WestEnd Capital Management, LLC (“WestEnd” or the “Firm,” and also the “General Partner” or the
“Manager”), a California limited liability company, was formed in 2002 and is a Registered Investment
Adviser with the SEC with its principal place of business in Sausalito, California. George Bolton, George
T. Elliman and Gustave R. Ozag are the Firm’s Principal owners.
WestEnd is an investment adviser that provides advisory services on a discretionary basis to a privately
offered pooled investment vehicle, WestEnd Partners, L.P. a California limited partnership, (“WEP” or the
“Private Fund”), which is intended for accredited investors with certain net worth requirements, as well as
advisory services on a discretionary basis to individuals through separately managed accounts (the
“Separate Accounts,” together with the Private Fund, the “Advisory Clients”). WestEnd also offers
financial planning services, such as retirement, risk management, and college funding concerns, to its
Separate Account clients, at their selection, at no additional charge.
WEP’s investment objective is to grow capital by holding, selling, trading, and otherwise dealing (both long
and short) in a broad spectrum of securities, consisting principally, but not solely, of equity and equity-
related securities that are issued by companies that are traded publicly in domestic markets as well as
preferred stocks, convertible securities, warrants, options, private securities, non-U.S. securities, equity total
return swaps and money market instruments as deemed appropriate by the General Partner. WEP may deal
in bonds and other fixed income securities but does not expect to do so. WEP may also engage in other
hedging strategies, margin trading, and other investment strategies to the extent consistent with its
investment strategy. The investment strategy of WEP is to attempt to achieve appreciation through market
inefficiencies in valuation of securities or commodities based on extensive research efforts involving a
process of collecting, synthesizing, and interpreting fundamental and technical data from a variety of
sources, including a network of industry executives, advisory services, independent research analysis,
capital market professionals, traders, brokers and other money managers, quarterly and annual reports and
various technical publications.
The investment objectives and strategies of the Separate Accounts vary based on the individual clients’
preferences. WestEnd offers its Separate Account clients three different investment mandates to choose
from: (i) Core Growth Portfolio – an equity-based investment approach, whereby the Manager invests in
both domestic growth and value companies from various sectors seeking largely to identify companies
with strong earnings relative to their peers as well as strong forward-looking earnings
expectations; (ii)
Equity Income Portfolio – seeks a high degree of current income with the secondary objective of capital
appreciation. These objectives are sought while following principles consistent with portfolio
diversification and long-term capital preservation. The strategy invests primarily in common equities but
may also invest in preferred and exchange traded funds (ETFs) as well as Master Limited Partnerships
(MLPs) and Real Estate Investment Trusts (REITs); and (iii) Custom – a client elects one of the above-
mentioned strategies and instead mandates the Manager to build a custom portfolio for their assets based on
specific investment objectives and risk tolerance of the client as disclosed to WestEnd.
WestEnd does not limit its investment advice to specific types of investments, however, the Core Growth
Portfolio is a selection of a limited number of securities. Because of this, the Core Growth Portfolio should
not be considered to be tailored to a client’s needs and may not be considered to be diversified. WestEnd
acknowledges the conflict of interest that exists as a result of WestEnd providing to Advisory Clients
financial planning services that could lead to more transactions with the Firm, though these services are
provided at no
additional charge. Clients should be aware that they are under no obligation to act upon WestEnd’s financial
planning recommendations, and that if they elect to act so, they are under no obligation to affect the
transaction through WestEnd.
The Firm’s investment management and advisory services provided to the Private Fund are provided
pursuant to the terms of the relevant offering documents and based on the specific investment objectives
and strategies as disclosed respectively therein. Investors in the Private Fund may not impose restrictions
and will not receive advisory services tailored to their individual needs.
As described above in response to Item 4.B., WestEnd’s advisory services for its Separate Account clients
are tailored to their preference as selected in the relevant Investment Management Agreements (“IMA”)
and are based upon the return expectations, tolerance for risk and volatility, and the need for liquidity of
each specific Separate Account client. The Separate Account clients may impose restrictions on investing
in certain securities or types of securities pursuant to the terms and specific investment objective and
strategy as stated in each individual Separate Account client’s IMA.
Not Applicable. WestEnd does not participate in a wrap fee program.
As of December 31, 2022 WestEnd, managers approximately $174,329,015 in Advisory Client regulatory
assets under management on a discretionary basis, as described in the relevant IMA or offering documents.
WestEnd does not manage any of its Advisory Clients’ assets on a non- discretionary basis.