IEQ Capital, LLC (“IEQ” or the “Firm”), a Delaware limited liability company, was founded
in 2019. Since December 2022, the Firm's direct owner is IEQ MidCo III, LLC (“MidCo III”),
a Delaware limited liability company. MidCo III’s direct owner is IEQ MidCo II, LP, a Delaware
limited partnership (“MidCo II”). MidCo II is majority-owned by IEQ MidCo I, LLC, a
Delaware limited liability company and majority-owned subsidiary of IEQ Holdings, LLC. IEQ
is managed by Co-CEOs Eric Harrison, Robert J. Skinner II and Alan Zafran, along with Frank
McFarland, Jeffrey Westsmith, and IEQ’s Executive Team, which includes IEQ’s CCO, CFO
and Chief Client Officer. In January 2023, certain funds managed by Stone Point Capital LLC,
an unrelated third-party investment adviser, acquired minority interests in MidCo II, which
entitle the holder to a non-controlling voting interest in MidCo II, customary minority consent
rights and information rights, and the right to appoint a non-controlling percentage of MidCo
II’s board members. After the transaction, IEQ continues to provide the services and manage
Client Accounts (as defined below) as described herein.
IEQ provides portfolio management and investment advisory services (collectively, “Advisory
Services”) primarily to individuals, high net worth individuals or families, as well as trusts,
foundations, endowments, non-profit organizations and other business entities herein referred
to each as a “Client” and collectively the “Clients”, as described under Investment
Management and Supervisory Services below. As a fiduciary, when providing Advisory
Services IEQ acts in the Clients’ best interest and fulfills its obligation by working closely with
Clients to identify and understand their investment objectives while building a long-term
relationship. In addition, IEQ offers its Clients certain ancillary administrative services
(collectively, the “Ancillary Services”) which are not investment advisory in nature, as
further described under Ancillary Services below.
Investment Management and Supervisory Services
Clients are strongly encouraged to inform IEQ of any life event on a timely basis (e.g., changing
jobs, change in marital status, death) that might impact the advisory services rendered by IEQ.
It is a Client’s responsibility to furnish their IEQ Portfolio Manager and, to the extent
applicable, any Independent Manager (in each case as defined below) with complete, accurate,
and current information about such Client's personal and financial circumstances, goals and
preferences because it will be the basis for the recommendations and advice the Client
receives. Neither IEQ nor any Independent Manager independently verifies the information
that Clients provide. Furthermore, IEQ does not automatically take into consideration other
information that Clients provide or make available to IEQ in connection with their receipt of
any Ancillary Services, or to any Independent Managers. Clients are responsible for furnishing
all information to their IEQ Portfolio Manager that the Client would like IEQ to consider in
formulating its investment recommendations.
IEQ typically will manage client assets in separately managed accounts (each, an “SMA” or a
“Client Account”, collectively, the “SMAs” or the “Client Accounts”). An SMA is a
dedicated account owned by a Client and governed through an investment management
agreement (“IMA”) between the Client(s) and IEQ. IEQ does not participate in a wrap fee
program.
As part of the Advisory Services provided to a Client, IEQ will work with the Client, typically
on a household basis, to develop and tailor a formal Investment Policy Statement (“IPS”) that
reflects such information as, but not limited to, the Client’s financial situation, investment
objectives, liquidity requirements, risk tolerances, and any reasonable investment restrictions
requested by the Client and accepted by IEQ. IEQ typically invests Client assets in stocks,
exchange-traded securities, mutual funds, index funds and alternative private investments, but
also invests in other securities and financial instruments within the capital structure, including
Digital Assets (as defined below). With respect to certain Clients, IEQ will also assist in the
development of 10b5-1 plans.
IEQ could also, and currently does for many Clients, engage one or more third-party sub-
advisers (“Independent Managers”) to manage a portion of client assets on a discretionary
basis if deemed in the best interest of a Client, subject to that Client’s IMA and IPS. Certain
Independent Managers arrangements are “inherited” as a result of the transition of wealth
managers from another investment adviser to IEQ. IEQ also uses some Independent Managers
as an “outsourced Trading Desk” to implement models delivered by other Independent
Managers. IEQ will generally execute a sub-advisory agreement with each Independent
Manager although there might be instances where IEQ could require Clients to sign separate
written agreements directly with those Independent Managers instead of IEQ doing so on a
Client’s behalf. Additionally, Clients could be asked to open new custodian accounts with a
third-party custodian to separate the sub-advised assets from other Client assets advised by
IEQ. Independent Managers will generally have limited power-of-attorney and will have only
trading authority over those assets IEQ directs to them for management. Independent
Managers will be authorized to buy, sell and trade on behalf of a Client’s account and to give
instructions, consistent with their authority, to the relevant broker-dealer and custodian. The
fees charged by the Independent Managers will be disclosed to Clients in the account
statements and applicable fee schedules, and will be in addition to the management fees
charged by IEQ. In addition to management fees, the Client will likely incur transaction and
custodial fees on assets managed by the Independent Manager. IEQ will monitor and review
all such sub-advised accounts on a periodic basis and conduct initial and ongoing investment
and operational due diligence on the Independent Managers. Clients whose assets are
managed by an Independent Manager are encouraged to carefully review such Manager’s Form
ADV and/or other provided disclosure materials for more information about that Manager,
including any applicable conflicts of interest.
Client Investments in Private Funds
Where suitable, IEQ recommends to Clients investments in private pooled investment
vehicles.
These private pooled investment vehicles can take the form of:
1. Access Vehicles
Privately offered fund vehicles (“Access Funds”) formed, sponsored, and
managed by Institutional Capital Network, Inc. (“iCapital”). These Access
Funds aggregate client capital to invest in certain third-party alternative
investment funds sourced and evaluated by IEQ. iCapital and IEQ created a
white labeled platform that IEQ representatives (“Portfolio Managers”) can
utilize to access and allocate client capital to.
IEQ acts as sub-adviser to each Access Fund pursuant to the Sub-advisory
Agreement between the two firms. iCapital receives administrative fees from
each Access Fund on their platform and all fees (including, but not limited to,
tax reporting oversight services fee and a report aggregation fee) are disclosed
in each Fund’s respective private placement memorandum, subscription
documents and/or limited partnership agreements (“Offering Materials”).
IEQ receives compensation for serving as sub-adviser to the Access Funds.
The Access Funds will also charge administrative, audit, legal and other such
allowable expenses pursuant to the Offering Documents. Clients are required
to receive, review, and execute the Offering Materials prior to being accepted
as an investor in any of these Access Funds.
2. Direct Investments
On occasion, IEQ will source, diligence, and recommend Clients to invest
directly in third-party alternative investment funds, single assets opportunities
or co-invest vehicles (“Direct Investments” in “Private Funds”) when it
is determined not practical to form an Access Fund to invest in a specific
opportunity, or if there is insufficient allocation to the alternative fund to
monetarily justify launching an Access Fund. In addition, in limited
circumstances (typically based on an investment size or related to tax status),
IEQ will accommodate a Client’s request to invest directly in a Private Fund
even though an Access Fund is also being formed. Thus, such Clients will
receive the benefit of the due diligence, legal review and negotiation
performed on behalf of, and paid by, the investors in the applicable Access
Fund. Conversely, there could be some unique benefits that will be negotiated
on behalf of an Access Fund which are not extended to direct investors in the
Private Fund (e.g., indemnification).
In instances where underlying fund fee
savings is associated with co-invest capability and such capability is extended
to direct investors, relevant direct investors will be “in the money”
instantaneously as for every dollar committed to a main fund, a dollar will be
contributed to the co-invest vehicle. Access Funds, on the other hand,
typically only commit money to a co-invest vehicle after the required
allocation to the main fund is filled. At other times, however, depending on
the underlying fund’s policies, “fee savings” co-investment opportunities will
not be extended to direct investors.
IEQ will, from time to time, provide a sample of internal investment due diligence memoranda
to Clients or prospective clients for certain funds, if so requested. These reports are provided
to highlight IEQ’s research approach and are redacted to exclude certain confidential and
performance-related information. Clients are encouraged to ask their representatives for
such reports.
Digital Assets
Clients interested in receiving exposure to, and IEQ’s portfolio management diversification
advice with respect to, Digital Assets will need to establish a Digital Asset account through
Fidelity Digital Asset Services, LLC (“FDAS”) and transfer funds into such FDAS account.
IEQ will assist such interested Clients with establishing a digital currency account through the
FDAS platform. “Digital Asset” shall mean a digital asset (also called a “cryptocurrency,”
“virtual currency,” “digital currency,” or “digital commodity”), such as Bitcoin or Ethereum,
which is based on the cryptographic protocol of a computer network that may be (i)
centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange
and/or store of value. The term “Digital Asset” does not include products with indirect
exposure to Digital Assets, including baskets of Securities (e.g., ETFs that include Digital Asset
company securities).
Retirement Plan Services
IEQ engages with retirement plan Clients in a wide range of capacities. For plans subject to
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), this could
include serving as an ERISA Section 3(21) fiduciary providing investment recommendations
to the plan sponsor and/or plan trustee, or as an ERISA Section 3(38) “investment manager”
with discretionary authority to make investment decisions on behalf of the plan. In addition
to allocating plan assets and portfolio management, these services can include assistance in
setting up an Investment Policy Statement for the portfolio, managing cash and liquidity needs,
selecting professional record‐keepers, administrators and custodians, and providing in depth
quarterly or annual review with the portfolio’s performance and our outlook on financial
market conditions.
In addition, IEQ has adopted policies and procedures designed to comply with the ERISA
fiduciary standards when advising retirement asset rollovers as set forth in the Department
of Labor Fiduciary Rule (“DOL PTE Rule”). Clients will be presented with disclosure
documents as prescribed by the DOL PTE Rule.
Donor Advised Fund Services
Some IEQ Clients establish donor advised funds through various third-party charitable
programs including the Fidelity Charitable Gift Fund Program and the Schwab Charitable Fund
(each, a “Charitable Platform”). The funds are managed in accordance with the specific
investment policies and guidelines of the applicable Charitable Platform. Clients will establish
a donor advised account, transfer funds earmarked for charitable donation and recognize a
tax deduction in the year that funds are transferred into an account opened on a Charitable
Platform. The funds remain in such account until the Client designates a charity, an amount
and a date to donate to such charity.
Ancillary Services
In providing the Ancillary Services described below, IEQ is not providing investment advice,
and has no fiduciary obligations and no obligations to independently verify, examine, confirm
or revise information regarding any assets outside of the Client Accounts that are owned by
a Client but not included as assets under management by IEQ (any such assets, “Non-
Advisory Assets”), whether such information is received from the Client or any of the
Client’s third-party service providers. In providing Advisory Services to a Client, IEQ has no
obligation, and should not be expected, to take into account any information regarding Non-
Advisory Assets, or otherwise received in the course of or in connection with providing any
Ancillary Services, including but not limited to the diversification of a Client’s assets in the
aggregate. While IEQ is permitted to consider any Non-Advisory Assets in connection with
the determination of an appropriate asset allocation or investment strategy for a Client’s
Accounts, and indeed does so with respect to many Clients, such consideration does not
extend the advisory relationship to any such Non-Advisory Assets.
Reporting and other Ancillary Services on Non-Advisory Assets
As a service to certain Clients, IEQ offers consolidated reporting, monitoring, and other
ancillary services with respect to Client Non-Advisory Assets. IEQ will report the value of
each Non-Advisory Asset to the Client, based solely on the valuations received by IEQ from
the third-party managers of the Non-Advisory Assets or other third parties, or from the
Client, but IEQ will not have any obligation to independently examine, confirm or revise Non-
Advisory Asset valuations. The scope of a Client’s Non-Advisory Assets and associated
Ancillary Services, and any fees agreed upon by the Client, are memorialized in writing,
whether in separate section(s) of that Client’s IMA or in a separate agreement between the
Client and IEQ.
“Family-Office” Services
IEQ assists certain Clients in addressing their wealth management needs with various family
office services. To this end, IEQ has launched the IEQ Family Office. IEQ Family Office supports
certain clients with select non-investment management services as mutually agreed to by the
client and IEQ from time to time. Certain ancillary services will be provided directly by IEQ
(e.g., global asset analysis and optimization, consolidated reporting and asset tracking, cash
flow analysis and liquidity management, investment tax strategy, wealth transfer and estate
planning analysis and support, charitable giving support, and family dynamics support). With
respect to providing family office services, IEQ does not provide legal, tax, accounting, or
investment advice. Other services are available from independent professional firms (e.g., tax
advisory, trust and estate planning, bill pay etc.). IEQ can help identify, interview, onboard, and
integrate these third-party professionals into the Client’s team. While IEQ maintains a list of
certain such third-party service providers with which IEQ, its personnel, and/or its Clients
have interacted, or otherwise fit certain selection criteria (e.g., size and geographical area) and
whose contact information IEQ provides to Clients to as a courtesy, IEQ is not endorsing any
such independent service provider, and IEQ has no oversight or supervision of, and does not
guarantee the performance of, any independent service provider. IEQ does not charge
additional fees in connection with family office services provided by IEQ, and neither IEQ nor
its employees charge fees or earn any direct compensation in connection any recommendation
to retain a third-party provider. Although an independent professional firm might decide to
refer prospective clients to IEQ on its own accord, IEQ does not solicit such referrals. Any
mutual referral arrangement, whether part of family office services or otherwise, will be made in
accordance with the Marketing Rule (as defined below).
Eligibility and level of participation in this program is largely dependent on a Client’s RAUM or
the annual sum of IEQ’s management fee. A Client who wishes to learn more information
about this program is strongly encouraged to reach out to his/her service team.
In addition to the formal family office services program, IEQ may, from time to time upon a
Client’s request, introduce certain Clients to service providers with which IEQ conducts
business with (e.g., an administrator, a lender). While IEQ does not receive any monetary
compensation as a result of such introductions, it does have a conflict of interest in making
them as the introduction enhances IEQ’s relationships with such third parties.
Assets Under Management (Regulatory Assets Under Management)
As of December 31, 2023, IEQ has total regulatory assets under management of
$23,584,354,606 of which $22,349,886,324 are discretionary and $1,234,468,282 are non-
discretionary regulatory assets under management.