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 (Canada) Inc.,
Heirloom Management Services FZE, Heirloom Litigation Funding 2022 SPV XI (a principal investment
company), and Heirloom Investment Fund SPC (a CIMA registered Fund). HIM owns 100% of the voting
shares of Fidelis Investment Co, Ltd. and Heirloom Helicopter Leasing Pool 2020 LLC. 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”). One of the services that HIM provides is to advise individual clients, their family
offices or their corporations or other holding entities on their investment portfolios. 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 and are reviewed on at least an annual
basis. 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’s advisory services is managing or advising on the whole portfolio of
its clients. All of HIM’s advisory clients are “accredited investors” as defined under Rule 501 of the
Securities Act of 1933, as amended and “qualified purchasers” as defined under Section 2(a)(51) of the
Investment Company Act, 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.
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.
C. Comingled and Pooled Funds
In addition to advising individual asset owners, HIM primary focus is as a discretionary manager to certain
comingled vehicles and pooled funds (“Funds”). These vehicles provide access to either a diversified
portfolio of investments or to a single investment or investment strategy.
All of HIM’s advisory clients are “accredited investors” as defined under Rule 501 of the Securities Act of
1933, as amended and “qualified purchasers” as defined under Section 2(a)(51) of the Investment
Company Act, as amended.
D. Wrap Fee Programs
HIM does not participate in wrap fee programs.
E. Assets Under Management
As of December 2022, HIM had US $117,388,000.00 in regulated assets under management managed on
a discretionary basis in Funds and $209,000,000 in assets on which it advised pursuant to advisory
services that do not qualify as regulated assets under management because HIM does not have discretion
over the manner in which they are invested.