GREYBULL Partners, LLC (hereinafter “GREYBULL”) provides investment management
services and has been in business since 2003. EARNEST Partners Private Capital, LLC
(hereinafter “EPPC”) provides investment management services, was established in 2018, and is
a “relying adviser,” (identified in Item 10 of this brochure, as well as on Schedule R of
GREYBULL’s Form ADV Part 1) and, as such, EPPC is not, and is not required to be,
independently registered with the SEC. Therefore, GREYBULL and EPPC are together filing a
single Form ADV, as permitted by SEC rules and regulations. Throughout this brochure, unless
the context requires otherwise, the responses combine information about GREYBULL and EPPC
and references to “we”, “us” and “Firm” mean GREYBULL and EPPC collectively.
We generally may offer investment advice on a variety of securities including without limitation
the following: equity securities, equity-linked securities, mutual fund shares, limited partnership
interests, membership interests, fixed income securities, notes, debentures, convertible securities,
depositary receipts, related rights, options (including without limitation, listed and over-the-
counter options and the writing of options, whether or not covered), warrants, other securities,
currencies and commodities, futures contracts, forward contracts, swaps, options on the
foregoing, other derivative instruments and hybrid instruments, and other instruments and
investments, in each case of every kind and character, traded on United States and non-United
States markets (including over-the-counter markets) and exchanges. EPPC also offers
investment advice on illiquid investment opportunities, including growth equity, venture capital,
private equity, and private debt.
The Firm manages client accounts in accordance with any investment restrictions or guidelines
set forth in the applicable client’s investment management agreement or governing documents
and, for a Fund (as defined below), also the offering documents for such Fund.
GREYBULL generally will not advise or act for clients in legal proceedings, including class
actions or bankruptcies, involving securities purchased or held in clients’ accounts.
Commercially reasonable efforts are used to transmit copies of class action notices GREYBULL
receives to the client or the client’s designee and GREYBULL will not be responsible for
reasonable delays in transmission.
The following is related to EPPC’s advisory business:
In general, EPPC provides investment supervisory services to investment vehicles (each, a
“Fund”) that are exempt from registration under the Investment Company Act of 1940, as
amended, and whose securities are not registered under the Securities Act of 1933, as
amended, pursuant to the governing documents of such Fund or separate investment and
advisory or investment management agreement among EPPC, the applicable Fund and the
general partner or manager entity of such Fund (each, a “general partner”). Each general
partner of a Fund is a related person of EPPC. EPPC may enter into a separate account
arrangement with a client.
EPPC’s client portfolios generally focus on illiquid investment opportunities, and the
investment advice that EPPC provides to each Fund is subject to the overall direction and
control of such Fund’s general partner. EPPC invests client assets in a range of countries,
markets and exchanges in Asia and throughout the world.
EPPC and its affiliates may establish or advise, on a case-by-case basis, an investment
vehicle or account
through which certain persons could invest alongside of one or more
Funds or clients (each, a “co-investment”) in portfolio companies in which one or more
clients may make an investment. In addition, certain Funds (and other EPPC clients) may
from time to time co-invest with each other. EPPC’s fee and compensation practices for co-
investments are subject to a case-by-case agreement with the applicable investor(s).
EPPC may face certain conflicts in allocating investment opportunities among its various
clients, including clients with similar or identical investment strategies or objectives and
clients that have separate and distinct, but overlapping, trading and investment strategies or
objectives. EPPC also faces additional allocation conflicts in connection with certain
proprietary or principal vehicles owned or controlled by EPPC and its affiliates. Although
EPPC and its affiliates will have significant latitude in determining the allocation of such
opportunities among its various clients, where investment opportunities fall within the
investment strategy or objectives of more than one client, EPPC’s policy is to allocate
investment opportunities among eligible clients fairly and equitably, to the extent possible,
over a period of time, taking into account a variety of considerations. In an effort to ensure
fairness in the allocation of investment opportunities among EPPC’s clients, EPPC has
adopted allocation policies, procedures, and processes that permit EPPC to take into account
various factors, including: the suitability of the investment for each of EPPC’s clients;
EPPC’s clients’ investment objectives, strategies and focuses; the pre-money valuation of the
prospective portfolio company; the portfolio composition of EPPC’s clients; the anticipated
holding period of the prospective investment; the expected amount of capital required for the
investment; the applicable client’s liquidity and reserve levels; the expected life cycle of the
applicable client and its ability to make or dispose of an investment; the applicable client’s
targeted rate of return; the stage of development of the prospective investment; the risk
profile or other attributes of the investment opportunity; allocation targets of the applicable
client; the sourcing of the investment opportunity within EPPC; the management, control or
governance rights of the prospective portfolio company; the EPPC personnel who will
monitor the investment opportunity; the potential to gain influence or control over the
prospective portfolio investment; and structural, timing, regulatory, legal, tax, contractual,
and other considerations deemed relevant in good faith.
GREYBULL is owned 25% by Westchester Limited, LLC and greater than 25% by Peloton,
LLC. EPPC is owned greater than 25% by EARNEST Partners, LLC. Paul E. Viera indirectly
owns more than 25% of GREYBULL and EPPC through Peloton, LLC and The PEV Revocable
Living Trust, and EARNEST Partners, LLC, Westchester Limited EP, LLC and The PEV
Revocable Living Trust, respectively.
The amount of client assets managed as of December 31, 2023:
Discretionary basis: $ 223,346,293
Non-discretionary basis: $ 0
Total: $ 223,346,293
The amount of assets under management reported in this brochure is “regulatory assets under
management” which is inclusive of any uncalled commitments ($31,316,700) and without
deducting any outstanding indebtedness or other accrued but unpaid liabilities ($0).