Description of Advisory Firm
Anfield Capital Management, LLC (“Anfield,” “ACM,” “we,” “our,” or “us”) is a privately owned limited
liability company headquartered in Newport Beach, California. Anfield is registered as an investment
adviser with the SEC. Anfield offers discretionary investment management services to investment
advisers, registered investment companies (mutual funds and ETFs), and in select cases to private and
institutional clients. Anfield was originally founded in 2009 and underwent reorganization in 2012.
Principal Owners
David Young is owner of The David Young and Sandra G. Glain Family Trust, which owns 100% of The
Anfield Group, LLC.
The Anfield Group, LLC is a holding company, which owns:
The controlling interest (92%) in Anfield Capital Management, LLC.
The controlling interest (100%) in Regents Park Funds, LLC, an SEC Registered investment
Adviser providing portfolio management for investment companies.
Advisory Services Offered
Investment Management
Anfield offers discretionary and non-discretionary investment management services to investment
advisers/banks/trust companies and their clients, serving as a sub-adviser to the investment adviser or
other regulated entity. The fees ACM receives under these arrangements are described below under
Item 5 - Fees and Compensation.
Adviser to Registered Investment Companies
Anfield serves as Adviser to the Anfield Universal Fixed Income Fund (the “Fund”), an open-end mutual
fund that is a series of the Two Roads Shared Trust. The Trust is registered under the Investment
Company Act of 1940. Anfield is not affiliated with Two Roads Shared Trust.
Pursuant to the discretionary authority granted to us, Anfield may from time to time invest all or part of
our clients’ assets in the Fund. The fees we receive for management of the Fund, including the portion
of such fees corresponding to the amount of our clients’ assets invested in the Fund, are separate from
and in addition to the investment management fee paid to us by clients for management of their assets.
In addition, the management fees charged by the Fund may be higher than those available from other
alternative investments. This presents a conflict of interest, since the fees we receive for managing the
Fund create an incentive for us to invest client assets in the Fund. However, we will only invest client
assets in the Fund if we believe the investment to be in the client’s best interests, considering the
client’s objectives, risk tolerance, limitations and capital available for investment.
Anfield Capital Management, LLC Brochure December 31, 2023 6
Sub-Adviser to Registered Investment Companies
Anfield will also act as Sub-Adviser to the various ETFs (the “Anfield ETFs”), advised by Regents Park Funds,
LLC, that are a series of the Two Roads Shared Trust. The Trust is registered under the Investment
Company Act of 1940. Anfield is not affiliated with Two Roads Shared Trust.
Pursuant to the discretionary authority granted to us, Anfield may from time to time invest all or part of
our clients’ assets in the Anfield ETFs. The fees we receive for management of the Anfield ETFs, including
the portion of such fees corresponding to the amount of our clients’ assets invested in the Anfield ETFs,
are separate from and in addition to the investment management fee paid to us by clients for
management of their assets. In addition, the management fees charged by the Anfield ETFs may be
higher than those available from other alternative investments. This presents a conflict of interest, since
the fees we receive for managing the Anfield ETFs create an incentive for us to invest client assets in the
Anfield ETFs. However, we will only invest client assets in the Anfield ETFs if we believe the investment
to be in the client’s best interests, considering the client’s objectives, risk tolerance, limitations and
capital available for investment.
Separate Account Management
Anfield offers investment management services to select private and institutional clients (also “direct
clients”), providing investment policy statement determination, asset allocation, portfolio management,
and client reporting. We specialize in understanding the unique goals and requirements of each client
that we work with and provide customized investment management advice responsive to their needs.
Investment management is generally provided on a discretionary basis. We also offer investment
advisory services to clients on a non-discretionary basis. For these clients, we will contact the client
before making recommendations we deem to be appropriate for the client. See also Item 16 –
Investment Discretion below.
We describe fees charged for our services below under Item 5 - Fees and
Compensation.
Consulting and Assets Under Advisement Services
Anfield also offers customized consultation regarding economic and market outlook, investment
strategy, security selection, and model portfolios. ACM will also participate in speaking engagements
and presentations on economics, investment principles, asset allocation, or other related topics as
requested by the client.
Types of Investments
Investment advice may be offered on any investment including, but not limited to, the following
securities: exchange-listed securities, securities traded over-the-counter, foreign issues, warrants,
corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment
company securities (variable life insurance, variable annuities, mutual fund shares), United States
government securities, options (securities, commodities), futures contracts (tangibles, intangibles),
partnership interests (real estate, oil and gas, private equity). However, Anfield may offer advice
regarding other types of investments on an ad hoc basis per individual client inquiry or as appropriate in
Anfield Capital Management, LLC Brochure December 31, 2023 7
order to address the individualized needs, goals, and objectives of the client. We describe the material
investment risks for many of the securities that we recommend under the heading Specific Security
Risks in Item 8 below.
We discuss our discretionary authority below under Item 16 - Investment Discretion. For more
information about the restrictions clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this item below.
Limitation by Plan Sponsor/Employer
In the event Anfield is managing assets within a retirement plan such as 401(k), 403(b), or other
employer plan, ACM is limited to those investment providers and investment options chosen by the plan
administrator. Similarly, when we provide services to participants in an employer-sponsored plan, the
participant may be limited to investing in securities included in the plan’s investment options. Therefore,
Anfield can only make recommendations to the client from among the available investment options, and
ACM will not recommend or invest the client’s account in other securities, even if there may be better
options elsewhere.
Tailored Services and Client Imposed Restrictions
Investment Management
The investment adviser client is responsible for determining each of its client’s investment objective,
investment strategy, and any restrictions by which Anfield will manage the account on a discretionary
basis as a sub-adviser based on the instructions of the investment adviser. Clients may request
restrictions on the account, such as when a client needs to keep a minimum level of cash in the account
or does not want ACM to buy or sell certain specific securities or security types in the account. Anfield
reserves the right to not accept and/or terminate management of a client’s account if we feel that the
client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s
investment strategy.
Separate Account Management
At the inception of each client relationship under the Separate Account Management service, Anfield
works with the client to assess the client’s financial situation and needs and to create a written
investment policy statement (“IPS”) for the client to govern the management of their investment assets.
Clients may also impose certain restrictions on investing in certain types of securities or investments
within the IPS.
Assets Under Management
Anfield manages discretionary accounts on a continuous and regular basis. As of December 31, 2023,
we managed approximately $1,436,480,900 in assets on a discretionary basis. In addition, Anfield
manages certain client accounts by providing what we would consider an assets under advisement
(“AUA”) service level and generally includes assets upon which Anfield provides model portfolios to
other investment advisers to utilize with its own clients. Anfield manages these models on a continuous
and regular basis but is not involved in the actual implementation of the models for such investment
Anfield Capital Management, LLC Brochure December 31, 2023 8
advisers and therefore does not count these assets as regulatory assets under management. Anfield
will, on a quarterly basis, request that such investment advisers attest to the value of the assets that
utilize these models. As of December 31, 2023, Anfield provided AUA services to approximately
$321,348,013 in assets.