A. Description of the Advisory Firm
VELA Investment Management, LLC (hereinafter “VELA”) is a Limited Liability Company
organized in the State of Delaware. The firm was formed in November 2019. VELA has 15
owners with Roderick Hadley Dillon, Jr. as its principal owner. VELA became a SEC registered
investment adviser in June 2020. Jason will provide updated language.
B. Types of Advisory Services
Portfolio Management Services
VELA offers ongoing portfolio management services based on the individual goals, objectives,
time horizon, and risk tolerance of each client. VELA creates an Investment Policy Statement for
each client, which outlines the client’s current situation to aid in the selection of portfolio
securities to meet a client's specific situation. Portfolio management services include, but are not
limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
VELA evaluates the current investments of each client. VELA will request discretionary authority
from clients to select securities and execute securities transactions without permission from the
client prior to each transaction.
VELA manages the investment strategies described in Item 8.a. These investment strategies may
be part of a client’s investment program or may be a clients only investment. If a client decides
to utilize one or more of VELA’s separately managed account strategies, the client’s Investment
Policy Statement will include the description of the strategies chosen.
VELA makes investment decisions in accordance with the fiduciary duties owed to its clients and
without consideration of VELA’s economic, investment or other financial interests. To meet its
fiduciary obligations, VELA attempts to avoid, among other things, investment or trading
practices that systematically advantage or disadvantage certain client portfolios, and accordingly,
VELA’s policy is to seek fair and equitable allocation of investment opportunities/transactions
among its clients to avoid favoring one client over another over time. It is VELA’s policy to
allocate investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
We are fiduciaries under the Investment Advisers Act of 1940 when providing advisory services
to you. In addition, when we provide investment advice to you regarding your retirement plan
account or individual retirement account, we are also fiduciaries within the meaning of Title 1 of
ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. We are required to act in your best interest and not put our interests ahead of yours.
In addition, we must:
• Meet a professional standard of care when making investment recommendations
• Never put our financial interests ahead of yours when making recommendations
• Avoid misleading statements about conflicts of interest, fees and investments
• Follow policies and procedures designed to ensure that
we give advice to you that is
in your best interest
• Charge no more than is reasonable for our services
• Give you basic information about conflicts of interest
We benefit financially from the rollover of your assets from a retirement account to an account
that we manage because your assets increase our assets under management and, in turn, our
advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best
interest.
Services Limited to Specific Types of Investments
VELA generally limits its investment advice to mutual funds, including its own open-end mutual
fund family, the VELA Funds, fixed income securities, equities, options, derivatives and ETFs.
However, VELA may also use other securities to help diversify a client portfolio when applicable.
Stifel, Nicolaus & Company, Incorporated Connect Program
VELA is an investment adviser in the Stifel, Nicolaus & Company, Incorporated (Stifel)’s Connect
program. A Stifel Financial Advisor provides its clients with investment advisory services on a
non-discretionary basis and assists its clients in the selection of an investment management, such
as VELA, to manage the client’s Connect account on a discretionary basis, in accordance with the
terms of a separate investment advisory agreement between the client and VELA. In each case,
the Stifel Financial Advisor will assist the client in establishing and maintaining a relationship
with VELA. In the Connect Program VELA will have trading authority over your account.
For Client’s in the Connect Program, Stifel will provide you with disclosures regarding the
Connect Program. You should carefully review those disclosures.
Connect Program clients to whom VELA provides discretionary investment management
services have a minimum account size of $250,000 and an annual investment management fee of
.50%.
C. Client Tailored Services and Client Imposed Restrictions
VELA will tailor a program for each individual client. This will include an interview session to
get to know the client’s specific needs and requirements as well as a plan that will be carried out
by VELA on behalf of the client. VELA may use model allocations together with a specific set of
recommendations for each client based on their personal restrictions, needs, and targets. VELA
allows clients to impose reasonable restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. VELA is an
investment manager for the Stifel Connect program.
E. Assets Under Management
VELA’s regulatory assets under management, as defined in Form ADV Part 1, are as follows:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 397,813,678 $ 78,325
12/31/23
VELA’s assets under management include mutual funds, separately managed accounts and
wealth management accounts as of 12/31/23 are $ 391,221,4480.