Lupa RIA Investment Management LLC (“we,” “us” or the “Adviser”) is an investment advisory
firm that was formed in 2021. The Adviser is based in New York City and is an indirect
wholly-owned subsidiary of Lupa Systems LLC (“Lupa Systems”). Lupa Systems is, in turn,
wholly owned by Lupa Investment Trust (“Lupa”), a trust established by James R. Murdoch.
Mr. Murdoch also serves as the Chief Executive Officer of Lupa Systems.
The Adviser provides investment advisory services to various private investment vehicles
and other institutional clients (each, a “Client” and, collectively, the “Clients”). Lupa, its
affiliates and certain key employees are the only investors in certain of our existing Client
accounts (the “Legacy Clients”), but certain other Clients have other third-party investors
(“Third-Party Clients”). In certain circumstances and where appropriate, opportunities to co-
invest alongside the Clients in portfolio companies may be offered to investors in our Clients,
including Lupa and other third party investors.
The Clients’ assets are invested in accordance with such Client’s governing documents, as the
same may be amended
from time to time (the “Client Governing Documents”). We tailor the
investment advisory activities we provide to the Clients to comply with the investment
objectives, guidelines and restrictions set forth in each Client’s Governing Documents. We do
not tailor our investment activities on behalf of the Clients to the needs of any individual
investor in a Client. However, in accordance with common industry practice, a Client may
from time to time enter into a “side letter” or similar agreement with an investor pursuant to
which the investor is granted specific rights, benefits or privileges that are not generally made
available to all investors. See “Item 8 – Methods of Analysis, Investment Strategies and Risk of
Loss” for additional details.
As of December 31, 2022, we managed approximately $1,579,490,226 in regulatory assets
under management, of which $721,820,303 were managed on a discretionary basis and
approximately $857,669,523 were managed on a non-discretionary basis.