A. Description of the Investment Adviser and Identification of Principal Owners. The Investment Adviser was founded on January 8, 2018. Additional information about the Investment Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by using the Investment Adviser’s CRD number, #305091. The SEC’s website also provides information about any persons affiliated with the Investment Adviser who are registered, or are required to be registered, as investment adviser representatives of the Investment Adviser.
The Investment Adviser is a privately held company that is a wholly owned subsidiary of Delphia Holdings Corp.
(“DHC”). Headquartered in Toronto, Ontario, Canada, the Investment Adviser is registered with the Securities Exchange Commission as an investment adviser. Information about the Investment Adviser’s organizational and ownership structure is provided on Part 1 of the Investment Adviser’s Form ADV, which is available online at http://www.adviserinfo.sec.gov. B. Description of Advisory Services. The Investment Adviser has two distinct lines of business: Institutional Asset Management services and Retail Wrap Fee services.
Retail Wrap Fee Services: Please refer to the Wrap Fee Brochure (described below) for details on the Investment Adviser’s Retail Wrap Fee services.
Institutional Asset Management Services: Please refer to this document for a description of the Investment Adviser’s Institutional Asset Management services.
The Investment Adviser’s institutional asset management business currently runs two strategies: a long / short strategy and a long-biased strategy. The Investment Adviser implements its strategies through the following investment vehicles and portfolios.
Private Pooled Investment Vehicles. The Investment Adviser serves as the investment manager with discretionary trading authority to United States and Cayman-domiciled private pooled investment vehicles, the securities of which are offered to Fund Investors (as defined below) on a private placement basis (each, a “Fund” and collectively, the “Funds”). The Funds advised by the Investment Adviser currently include: i.Delphia US Fund LP (the “US Feeder Fund”), a private investment fund organized as a Delaware Limited Partnership, ii. Delphia Cayman Master Fund LP (the “Long Short Fund”), a private investment fund organized as a Cayman Limited Partnership; and iii. Delphia US Long Biased Cayman MasterFund LP (the “USLB Fund”), a private investment fund organized as a Cayman Limited Partnership.
Other feeder funds that are not advised by the Investment Adviser also invest in the USLB Fund and the Long Short Fund. The US Feeder Fund will only be sold to investors who are “accredited investors” or “qualified purchaser” (each a “Fund Investor”).
ADV Part 2A–Firm BrochureMarch 31, 2023Page 4 of 25 Separately Managed Accounts. The Investment Adviser anticipates that it will provide investment advisory services to separate managed account clients (“SMAs” and together with the Funds, “Clients”).
A number of investment professionals employed by the Investment Adviser or its affiliates assist with the execution of the investment strategies. Investment decisions for each Fund are guided and controlled by the stated investment objectives set forth in its offering documents and/or advisory agreements.
The principal objective for the Clients is to generate attractive, risk-adjusted returns through the deployment of Delphia Asset Management Inc.’s (“Delphia AM”) suite of artificial intelligence (“AI”) tools that corroborate and calibrate publicly available data that impacts companies, brands, and sectors across the globe. The Investment Adviser utilizes these AI tools in its services to Clients and believes the AI tools will better inform its investment advisory services.
The Investment Adviser seeks to generate attractive, risk-adjusted returns using a machine learning (“ML”) framework that corroborates and calibrates a plethora of publicly and commercially available data impacting markets,

companies, brands, and sectors across the globe. The Investment Adviser employs a linear factor model with risk, industry and alpha terms that is commonly used by quantitative investors and then engineers proprietary alpha factors using a computationally intensive machine learning pipeline that ingests large volumes and varieties of data, resulting in these factors loading heavily on metrics of future growth and efficiency. The Investment Adviser will also build models of market expectations of growth and efficiency aligned with the alpha factors such that the Investment Adviser understands what is priced into the markets. Using information from the machine learning pipeline and the models of market expectations, the Investment Adviser seeks to be able to predict “surprise” exposures, and to be rewarded through the convergence of market expectations.
In the future, the Investment Adviser expects that its advice will be augmented by the insights it can make when individuals (the “Members”) contribute data (a “Member Contribution”) by connecting their social media, banking, and other accounts (the “Source Accounts”) to its affiliate, Delphia Technologies Inc. (“Delphia Tech”), through Delphia Tech’s data collection platform (“Platform”). Member Contributions will be made when a Member connects a Source Account to the Platform. This proprietary data will provide the Investment Adviser with a source of unique factors that the Investment Adviser will use to predict public opinion and consumer behavior. Currently, Delphia Tech collects data from Members; however, Investment Adviser does not use Member Contributions to power its advice.
To the extent an individual or institution that qualifies as a Fund Investor retains the Investment Adviser to provide investment advisory services for an SMA, the Fund Investor may impose specific investment restrictions on the SMA with respect to investing in securities or certain types of securities.
Please see Item 8 for further information about the Investment Adviser’s investment strategies.
Additional information about the Investment Adviser’s products and services is provided in the Investment Adviser’s Form ADV Part 1, available at http://www.adviserinfo.sec.gov. C. Tailored Advisory Services. The Investment Adviser tailors its advisory services as described in the investment program of the relevant Client’s private placement memorandum or as set forth in such Client’s organizational documents (e.g., a Client’s limited partnership agreement) and/or as set forth in the investment management agreement with such Client.
D. Difference Between the Management of Funds, SMAs and Wrap Fee Program The Funds are managed by the Investment Adviser in accordance with each Fund’s investment objective as disclosed in that Fund’s private placement memorandum. Each SMA is managed in accordance with the investment policy statement negotiated by the account holder and the Investment Adviser. The Investment Adviser receives a portion of the fees charged to each Fund and SMA in accordance with the applicable fee schedule.
ADV Part 2A–Firm BrochureMarch 31, 2023Page 5 of 25 Further, the Investment Adviser also offers separate advisory services to primarily retail investors (the “Wrap Fee Account Clients”) and has previously prepared and filed a wrap fee brochure (“Wrap Fee Brochure”) which describes this service. As of the date of this document, Wrap Fee Account Clients do not pay the Investment Adviser any management fees on their investment accounts. For additional details, please see the Investment Adviser’s Wrap Fee Brochure.
E. Discretionary Client Assets Managed As of December 31, 2022, the Investment Adviser and Corton Capital Inc., a non-affiliated Canadian investment adviser whose managed accounts utilize the same suite of AI tools from Delphia AM and the same investment strategy as the Master Fund, have $78.9 million in client (net) assets under management on a discretionary basis. As of December 31, 2022, Delphia (USA) Inc. manages $41.4 million of such $78.9 million aggregate discretionary client (net) assets under management.