Description of Firm Spearhead Administrative Services, LLC is an investment adviser primarily based in Greenville, Delaware. We are organized as a limited liability company ("LLC") under the laws of the State of Delaware. We have been providing investment advisory services since April 2022. The direct owners of Spearhead Administrative Services, LLC are Spearhead Strategic Partners, LLC (61.6%) and Fieldstone II, LLC (26.4%) and Whitlow, LLC (12%).
The owners of the beneficial interests of Spearhead Strategic Partners, LLC are: 1. New Vernon Financial, LLC: owns 50% 2. Abstrum Partners, LLC: owns 50% The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the abbreviation or words "SAS," "firm," "we," "our," and "us" refer to Spearhead Administrative Services, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. For purposes of this document.
SAS provides investment advice and administrative services to private investment funds (each a "Fund" or "Series" and collectively the "Funds" or "Series") and separately managed accounts ("each an "Account" and collectively the "Accounts").
We are the Investment Manager to various insurance dedicated funds ("IDFs") and separately managed accounts ("Accounts"). An IDF may operate as one or more private investment funds each being organized as a designated series (each a "Fund"). Each Fund or Account managed by us will have its own set of investment objectives and strategy. We select and retain subadvisors to directly manage all Funds and Accounts consistent with the Fund's or Account's objective and strategy and subject to our oversight. The Funds and Accounts are solely offered to segregated asset accounts of insurance companies established for the owners of private placement variable life insurance contracts or private placement variable annuity contracts.
We may also set up the offering docs around a Fund. We do not provide legal advice but only provide documents to be reviewed by outside counsel.
Prospective investors in a Fund will be provided with

a Private Placement memorandum which includes a full description of the Fund, including details of the guidelines, parameters and restrictions on investments relating to the Fund, along with detailed terms, strategies and risks applicable to the Funds.
The Accounts are managed according to the objectives and investment policies in their respective policy and/or operational documents, including an Investment Management Agreement (an "IMA") and an Investment Policy Statement (an "IPS").
Certain affiliates of SAS serve as the Manager of the Funds.
The Funds are exempt from registration as an investment company under the U.S. Investment Company Act, as amended (the "Investment Company Act"), under Section 3(c)(7) thereof. In addition, SAS is registered as a Commodity Pool Operator with the National Futures Association. As such, it has certain reporting and recordkeeping requirements with regard to the Funds.
4 Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments Each Fund or Account will have the ability to invest globally in speculative investments utilizing a variety of financial vehicles, including without limitation, funds, private investment vehicles, hedge funds, stocks, bonds, pools, warrants, options, preferred and convertible debt and equity, real estate and any other investments which may be legally invested in by the Fund under applicable law.
The investment strategy applicable to investments in all Funds and Accounts is to seek capital preservation or capital appreciation. The IDFs and Accounts intend to diversify the investment objective and strategies by selecting subadvisors for each Fund or Account who utilize different investment strategies or who focus on different asset classes. Investors in the Funds and Accounts may not impose restrictions on investing in certain securities or types of securities.
Since our investment strategies and advice are based on each client's specific needs, the investment advice we provide to you may be different or conflict with the advice we give to other clients.
Assets Under Management As of December 31, 2023, we provide continuous management services for $1,215,303,747 in client assets on a discretionary basis.