Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Delaware in 2021 and has been in business as an investment adviser since that time. Our firm
is wholly owned by Nilsine Assets, LLC.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Portfolio Management:
As part of our Portfolio Management service, Clients will be provided asset management and financial
planning or consulting services. Our firm conducts Client meetings to understand their current financial
situation, existing resources, financial goals, and risk tolerance. Based on what is learned, an investment
approach is presented to the Client that may consist of individual stocks, bonds, exchange traded funds
(“ETFs”), options, mutual funds and other public and private securities or investments. The Client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Portfolios will be designed to meet a particular investment goal,
determined to be suitable to the Client’s circumstances. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based
upon the Client’s individual needs, stated goals and objectives. Upon client request, our firm provides
a summary of observations and recommendations for the planning or consulting aspects of this
service.
Third-Party Managers:
Our firm may utilize and/or refer Clients to utilize the services of third-party investment advisory
firms or individual advisors (“Third-Party Managers”) to aid in the implementation of an investment
portfolio designed by our firm. Before selecting a firm or individual, our firm will ensure that the
chosen party is properly licensed or registered. Our firm will not offer advice on any specific securities
or other investments in connection with Third-Party Managers services. We will provide initial due
diligence on Third-Party Managers and ongoing reviews of their management of Client accounts. In
order to assist in the selection of a Third-Party Manager, our firm will gather client information
pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon
the management of the account.
Our firm will periodically review Third-Party Manager reports provided to the Client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
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and objectives; communicate information to Third-Party Managers as warranted; and, assist the
client in understanding and evaluating the services provided by the Third-Party Manager. Clients will
be expected to notify our firm of any changes in their financial situation, investment objectives, or
account restrictions that could affect their financial standing.
Private Investments Platform:
Nilsine Partners provides investment management and investment advisory services to feeder funds
and master funds (collectively “Funds”) through the platform discussed below.
Nilsine utilizes the services of Proteus Capital, LLC, who sponsors an alternative investment platform
(the “Platform”) that makes available to approved investors professionally managed alternative
investment strategies. The Platform provides information to investors that invest in various funds
(“Feeder Funds”) which invest in separately managed accounts, other pooled investment vehicles,
individual securities or master funds (“Master Funds”) that, in turn, invest in any combination of
these investments (collectively “Investment Products”) each of which are managed by assigned
managers (“Underlying Managers”). The Underlying Managers available to Nilsine clients on the
Platform are evaluated and selected by Nilsine, subject to Proteus’ review and approval of each
investment for use on their platform. Nilsine constructs and manages portfolios of Investment
Products into pools which are available to Nilsine clients through the Platform (the “Antero Pools”).
The investors in the Feeder Funds (“Investors”) may be individual or institutional investors, but in
each case must be “accredited investors” as defined in Rule 501(a) of SEC Regulation D. In addition,
some of the Feeder Funds on the Platform may require the investors to be “qualified purchasers” as
defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment
Company Act”), and/or “qualified clients” as defined in Rule 205- 3(d) under the Investment Advisers
Act of 1940, as amended (the “Advisers Act”).
As Investment Advisor to the Funds, the role of Nilsine Partners includes investment sourcing,
portfolio construction and commitment pacing. Nilsine creates model portfolios utilizing Underlying
Managers. These model portfolios are implemented by Nilsine and Proteus through the Antero Pools.
Nilsine actively manages the model portfolios and has the ability to add and remove managers, as
necessary (subject to approval by Proteus).
The role of Proteus is twofold. First, Proteus operates the Platform and, in this role, operates in an
administrative capacity as a manager of the Funds. Second, Proteus conducts due diligence on, and
continuously monitors the Underlying Managers available to Nilsine Clients on the Platform and, in
this role, Proteus operates in an advisory capacity. Additionally, Proteus provides Nilsine, as part of
the Platform, information and investigatory tools to facilitate the review, due diligence, and decision-
making process in evaluating Underlying Managers on the Platform.
Nilsine’s Investors subscribe to interests, units or shares (collectively “Interests”) of a Feeder
Fund. In this regard, Investors own Interests in the Feeder Fund which invests in Investment
Products and are maintained on behalf of the Investor in their capital account (“Investor’s Capital
Account”). For short-term cash management purposes, the Feeder Fund may invest in United States
government securities, banker’s acceptances, bank certificates of deposit, commercial paper, high
quality short-term instruments, including repurchase agreements, and shares of open-end mutual
funds and similar short- term instruments or accounts. Subsequent to a subscription to a Feeder
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Fund, Proteus provides the Investor with investment monitoring and reporting capabilities until such
time as the Investor redeems its investment from the Feeder Fund.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning
or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
We also provide institutional level consulting services where we make allocation recommendations
for client portfolios held with an outside broker dealer.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
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funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the
provision of services described therein.
Dynasty Network
We have entered into a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"),
which provides us with operational and back office support including access to a network of service
providers. Through the Dynasty network of service providers, we may receive preferred pricing on
trading technology, reporting, custody, brokerage, compliance and other related services. Dynasty
charges a "Platform Fee," as described in Item 5 below. In addition, Dynasty's subsidiary, Dynasty
Wealth Management, LLC ("DWM") is an SEC registered investment adviser, that provides access to
a range of investment services including: SMAs, mutual fund and ETF asset allocation strategies, and
unified managed accounts ("UMA") managed by external Third Party Managers (collectively, the
"Investment Programs"). We may separately engage the services of Dynasty and/or its subsidiaries
to access the Investment Programs. Under the SMA and UMA programs, we will maintain the ability
to select the specific, underlying Third Party Managers that will, in turn, have day-to-day
discretionary trading authority over the requisite client assets.
DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is available
to the advisers in the Dynasty Network, such as our firm. Through the Platform, DWM and Dynasty
collectively provide certain technology, administrative, operations and advisory support services
that allow us to manage our own client portfolios and access independent Third Party Managers that
provide discretionary services in the form of traditional managed accounts and investment models.
We can allocate all or a portion of Client assets among the different Third Party Managers via the
Platform. We may also use the model management feature of the TAMP by creating our own asset
allocation model and underlying investments that comprise the model. Through the model
management feature, we may be able to outsource the implementation of trade orders and periodic
rebalancing of the model when needed.
We will maintain the direct contractual relationship with the Client and obtain, through such
agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as
applicable, for services rendered through the Platform in service to the Client. We may delegate
discretionary trading authority to DWM and/or independent Third Party Managers to effect
investment and reinvestment of Client assets with the ability to buy, sell or otherwise effect
investment transactions and allocate client assets. If the Client participates in certain Investment
Programs, DWM or the designated manager, as applicable, is also authorized without prior
consultation with either us or the Client to buy, sell, trade or allocate Client assets in accordance with
the Client’s designated portfolio and to deliver instructions to the designated broker-dealer and/or
custodian of the Client’s assets.
Tailoring of Advisory Services
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Our firm offers individualized investment advice to our Portfolio Management clients. General
investment advice will be offered to our Third-Party Manager Clients, Financial Planning &
Consulting, and Retirement Plan Consulting Clients.
Each Portfolio Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, our firm has $1,236,202,842 in Assets Under Management, $1,046,634,993
of which is managed on a discretionary basis, and $189,567,849 of which is managed on a non-
discretionary basis.