A. Principal Owners and Background
The Palisades Group, LLC (“TPG”), a Delaware limited liability company, is a mortgage credit, real estate, and
fixed income investment advisory firm that was formed in 2012. TPG is a wholly owned subsidiary of
Palisades Holdings II, LLC (“Holdings II”), which is in turn a majority owned subsidiary of Palisades Holdings I,
LLC (“Holdings I”). Jack L. Macdowell, Jr. is the principal owner of Holdings I.
Palisades Investment Partners I, LLC (“PIP I”) was formed in 2017 to act as a sub‐adviser to an unaffiliated
investment adviser for a privately offered pooled investment vehicle. PIP I is a wholly‐owned subsidiary of
TPG and is a relying adviser with respect to TPG’s investment adviser registration.
Palisades Advisory Services, LLC (“PAS”) was formed in 2016 and was appointed in 2021 to act as asset
manager to a securitization vehicle that holds residential transition loans. PAS is a wholly‐owned subsidiary
of Holdings II and is a relying adviser with respect to TPG’s investment adviser registration. TPG, PIP 1 and
PAS are collectively referred to herein as “Palisades”.
Mr. Macdowell is the Chief Investment Officer and manages the investment advisory business.
B. Types of Advisory Services
Palisades provides investment management and advisory services on both a discretionary and non‐
discretionary basis.
Palisades’ discretionary strategies involve making direct investments in residential mortgage loans and other
real estate‐related assets on behalf of privately offered pooled investment vehicles (the “Discretionary
Funds”). Palisades provides sub‐advisory services to privately offered pooled investment vehicles, separate
accounts, insurance companies, and other institutional clients whose portfolios consist of a variety of
residential loans, real estate related assets, and consumer loans (the “Non‐Discretionary Clients” and
together with the Discretionary Funds, the “Clients”).
As part of the advisory services, Palisades provides investment advice regarding the acquisition and
management of mortgage loans and real estate related assets including sourcing, valuation, analytical
services, and portfolio and risk management strategies. Palisades also provides transaction settlement and
mortgage loan document remediation services to
its advisory Clients. As part of the normal course of
managing certain mortgage loan portfolios, Palisades performs due diligence on mortgage loan servicing
partners, negotiates terms of servicing arrangements, and retains certain rights to direct the servicers’
activities, and transfer the servicing duties with or without cause.
Services and activities performed by Palisades for Clients may include one or more of the following:
(i) investigating, identifying, analyzing, evaluating, and selecting possible investment
opportunities on a discretionary and non‐discretionary basis, and negotiating, acquiring,
financing, managing, monitoring, selling, restructuring, or disposing of assets consistent with
a Client’s investment or asset management guidelines;
(ii) negotiating financing arrangements, including credit facilities (including term loans and
revolving credit facilities), securitizations, warehouse facilities, repurchase agreements, and
similar agreements and engagements;
(iii) evaluating hedging activities on a Client’s behalf;
(iv) performing due diligence on, negotiating commercial arrangements with and supervising
parties and independent contractors that provide real estate, investment banking, mortgage
brokerage, mortgage loan servicing, appraisal, securities brokerage, underwriting review, due
diligence, insurance, legal and accounting, and other legal, or administrative financial
services, and similar services; and
(v) performing management services as may be required from time to time and other activities
relating to a Client’s assets and business as a Client shall reasonably request.
C. Tailoring of Advisory Services
Palisades tailors its investment advisory services in accordance with the investment objectives and strategies
of its Clients. Investment advisory services may be provided on either a discretionary or non‐discretionary
basis. Clients that grant Palisades discretionary authority may restrict the types of investments that Palisades
will make on their behalf.
D. Wrap Fee Programs
Palisades does not participate in wrap fee programs.
E. Amount of Client Assets We Manage
As of December 31, 2023, Palisades has regulatory assets under management of approximately
$15,183,512,221 on a non‐discretionary basis and $624,605,733 on a discretionary basis.