Summary
Hunter Lewis LLC (referred to as “we,” “our,” or “us” below) is a privately-owned investment
advisory firm that is registered with the Securities and Exchange Commission (“SEC”) as a
registered investment adviser. Our firm was founded by Hunter Lewis on July 30, 2018, and is
100% owned by the Hunter Lewis 2013 Trust. We became a registered investment adviser in
2019 and opened our doors to outside clients in 2020. We serve endowed institutions, private
clients, families, and pension plans by offering financial and investment advisory services (which
are discussed in more detail in the following pages).
The Firm
Our Philosophy
We believe there are investment principles that stand the test of time. In contrast, investment
strategies must be evaluated and adapted as economic circumstances change.
Hunter Lewis, our founder and Chief Executive Officer, is best known as the co-founder of
Cambridge Associates LLC where over the last four decades he co-invented and further
developed (along with his colleagues and clients, especially Yale) what became known as the
American university investment model, which has been widely emulated around the world.
Despite our founder’s previous history in the investment management industry, we are not
committed to this or any other investment strategy.
Our firm is committed to rethinking, modifying, or if necessary, replacing many of the
investment strategies used in today’s markets – particularly those strategies that have been
very successful in recent years. In rethinking strategies, particular care must be taken to
separate good new ideas from what are essentially fads that may have serious unintended
consequences for investors.
Hunter Lewis’ history in helping to create the American university investment model does not
guarantee that we will be successful in developing or implementing investment strategies for
our clients. We believe, however, that his knowledge and experience, combined with that of our
other employees, will help us to work with our clients to develop and implement investment
strategies and plans that meet our clients’ needs.
We also recognize that no investment is completely safe. Even cash, which many investors think
is free from risk, is subject to inflation and other risks. We will seek to help our clients reduce
their investment risk by constructing diversified investment portfolios, by seeking the best
pricing available for our clients’ securities transactions, and by watching other costs. Although
all investing involves significant risk, we will work with our clients to make sure they understand
the risks of their investments and attempt to minimize those risks wherever we can.
HU N TE R L EW IS LL C FIR M B R OCHU R E | FO RM A DV PA R T 2 A 5
Our approach will combine a broad-based focus on developing a client’s overall investment
strategy with a detail-oriented approach to executing that strategy. We believe that adhering to
proven principles and modifying an investment strategy as needed is likely to be the most
important contributor to investment success over time. Other important components of a
successful investment program are asset allocation, security selection, and (as noted above)
cost control.
More on Our Firm
• Cost-conscious Investing: We believe in watching every penny of investment costs
for our clients in order to keep costs as low as possible. Investment costs may not
appear to have a dramatic impact on a single year’s return, but over time they add up
and may have a tremendous impact on what a client ends up with after many years of
investing. Consequently, we try to keep our fee as low as possible and also to help our
clients keep their total investment costs as low as possible.
• Conflict-averse. Investment advisers are legally required to put the interests of their
clients first. If the interests of an adviser’s clients diverge from its own interests, the
adviser must at a minimum disclose the potential conflict of interest and how it plans to
control the conflict. Our firm believes that conflicts of interest will severely interfere with
our ability to serve our clients to the best of our ability and earn the highest possible
returns for them over the long term. We will strive to avoid conflicts of interest, as
discussed below under One Service, Two Elements and as set forth in our Code of Ethics
(discussed below), where we have developed an internal policy to help us address any
potential conflicts that may arise.
• One Service, Two Elements. In our opinion, if a firm offers several services, and
some are higher priced than others, this creates a potential conflict of interest. If some
services are higher priced than others, it is too easy to justify why a client needs the
higher-priced service or services. Our firm attempts to control this important conflict by
offering clients a single service with two elements. The two elements are: a) an
investment strategy review and/or development of an investment plan and b)
implementation of the plan through investment management. Clients who have received
a plan are not committed to the implementation/management element of the service.
They can instead implement the plan on their own or in some other way. Everything we
do is covered by a single fixed fee. This is further explained below.
• Risk-focused. No asset class is safe. Even cash can melt away from inflation or
negative interest rates or evaporate in a moment of monetary collapse. Contrary to
modern portfolio theory, the risk of catastrophic loss cannot be captured adequately by
a mathematical equation. Fortunately, each asset class has a role to play in protecting
you as well as in growing your portfolio. Risk is part of life and cannot be avoided. We
HU N TE R L EW IS LL C FIR M B R OCHU R E | FO RM A DV PA R T 2 A 6
believe that understanding risk is our clients’ best protection. We will work with each
client to develop a risk management approach that is right for the client and, for our
investment management service clients, implement that approach as well.
• Independence. Our independence is important to us. We are not owned by or
affiliated with banks, brokers, other financial firms, other companies, or a broad group
of public equity holders. In our opinion, this helps us work solely for our clients, without
being pressured to steer our clients’ business to industry affiliates or meet the earnings
expectations of equity holders. We also believe our independence helps us remain long-
term investors, forging our own path for our clients rather than “following the crowd.”
• Long-term Orientation. In our experience, the investment world often speaks of long-
term investment but does not always practice what it preaches. Our philosophy focuses
on creating long-term returns for our clients, and we will manage our client’s portfolio
with this time horizon in mind.
• Global Orientation. We invest all over the world, allowing our clients to access
multiple markets and further diversify their portfolios.
Our Services:
Overview of Our Services
As mentioned above, the first element of our service is a review of investment strategy and/or
development of an investment plan. The second element is implementation of the plan through
investment management. Clients who have received a plan are not committed to the
implementation/management element of the service. In addition, some investors may have to
accumulate assets before management is feasible.
• Investment Strategy. For each category of client (individual, family, endowment, or
pension), we utilize our specialized knowledge of the particular financial challenges of
that category. For example, in working with endowments, we utilize our specialized
knowledge of the finances of universities, foundations, museums, medical centers, arts
organizations, and many other such institutions. Investment plans for all clients will
usually include the following:
o An investment objective (taking into account the client’s financial circumstances
and goals);
o A broad investment strategy;
o An appropriate asset allocation;
o An appropriate investment management plan.
HU N TE R L EW IS LL C FIR M B R OCHU R E | FO RM A DV PA R T 2 A 7
• Investment Management. In addition to developing an investment plan with the
client, we also help implement it, either on a non-discretionary or discretionary basis (as
discussed in more detail below).
Additional Information Regarding Our Client-Specific Investment Plans
In developing a broad investment strategy for our clients, we typically consider:
• The role and use of different asset classes;
• Risk control techniques;
• Management techniques.
We may also consider other collateral issues when establishing a client’s broad investment
strategy, such as:
• Investment committee composition and process;
• Investment fees and costs;
• Leverage at different levels of the portfolio;
• Counter-party risks;
• Tail risks;
• Best practices for investment risk control;
• Risks related to short term liability management.
Asset allocations that we develop for our clients may include a number of diverse asset classes,
including but not limited to the following:
• U.S. marketable equities;
• U.S. marketable fixed income securities;
• global developed marketable equities;
• global developed marketable fixed income securities;
• global emerging market equities;
• global emerging market fixed income securities;
• global “frontier” market equities;
• global “frontier” fixed income securities;
• real estate, including REITs;
• natural resource investments;
• precious metals;
• private investments.
Investment Discretion and Custody
If a client asks us to implement the investment plans that we develop (including an investment
objective, a broad investment strategy, an asset allocation plan, and an investment
management plan), we will implement the plan on either a:
HU N TE R L EW IS LL C FIR M B R OCHU R E | FO RM A DV PA R T 2 A 8
• Non-discretionary basis: we provide investment recommendations; however, the client
ultimately makes its own investment decisions and generally executes its own securities
transactions;
• Discretionary basis: we are granted authority to make investment decisions and to
transact on the client’s behalf without prior authorization from the client.
We do not generally take physical custody of client assets, although we may be deemed to have
custody of certain emerging market investments, and as further discussed below under
“Custody,” we may be deemed to have custody of our client’s assets for certain purposes under
the Investment Advisers Act of 1940.
Additional Features of Our Services
We offer three additional, optional features to our clients at no additional fee:
• Tailoring the portfolio to be consistent with the client’s view of its social “impact” as well
as consistent with an appropriate level of risk;
• Philanthropic advisory services for private clients;
• Assistance in obtaining from third parties other miscellaneous financial or investment
services requested by the client, such as bill paying, bookkeeping, accounting, legal, and
purchasing of non-financial products and services.
By including these optional features within our fee, clients can decide for themselves whether
they want these services without worrying that we are recommending these features in order to
increase our fees. For more information, please see “Fees and Compensation” below.
Regulatory Assets Under Management
As of May 10th, 2024, our discretionary assets under management were $259,300,000.
This figure (rounded to the nearest $100,000) is based on the net asset value of our clients’
securities as reported to us by their respective custodians.
As of May 10, 2024, we did not have any assets under management in a non-discretionary
capacity.
HU N TE R L EW IS LL C FIR M B R OCHU R E | FO RM A DV PA R T 2 A 9