatility Several stocks and other assets have recently been targeted for trading by participants on social media platforms. Recent changes to market structures and the low cost of trading for retail clients may exacerbate the volume of trading related to social media attention. This volume may be significant and may result in dislocations of prices, which may be difficult for Lineage to accurately predict. SPAC securities, in particular, may be subject to heighted volatility due to social media driven sentiment. It is possible that Congress and regulators may react to the volatility relating to social-media-related trading and restrict, or require the public reporting of, the ability to achieve Lineage’s trading objectives. Short Selling Risk Lineage’s investment program includes short selling. Short selling transactions expose the Clients to the risk of loss in an amount greater than their initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed on behalf of the Clients by Lineage in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein Lineage might be compelled, at the most disadvantageous time, to replace the borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. Short selling may be used to hedge SPAC warrant positions or express views on post-merger equity performance, which may amplify exposure to market dislocations. Fluctuations of Securities The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and "growth" stocks can react differently from "value" stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse longterm effects on world economies and markets generally. SPAC securities may be particularly sensitive to market sentiment and deal related news, which can result in rapid price movements. Epidemics, Pandemics and Covid-19 Risks Epidemics, pandemics and other widespread public health problems could adversely affect the performance of the Client. As the potential impact on global markets from COVID-19, or future epidemics, pandemics or other health crisis, is impossible to predict, the extent to which any such crisis may negatively affect Client performance, or the duration of any potential business disruption, is uncertain. Precautions or restrictions imposed by governmental authorities and public health departments related to this pandemic resulted in periods of decreased economic activity throughout the U.S. and globally, including reduced or ceased business operations, decline in international trade and shortages of supplies, goods and services. An outbreak such as COVID-19, and the reactions to such an outbreak, caused uncertainty in the markets and businesses and adversely affected the performance of the U.S. and global
economy, including due to market volatility, market and business uncertainty and closures, supply chain and travel interruptions, the need for employees to work at external locations and extensive medical absences among the workforce. Business Continuity Various force majeure events, including natural disasters such as fire, flood or earthquakes, wars, terrorist acts, outbreaks of infectious disease, epidemics, pandemics or other serious public health concerns, cyberattacks, technology and/or power failures, labor strikes, or geopolitical or other extraordinary, or other unforeseen circumstances or events, may materially disrupt the Firm’s business and operations, or the business and operations of any counterparty or service provider to the Firm or the Client, and the Firm and/or the Client may be adversely affected thereby. For example, if some or all of the management team were to be unavailable in a force majeure event (including but not limited to, events such as war, terror attack or an outbreak of infectious disease), the Firm’s ability to effectively conduct the Client’s business could be severely compromised. In addition, the cost to the Client, the Firm or its affiliates of repairing or replacing damaged assets or systems resulting from such force majeure event could be considerable. While the Firm has adopted certain policies and procedures designed to restore and/or continue its business and operations in such situations, there is no guarantee that such policies and procedures will be effective in any of such situations or will be implemented in time, and the Clients may be adversely affected thereby. Reliance on Fundamental Analysis Lineage’s investment strategy is based, in whole or in part, on fundamental analysis. Fundamental investment programs consider many factors, such as inflation, trade balances, inventories and interest rates, which do not have an impact on traditional technical trading systems, in an attempt to identify investment opportunities. To the extent that such factors provide mixed or conflicting signals, a fundamental investment program may not be able to detect and/or accurately predict price trends. There can be no guarantee that the fundamental investment program utilized by Lineage will enable it to accurately value the financial instruments in which Lineage invests on behalf of its Clients or that any anticipated price trends will materialize with respect to such investments. A portion of Lineage’s investments for its Clients may involve purchases or sales of equity interests of companies that Lineage believes are mispriced because of an extraordinary event, or that are expected to undergo a change in value because of an expected occurrence. This may include companies that are involved in (or are the target of) mergers, acquisitions or tender offers, work-outs, liquidations, spin-offs, reorganizations, bankruptcies and similar transactions. In any investment opportunity involving any such special event, there may be substantial uncertainty concerning the outcome of such events, and attempting to identify and make investments based on the outcome of such events generally entails a high degree of risk. Accordingly, there can be no assurance that Lineage will correctly evaluate the likelihood of a favorable investment outcome in connection with such events, which could result in substantial losses to Cs. Effectiveness of Risk Reduction Techniques Lineage employs various risk reduction and hedging strategies designed to manage and minimize the risk of its investment positions. A substantial risk remains, nonetheless, that such strategies will not always be possible to implement and when possible, will not always be effective in limiting losses. If Lineage analyzes market conditions incorrectly, or employs a risk reduction strategy that does not function as expected, such risk reduction techniques could result in a loss, regardless of whether the intent was to reduce risk
or increase return. These risk reduction techniques may also increase the volatility of Clients and/or result in a loss if the counterparty to the transaction does not perform as promised. Leverage The low margin and collateral deposits required to trade many exchange-traded derivatives may permit an extremely high degree of leverage. In addition, Lineage may utilize broker-provided margin arrangements in its trading on behalf of Clients. The degree of leverage that Lineage may utilize may not be limited to any predetermined level, but will be subject to applicable legal, regulatory or broker imposed leverage limitations, to the extent applicable. As a result of trading with leverage, a relatively small price movement in a financial instrument’s price may result in immediate and substantial losses to Clients. Thus, like other leveraged investments, any trade may result in losses in excess of the amount invested. Clients may lose more than their initial margin deposit on a leveraged trade. In addition, if a Client is in a leveraged position, any losses would be more pronounced than if leverage were not used and, under particularly adverse circumstances, could exceed the Client’s capital under Lineage’s management. Should financial instruments purchased for Clients on margin decline in value, the Client could be subject to a “margin call” or other collateral call, pursuant to which the Client must either deposit additional funds or assets in its account or suffer mandatory liquidation of the relevant financial instruments. In the event of a sudden precipitous drop in the value of a Client’s assets, Lineage might not be able to liquidate assets quickly enough to cover a margin call or other collateral call. INVESTING INVOLVES RISK OF LOSS THAT INVESTORS SHOULD BE PREPARED TO BEAR. LINEAGE DOES NOT REPRESENT OR GUARANTEE THAT ITS SERVICES OR METHODS OF ANALYSIS CAN OR WILL PREDICT FUTURE RESULTS, SUCCESSFULLY IDENTIFY MARKET TOPS OR BOTTOMS, OR INSULATE CLIENTS FROM LOSSES DUE TO MARKET CORRECTIONS OR DECLINES. LINEAGE CANNOT OFFER ANY GUARANTEES OR PROMISES THAT FINANCIAL GOALS AND OBJECTIVES WILL BE MET. PAST PERFORMANCE IS NOT AN INDICATION OF FUTURE PERFORMANCE.
Item 9. Disciplinary information
Lineage is required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client’s evaluation of the Firm’s management and personnel. Lineage has not been subject to any legal or disciplinary events that are material to a Client’s evaluation of the Firm, its personnel, or its integrity.
Item 10. Other financial industry activities and affiliations
Lineage nor any of its supervised persons are registered or applying to register as a broker-dealer or a representative of any broker-dealer, a futures commission merchant, commodity pool operator, commodity trading advisor, or associated person of the foregoing entities. To the extent a Client trades or is deemed to trade in commodity interests, Lineage will seek to maintain certain exemptions from registration with the U.S. Commodity Futures Trading Commission as a commodity pool operator or commodity trading advisor, as applicable, with respect to such Clients. The Adviser, its affiliates and its officers, directors, and employees may become aware of, and participate in, business opportunities and investments in which Clients will not be given an opportunity to participate. The Adviser will use its best efforts in connection with the purposes and objectives of each Client and will
Read the rest of Item 10 (152 more words)
devote as much of their business time and effort to the affairs of each Client as may, in their judgment, be necessary to accomplish the investment objectives of the Client. Affiliated persons may conduct other business activities, including any business within the securities industry, whether or not such business is in competition with a Client. Without limiting the generality of the foregoing, the Adviser or its affiliated persons may act as the investment adviser for others, may manage funds or capital for others, may have, make and maintain investments in their own name or through other entities, and may serve as officers, directors, consultants, partners or stockholders of one or more investment funds, partnerships, securities firms or advisory firms. It may not always be possible or consistent with the investment objectives of Clients for the same investment positions to be taken or liquidated at the same time or at the same price.
Item 11. Code of ethics, participation in client transactions and personal trading
Code of Ethics Lineage has adopted a Code of Ethics (“Code”) for all supervised persons of the Firm 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, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, policies and procedures relating to expert networks, and personal securities trading procedures, among other things. All supervised persons of Lineage must acknowledge the terms of the Code annually, or as materially amended.
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Lineage’s Clients or prospective clients may request a copy of Lineage’s Code by emailing Lineage at info@lineagepoint.com. Personal Trading Lineage manages the potential conflicts of interest inherent in supervised person personal trading by rigorous enforcement of its Code, which contains significant limitations on supervised persons’ personal investment activities, including pre-clearance requirements and reporting guidelines. Lineage receives transaction and holdings reports in accordance with Rule 204A-1 under the Investment Advisers Act of 1940, as amended (“Advisers Act”) which are reviewed by the Chief Compliance Officer (“CCO”) or their designee to ensure each supervised person is conducting his or her personal securities transactions in a manner that is consistent with the Code. Supervised persons generally are prohibited from personal trading in publicly-traded “reportable securities” that comprise the investable universe of the Firm’s Clients. However, if upon hire, a supervised person holds any such reportable securities (“legacy positions”), the supervised person may retain them indefinitely or, subject to pre-approval by the CCO (or their designee), close any such legacy positions, but may not make new investments in such securities without CCO approval while they are supervised persons of Lineage. Lineage’s supervised persons may also purchase and sell a narrowly defined universe of instruments (e.g., mutual funds, money market funds, certificates of deposit, Treasury securities, open-end funds, exchange-traded funds and municipal bonds) without pre-clearance and private investments with pre-clearance. Some Lineage Clients may invest in the same or similar mutual funds and exchange-traded funds that supervised persons may permissibly invest in under the Code. Notwithstanding the restrictions on trading reportable securities as described above, a supervised person may have an account which trades in such securities if (a) the employee delegates to a professional investment adviser full investment discretion over the account, (b) the employee confirms that he or she
will not exercise investment discretion over the account or directly or indirectly influence any investment decisions for the account, and (c) such professional investment adviser confirms that he or she will independently manage the account, as any such account is not subject to the reporting requirements of Rule 204A-1 under the Advisers Act. Supervised persons may trade in other securities, including for example single-name investments, if they receive specific advance clearance of a proposed trade from the CCO. Participation or Interest in Client Transactions As a matter of policy, Lineage does not cause Clients to effect transactions in which such Client purchases securities or derivatives from, or sells securities or derivatives to, Lineage or its principals or affiliates (i.e., principal trades), or in which one of Lineage’s affiliates acts as broker for both the Client’s account and the other party to the transaction (i.e., agency cross transactions). Unless otherwise agreed with a Client, and subject to applicable law, Lineage may effect transactions between two of its Clients (i.e., cross trades), either directly or through open-market transactions, where Lineage believes that such transaction is in the best interests of both participating Clients. Effecting cross trades may increase brokerage commissions and may result in certain Clients holding less of a profitable investment, or more of an unprofitable investment, than would be the case if there were no cross trades.
Item 12. Brokerage practices
With respect to Clients, unless otherwise agreed between Lineage and a particular Client, the Client will generally select the brokerage firm that will serve as custodian for the Client and handle clearing and settlement of trades. However, Lineage generally selects the brokers that will execute trades and negotiates the commission rates and other transaction costs to be paid by the Client. The Firm recognizes its duty to obtain “best execution.” Consistent with such duty, in determining best execution, the Firm considers the full range and quality of a broker-dealer’s services, including such factors as the financial stability and reputation of brokerage firms, and the brokerage or other services provided by such brokers.
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The Firm does not select broker-dealers solely based on the lowest possible commission costs, but on the best qualitative execution and overall value. Moreover, the Firm does not measure best execution by the circumstances surrounding a single transaction but measures best execution instead over time. Consistent with such policy, consideration is given to a variety of factors, including, but not limited to, one or more of the following:
attention to the Adviser’s account willingness to commit capital for trades ability to source or provide liquidity broker’s creditworthiness broker’s ability to maintain confidentiality cost of execution trading products/execution expertise access to market information providing investment ideas brokers’ efficiency in booking and settling trades ability of broker to provide access to multiple markets and venues
Although the Firm will make a good faith determination that the amount of any commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable (i.e., Clients may “pay up” for research and other services provided by the broker through the commission rate (“soft dollars”)). The receipt of such products or services and the determination of the appropriate allocation in the case of “mixed use” products or services (described below) create a potential conflict of interest between the Firm and its Clients. Except for services that would be a Client expense or as otherwise described herein, the Firm will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning of the safe harbor in section 28(e) of the Securities Exchange Act of 1934. In some instances, the Firm may receive a product or service that may be used only partially for functions within Section 28(e) (i.e., an order management system, trade analytical software or proxy services). In such instances, the Firm will make a good faith effort to determine the relative proportion of the product or service used to assist the Adviser in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting the Firm in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by Client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by the Firm from its own resources or borne by the Client as an expense where allowable. Research and brokerage services obtained by the use of commissions arising from Clients’ portfolio transactions may be used by the Firm in its other investment activities and thus, Clients may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. The Firm has no obligation to deal with any particular broker or dealer in executing transactions and does not have any directed brokerage arrangements. The Firm periodically reviews brokerage and soft dollar arrangements. Allocation and Aggregation of Investments Lineage’s duty of loyalty to one Client may potentially conflict with its duty of loyalty to another, particularly with respect to allocations of investments. In order to mitigate this inherent potential conflict of interest among Clients, Lineage has adopted a policy to provide equitable and fair treatment to all Clients consistent with Lineage’s duty of loyalty. In particular, investments may not be allocated to one Client over another in order to, among other things: (i) favor one Client at the expense of another; (ii) generate higher fees paid by one Client over another, or produce greater performance compensation; (iii) develop a relationship with an investor or prospective investor or client; (iv) compensate an investor for past services or benefits rendered to Lineage, or induce future services or benefits to be rendered to Lineage; or (v) equalize performance among different Clients, or for any other similar reason. In the event Lineage determines to buy or sell the same security on behalf of more than one Client, Lineage may (but is not required to) place an aggregate order (in accordance with trade guidelines, as applicable) with the broker on behalf of all such accounts in order to ensure fairness for all accounts. It is Lineage’s policy, when purchasing securities for more than one of its Clients (i.e., bunching orders), to purchase the
quantity of such securities necessary to supply all Clients and to then average the aggregate costs over all securities purchased. Related benefits to such Clients also will be averaged over the securities purchased. In some circumstances, it may be appropriate for Lineage to buy or sell a security on behalf of more than one Client over a period of time. For example, if Lineage is buying a small capitalization and/or relatively illiquid security for more than one Client, Lineage may wish to fill the order over a period of days or even weeks. In such instances, although it may not be possible to aggregate orders to be entered for all Clients, Lineage still must allocate Clients’ orders pursuant to the allocation guidelines (as applicable). However, in the event that Lineage determines a need to buy or sell a security on behalf of more than one Client over a period of time, there can be no assurance of equality of treatment among all Clients. Trade Errors Trade errors involving transactions effected by Lineage on behalf of its Clients may occur. Lineage will use reasonable efforts to detect such errors prior to settlement and promptly correct them. Trade errors may result in losses or gains. Unless otherwise agreed with a particular Client, losses caused by trade errors committed by Lineage will ordinarily be borne by Clients, except for losses caused by Lineage’s bad faith or gross negligence, which losses would then be borne by Lineage. To the extent a trade error is caused by a counterparty, such as a broker-dealer, Lineage will use reasonable efforts to recover any losses associated with such error from the counterparty. Any gains resulting from such errors will be retained by the affected Client(s). The evaluation of the standard of care exercised in committing a trade error will be performed by Lineage, in its sole discretion, and may be conflicted in making such a determination.
Item 13. Review of accounts
Clients are reviewed on an ongoing basis for conformity with the investment objectives and guidelines set forth in the respective advisory agreements. This review is conducted by the Chief Investment Officer. End investors of separate accounts advised by Lineage will receive all brokerage confirmations and periodic statements with respect to their accounts directly from the account custodian(s). Each investor will also receive reports from Lineage with respect to their Client in accordance with the terms of the applicable advisory agreement.
Item 14. Client referrals and other compensation
Lineage currently has no arrangements whereby it receives an economic benefit from any person who is not a Client for providing investment advice or other advisory services to its Clients, and does not directly or indirectly compensate any third-parties for Client referrals.
Item 15. Custody
Lineage does not have custody of the funds and securities of Clients. Clients should receive at least quarterly statements from the custodian that holds and maintains their Client. Lineage urges each Client to carefully review such statements and compare them to any reports provided by the Firm. Any reports provided by Lineage may vary from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities or other instruments.
Item 16. Investment discretion
Lineage exercises discretionary authority over the accounts of its Clients. Lineage generally receives discretionary authority from the Client at the outset of an advisory relationship, through an investment advisory or similar agreement. These agreements grant the Firm authority to determine the securities to be bought or sold, the amount, and the timing of transactions on behalf of its Clients. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular Client’s account.
Item 17. Voting client securities
To the extent that Lineage has discretion to vote the proxies of the Client and has a reason to vote, the Firm will vote (or abstain from voting) any such proxies in the best interests of its Clients. Prior to voting any proxies and, if applicable, the Firm’s CCO (or their designee) will identify any potential material conflicts of interest related to the proxy in question. If a material conflict is identified, the CCO (or their designee) will then decide (which may be in consultation with outside legal counsel) as to whether the conflict is material or not. If no material conflict is identified, the Firm will make a decision on how to vote the proxy in question.
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Clients may obtain a copy of the Firm’s complete proxy voting policies and procedures and information about how the Firm voted any proxies on behalf of such Client by contacting the Firm by emailing Lineage at info@lineagepoint.com.
Item 18. Financial information
Lineage is required to provide Clients with certain financial information or disclosures about its financial condition. Lineage has no financial condition that would reasonably be expected to impair its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy petition at any time during the past ten years.
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.