PPMC was formed by S. Donald Sussman in 1989. Mr. Sussman and Gregory Hayt are PPMC’s
directors. PPMC is owned equally by Mr. Sussman, Mr. Hayt and 15 senior employees of PPMC, all
of whom are listed in Schedule A of PPMC’s Form ADV Part 1A. Paloma Partners Advisors LP
(“Paloma Advisors”), is a relying adviser with respect to PPMC’s investment adviser registration.
Mr. Sussman owns and controls Paloma Advisors; additional information about Paloma Advisors is
provided in Schedule R of PPMC’s Form ADV Part 1A.
PPMC has a wholly-owned subsidiary, Paloma Switzerland GmbH, which maintains an office in
Zurich, Switzerland. Paloma Switzerland GmbH provides investor relations and product
development services to, and advice (without decision making authority) regarding the allocation of
capital of the Paloma Fund, subject to the direction of, and the policies established, by PPMC.
Paloma Switzerland GmbH is registered as an exempt reporting adviser with the SEC. References
herein to “PPMC” include Paloma Switzerland GmbH, as applicable.
PPMC and Paloma Advisors are collectively referred to herein as Paloma Management.
Paloma Management provides discretionary investment advisory services to the Paloma Fund
(defined below). Investors in the Paloma Fund cannot obtain services tailored to their specific
needs. Paloma Management does not participate in wrap fee programs.
As of December 31, 2022, Paloma Management advised $3,857,751,946 on a discretionary basis.
Neither PPMC nor Paloma Advisors manage assets on a non-discretionary basis.
• THE PALOMA FUND
The “Paloma Fund” is a multi-strategy hedge fund with a master–feeder structure including three
feeder funds which invest all their investable assets in the master fund. The Paloma Fund seeks to
achieve attractive long-term risk-adjusted returns through dynamic capital allocation among a
changing set of investment strategies and Portfolio Managers.
The investment program of the Paloma Fund is exclusively carried out through the master fund,
Paloma International L.P., and other entities through which the master fund makes investments or
enters into transactions (collectively, the “Master Fund”). There are no diversification requirements
or material limitations on the strategies, investments, instruments, leverage, markets or countries
in which the Paloma Fund may invest.
Paloma Management has ultimate discretion and control over the Paloma Fund and its
investments. Investment advice is provided to the Paloma Fund pursuant to the terms of each
feeder fund’s
confidential private offering memorandum and other organizational and governing
documents (collectively, “Fund Documentation”). Paloma Management’s responsibilities to the
Paloma Fund include: the selection of Portfolio Managers and strategies, managing the Master
Fund’s allocations and exposures across strategies and among Portfolio Managers, providing
investment and credit risk management advice, and risk hedging. Portfolio Managers is the
collective term used for Trading Teams, managers of Portfolio Funds and managers of other direct
investments in public or private companies.
Most of the Paloma Fund’s Portfolio Managers are Trading Teams. Trading Teams are investment
teams that pursue investment strategies in the Master Fund. Trading Teams are either engaged as
independent contractors or are employed by PPMC. Independent contractors are responsible for
their own operations (e.g., compliance and registration(s), supervision of employees, hiring of
personnel and information technology) but are subject to Paloma Management’s portfolio and risk
management oversight. Descriptions of Trading Teams and their activities in this Brochure
generally apply to all Trading Teams (regardless of whether or not a Trading Team is an
independent contractor (“External Trading Team”) or PPMC employee (“Employee Trading Team”))
unless otherwise noted.
The Paloma Fund also makes direct investments in public or private companies and Portfolio Funds.
Portfolio Funds are generally passive investments in standalone, externally managed private
investment funds.
Additional information about the Paloma Fund’s entities is included in Section 7.B of Schedule D in
PPMC’s Form ADV Part 1A.
DISCLAIMER
No guarantee or representation is made that the Paloma Fund’s investment program, including,
without limitation, its investment objectives, diversification, strategies or risk monitoring processes,
will be successful. The risk management process includes an effort to monitor and manage risk, but
does not imply low risk. There may be risks which are not monitored or controlled and risks that
may be greater than forecasted, especially in unusual market conditions. Nothing herein is
intended to imply that the Paloma Fund’s investment strategy is “conservative”, “safe”, “risk free”,
or “risk averse”. There can be no assurance that the Paloma Fund’s investment objective will be
achieved or that its portfolio design and risk monitoring strategies will be successful. Investors may
lose all or substantially all of their capital.