A. Description of Firm
36 North is a Bentonville, Arkansas-based investment management firm founded in 2021.
36 North provides customized investment management services to institutional clients,
including endowments, foundations, family offices, and select high net worth individuals to
help them meet their financial and investment objectives. 36 North provides discretionary
Outsourced Chief Investment Officer (“OCIO”) services, as well as non-discretionary
Investment Management Services for those clients that prefer to approve certain portfolio
changes. In all instances, 36 North provides continuous and supervisory investment
monitoring of client portfolios, including asset allocation, tactical positioning, portfolio re-
balancing, and manager monitoring ("Investment Management Services"). 36 North will
not generally provide advice on individual stocks and bonds, but rather will advise and
invest with third-party institutional-quality investment managers across the full spectrum of
public and private investment strategies. These investments with third-party managers will
typically be made through Alternative Funds (as defined below) or separately managed
accounts managed by such third-party managers. 36 North also provides investment
consulting services and offers guidance at each stage of investment decision-making, risk
management, and investment monitoring processes. 36 North has been registered with
the SEC as an investment adviser since 2021.
Mark Fowler (“Mr. Fowler”) and Carolyn Keating (“Ms. Keating”) are the principal owners
of 36 North.
Mr. Fowler is 36 North’s Chief Investment Officer, Chief Compliance Officer and Chief
Executive Officer. Before co-founding 36 North, Mr. Fowler was a Partner at Cambridge
Associates, LLC, a global investment management firm, where he worked for twenty-eight
(28) years. In that capacity, Mr. Fowler worked with a diverse mix of clients, including
colleges, universities, foundations, museums, hospitals, families, and a sovereign wealth
fund. While at Cambridge, he led a team of eight investment professionals managing $9
billion in assets. Mr. Fowler has also served as a speaker at internal and external
investment conferences. Mr. Fowler holds a B.S. from the University of Virginia’s McIntire
School of Commerce and has earned the CFA designation.
Ms. Keating is 36 North’s Head of Private Investments, Chief Operating Officer and Chief
Financial Officer. Before co-founding 36 North, Ms. Keating spent more than six (6) years
at Cambridge Associates as a senior private investment specialist. Ms. Keating had
primary responsibilities for advising institutional clients on all aspects of their private
investment portfolios on both a discretionary and non-discretionary basis. Previously, Ms.
Keating spent five (5) years as a private equity specialist and was Head of Structuring &
Analytics for the U.S. Development Finance Corporation (formerly known as OPIC). While
at OPIC, Ms. Keating was responsible for selecting, investing with, and monitoring
emerging market private investment managers for a multi-billion-dollar private investment
portfolio. Ms. Keating spent the first half of her career in investment banking as a corporate
Eurobond specialist with Citibank and Deutsche Bank. Ms. Keating holds a B.S. from the
University of Virginia’s McIntire School of Commerce and an MBA from the Darden
Graduate School of Business.
B. Advisory Services Offered
1. Investment Management Services
36 North offers clients Investment Management Services covering the client’s total
investment portfolio, encompassing all traditional asset classes, including public equities
(both foreign and domestic), fixed income and credit, real assets, and alternative asset
classes (i.e., hedge funds, private equity funds, venture capital funds and other private
investment funds, collectively “Alternative Funds”). 36 North typically provides
investment advice utilizing a multi-manager approach, including recommendations
regarding investments in Alternative Funds or separately managed accounts managed by
third-party managers. In all instances, the advice provided by 36 North is bespoke for each
client’s investment objectives, financial condition, and risk tolerances.
36 North may manage a client’s investment portfolio on either a fully discretionary or non-
discretionary basis. In exercising full discretionary authority, 36 North selects, without first
obtaining the client’s agreement, (1) the investment managers or funds to be hired or fired;
(2) the amounts to be transacted; and (3) portfolio re-balancing/repositioning based on
market conditions and exposures. 36 North’s discretionary authority may be subject to
conditions imposed by a client. For example, this may occur when a client restricts or
prohibits transactions in an asset class, industry, or for a specific company or manager. In
all circumstances, when exercising its discretionary authority, 36 North will make
appropriate changes to the portfolio as it believes they are needed using 36 North’s asset
allocation methodology and based on a personalized understanding of each client’s
individual investment objectives.
36 North employs a defined process for each step in the investment management cycle,
including goal setting and risk/return profiling, asset allocation modeling, investment
selection and implementation, and ongoing monitoring and reporting. The outcomes and
mutual understandings resulting from this process are reflected in the client’s investment
policy statement (the “Investment Policy Statement”) or other
similar documentation and
help inform 36 North’s formation of the client’s asset allocation and manager selection for
the client’s portfolio. 36 North may also provide ongoing investment advice regarding
reviewing, developing, and evolving a client’s Investment Policy Statement. This
approach helps to provide a robust process to provide long-term investment solutions.
Depending upon the strategy selected by 36 North and the client, 36 North may invest
client assets in various sectors and securities, including investments in alternative
investment assets managed by third-party managers. Please refer to Item 8 for more
information on 36 North’s investment strategies, methods of analysis, and their associated
risks of loss.
Clients may request that 36 North place trades with a particular broker-dealer (also known
as “Directed Brokerage”). For more information on 36 North’s discretionary authority
and brokerage practices, please refer to Items 12 and 16.
2. Other Consulting Services
Other consulting services include financial advice and/or analysis of a specific client
objective or situation, as defined and agreed on by the client and 36 North in advance
(“Other Consulting Services”). For example, 36 North may conduct both investment and
operational diligence reviews on third-party managers, evaluate a particular venture or
investment, or assess advisory services offered by another professional organization.
Fees for Other Consulting Services are described below under Item 5: Fees and
Compensation.
C. General Information About 36 North’s Advisory Services
1. Gathering Individual Client Information
Investment Management Services provided by 36 North are customized based upon the
client’s individual needs, objectives, and other financial goals. Early in the relationship,
36 North may memorialize each client’s investment objectives, risk tolerance, time
horizons, and additional essential information, including any investment guidelines, in the
client’s Investment Policy Statement. Together with any other information relating to the
client’s overall financial circumstances, this information will be used by 36 North to
determine the most appropriate asset allocation and investment strategy to best meet the
client’s financial goals. At times, a client may place certain restrictions that may prevent
36 North from accepting or continuing to service the client’s account.
Under all circumstances, clients are responsible for promptly notifying 36 North in writing
of any material changes to the client’s financial situation, investment objectives, time
horizon, risk tolerance or Investment Policy Statement.
The decision to invest client assets in Alternative Funds or separately managed accounts
is based on a number of factors, including the client’s investment strategy, objectives,
restrictions, size, third-party manager minimum asset size requirements for separately
managed accounts or Alternative Funds, as well as available assets and cash.
2. Manager Research and Due Diligence
36 North uses a combination of historical and forward-looking analytical models to
determine the appropriate asset allocation and manager structure for client portfolios.
36 North’s investment manager research and due diligence for traditional and alternative
asset funds is based on quantitative and qualitative analysis. The evaluation typically
includes an assessment of the quality of the firm, product/strategy, investment team,
historical performance, investment selection process, holdings, portfolio construction,
risks, terms and fees, and back-office infrastructure. 36 North may also conduct reference
checks as part of the due diligence process. 36 North may recommend different
investment managers to different clients based on unique needs, including the degree to
which a strategy complements other investments in the respective portfolios.
3. Advisory Agreements
Before engaging 36 North to provide investment advisory services, the client will be
required to enter into a written client agreement ("Client Agreement") with 36 North,
setting forth the fees to be charged and the terms and conditions under which it will render
its services. Further, 36 North will provide a Brochure and one or more Brochure
Supplements to each client or prospective client before or contemporaneously executing
a Client Agreement. The advisory relationship will continue until terminated by the client
or 36 North as outlined in the Client Agreement.
4. Client Restrictions
Clients may impose reasonable restrictions on the types of asset classes, sectors,
industries, and/or securities they do not want to be included in their portfolio. Such
restrictions must be communicated to 36 North in advance and documented in writing.
Once this information is gathered initially, each client is responsible for informing 36 North
in writing of any changes to these restrictions or their overall investment objectives. 36
North does not assume any responsibility for the accuracy of the information provided
directly by its clients or the failure of clients to inform 36 North of changes to their
investment or financial objectives. However, certain client restriction requests may be
limited when investing in Alternative Funds.
D. Wrap-Fee Programs
36 North does not provide portfolio management services to any wrap fee programs, as
that term is defined in the instructions to Form ADV Part 2A.
E. Assets Under Management
As of December 31, 2022, 36 North’s assets under management ("AUM") totaled $1.3
billion.