A. Firm and Principal Owners
Heirloom Investment Management LLC (“HIM” or “the Advisor”) is a privately-held investment advisor
founded in 2015. It is a Delaware Limited Liability Corporation, and is owned by Heirloom Holdings, a
Cayman Islands based holding company that also owns Heirloom Investment Management (Cayman)
and Heirloom Investment Fund SPC, a Cayman Islands segregated portfolio company. Together these
entities are known as the Heirloom group of companies. Heirloom Holdings is majority owned by Geoff
Dover, HIM’s President and Chief Investment Officer.
B. Advisory Services
HIM is an investment adviser registered with the SEC under the Investment Advisers Act of 1940
(“Advisers Act”). The terms of such advisory services, including any restrictions on investments in
certain types of securities, are established by the firm, as modified through negotiations with clients,
and as set forth in each client’s advisory or management agreement. Investment guidelines and
restrictions are determined jointly by HIM and each client at the onset of the relationship. Clients can
engage HIM to manage all, or a portion of, their assets on either an advisory or a discretionary basis.
The primary focus of the Advisor is managing the whole portfolio of its clients. All of HIM’s clients are
“accredited investors” as defined under Rule 501 of the Securities
Act of 1933, as amended. As such,
HIM recommends, or directs, its clients to invest in all types of securities, including domestic and
international equity securities, fixed income securities, pooled investment vehicles, managed accounts,
private placements, real estate, currencies, direct loans, commodities, structured products and various
derivative instruments.
C. Tailoring Advisory Services to Individual Needs
HIM tailors its advisory services to the individual needs of its clients, and will only recommend or direct
investments that are consistent with each client’s investment objectives and risk tolerances. The firm
consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and
other factors that may impact the clients’ investment needs. HIM ensures that clients’ investments are
suitable for their investment needs, goals, objectives and risk tolerance. HIM is responsible for
originating and recommending investment opportunities to clients, monitoring, evaluating and making
recommendations regarding timing and manner of disposition of investments and other services as the
clients may reasonably request.
D. Wrap Fee Programs
HIM does not participate in wrap fee programs.
E. Assets Under Management
As at December 2019, HIM has US $115,882,891.00 in regulatory assets under management.