André Luiz Ferreira da Costa - Sole Proprietor (“The Advisor”) is a SEC-registered investment
adviser. The Advisor became a registered investment adviser and commenced active business
operations in 2017. The Advisor is organized as a Sole Proprietorship owned by Mr. André Luiz
Ferreira da Costa who also serves as The Advisor´s designated principal.
The Advisor provides investment advisory services to a variety of alternative investments
assets classes and vehicles, including, but not limited to, separately managed accounts
(“SMAs”), DIGITAL ASSETS and commingled investment vehicles that would be investment
companies as defined in the Investment Company Act of 1940, as amended (the “Investment
Company Act”), but for section 3(c)(1) or 3(c)(7) thereof (collectively, “Private Funds”).
Investment services to clients may be provided on a discretionary or non-discretionary basis.
The types of clients to which each Adviser provides investment management services are
disclosed in the Advisers’ Form ADV Part 1 and summarized in Item 7 (“Types of Clients”) of
this Brochure.
The Advisor generally provides investment management services in accordance with
applicable investment guidelines and restrictions, including applicable restrictions on
investing in certain securities, or types of securities or other financial instruments, that are
developed in consultation with the client. Pooled investment vehicle managed or otherwise
advised by the Advisor is managed in accordance with its investment guidelines and
restrictions and generally is not tailored to the individualized needs of any particular fund
shareholder or fund investor, and an investment in such a vehicle does not, in and of itself,
create an advisory relationship between the shareholder or investor and The Advisor. The
Advisor may use both automated and/or manual processes to manage portfolios in accordance
with their stated portfolio investment guidelines and restrictions.
The current primary focus of The Advisor is to manage assets through SMAs with mandates
that focus on alternative investment strategies and invest in debt and equity instruments
relating to the infrastructure sector, including energy, aviation assets and natural resources
industries. The Advisor may also provide investment advisory services to a variety of alternative
investment vehicles for accredited investors, qualified purchasers, trusts,
U.S. and international
business organizations, private funds and institutional clients with mandates that focus on
hedge funds and managed futures (CTAs), commodities, real assets, DIGITAL ASSETS and
structured products for investment or hedging purposes. The Advisor trading approach
includes a broad range of strategies, including, without limitation, distressed securities,
hedge/arbitrage positions (including event arbitrage, related securities arbitrage, convertible
arbitrage, volatility arbitrage, commodities trading, and fixed income arbitrage), equity-
oriented positions, private equity and private credit positions, currency trading, basis trading,
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portfolio volatility protection positions, parametric approaches, and real estate-related
securities positions. The Advisor generally advises in a wide variety of exchanged traded and
OTC financial instruments, including, without limitation, bonds, cat bonds, swaps, options,
futures, forwards, swaptions, private equity, structured credit products, ILS, DIGITAL ASSETS
and climate derivatives.
The Advisor may use the services of one or more third party service provider or appropriate
personnel for investment advice, portfolio execution and trading, operational support, and
client servicing in their local or regional markets or their areas of special expertise without
specific consent by the client, except to the extent explicitly restricted by the client in or
pursuant to its investment management agreement (“IMA”), or inconsistent with applicable
law. Arrangements may take a variety of forms, including but not limited to dual employee,
delegation, participating affiliate, sub-advisory, sub-agency, or other servicing agreements.
This practice is designed to make The Advisor’s global capabilities available to The Advisor’s
clients in as seamless a manner as practical within a varying global regulatory framework. In
these circumstances, The Advisor remains fully responsible for the account from a legal and
contractual perspective. No additional fees are charged for these services except as set forth in
the IMA.
The Advisor does not offer custody services to its clients.
A PROSPECTIVE INVESTOR SHOULD NOT CONSTRUE THE CONTENTS OF THIS DISCLOSURE
DOCUMENT AS TAX OR LEGAL ADVICE. THIS DISCLOSURE DOCUMENT SHOULD BE REVIEWED BY THE
PROSPECTIVE INVESTOR AND ITS TAX, ACCOUNTING, LEGAL AND OTHER ADVISERS.