A. Description of the Advisory Firm Deltec Investment Advisers Limited ("DIAL") is a registered investment adviser based in Nassau, Bahamas. We are organized as an international business company under the laws of the Commonwealth of the Bahamas and have been in business since February 2013. Deltec International Group ("DIG") is our principal owner. DIG is a Cayman Islands corporation. Schell Stubbs is our Chief Compliance Officer, Jean Chalopin is our President, and Terence Girling is our Secretary.
As used in this brochure, the words "we", "our" and "us" refer to Deltec Investment Advisers Limited and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm.
B. Description of Services 1. Investment Advisory Services DIAL offers investment advisory services to wealthy individuals and families as well as to certain trusts, foundations, and other corporate entities. These services include, but are not limited to, the following: 1. Portfolio Management and Financial Planning Services 2. Security, Strategy and Manager Selection (Selection of Other Advisers) 3. Fund Management DIAL's investment advisory services integrate the fundamentals of financial planning with the full range of portfolio construction and management techniques in order to provide objective advice through an open architecture platform. DIAL works individually with each client to develop a tailored investment policy based on the specific goals, objectives, risk tolerance, time horizon, liquidity and cash flow needs of each pool of assets (or grouping of accounts/portfolios) the client may own or control. The investment policy for individuals and families considers a variety of inputs which include a set of financial statements (Balance sheet, Income statement, cash flow statement and budget), tax returns, estate planning efforts as well as philanthropic and legacy issues and desires. We typically work with your other professionals (accountant, estate lawyer, insurance agent, etc.) in order to provide you with comprehensive investment advisory services. These inputs, along with a number of qualitative factors such as your risk tolerances and investment experience and disposition, are used to form the basis of our investment recommendations. Our advice is captured in an investment policy statement (IPS) that is created in collaboration with you. The IPS serves to document the goals and objectives of the portfolio or group of portfolios, risk tolerances, limits and restrictions on specific investments, investment types, structures and strategies. The IPS is reviewed periodically, but no less than annually, and is updated when appropriate.
The following paragraphs describe our services in more detail. Please refer to the description of each service listed below for information on how we tailor them to your individual needs.
a. Portfolio Management and Financial Planning Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' goals, needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment goals and objectives, risk tolerance, time horizon and other relevant information at the beginning of our advisory relationship. Based on our discussions with you we will create an Investment Policy Statement (IPS) which outlines your current situation (income, tax levels, goals and objectives, and risk tolerance, among others). The 4 IPS will outline a plan and the strategies that will enable our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you according to your risk tolerance and goals and objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio to meet changes in market conditions, regulations, the tax code or your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us, without your approval prior to each transaction, to determine the specific securities, strategies and managers and the amount to invest in each for your account. Discretionary authority is granted through the investment advisory agreement you sign with our firm along with the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transaction or the hiring/firing of an investment manager on behalf of your account.
In conjunction with our portfolio management service, we may also offer broad based financial planning services. These services typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. We will meet with you to gather information about your financial circumstances and objectives. Part of this review process includes the review of prior tax returns and an evaluation of any estate planning efforts you have made. We use many financial planning tools to determine your current financial position and to define and quantify your short-term as well as long-term goals and objectives; these include financial statements (balance sheet, income statement, cash flow statement and budgets). Once we review and analyze the information you provide us and the data derived from our financial planning analysis, we will develop a plan for you which will be designed to help you achieve your stated financial goals and objectives. Once we are able to determine your long-term objectives (both financial and non-financial) we recommend a long-term, strategic asset allocation for your portfolio. With the long-term strategic asset allocation in place we then have the opportunity to overlay shorter-term, over/under weights to take advantage of potential apparent asset mis-valuations and market dislocations. This entire plan will be incorporated into the Investment Policy Statement we create for you.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
i. Asset Allocation There are a number of dynamics involved in making asset allocation decisions. Our approach to asset allocation involves a two-staged process.
Stage One: The first stage begins with an analysis and consideration of the client goals and objectives.
The purpose of this stage is to determine the appropriate allocation to short term, intermediate term and long term sub-portfolios intended to meet the client goals and objectives with similar time horizons.
To the extent that some client objectives have a short-term time frame or involve a significant cash flow requirement, we generally allocate a portion of client assets to a short-term cash flow and liquidity sub- portfolio. This sub-portfolio primarily holds cash and high quality fixed income investments taking into account each client's structure and tax considerations. Assets with higher expected returns and higher 5 levels of potential volatility (uncertainty) are appropriately associated with intermediate-term and longer-term client objectives. In those cases, intermediate-term and long-term sub portfolios are developed to meet these client goals and objectives using similar time horizons. Through this first stage we strive to appropriately size a series of sub-portfolios designed to meet specific client goals and objectives. We believe that this process allows for the allocation of risk in proper proportion to the time frame of client goals. This goals-based approach works to build durable portfolios that are designed to stand the test of both time and market volatility.
Stage Two: The second stage seeks to create an appropriate allocation of assets within each of the various sub-portfolios. ii. Investment Policy Creation, Monitoring and Updating We have created a comprehensive and thoughtful process to prepare detailed Investment Policy Statements (IPS) for our clients. In order to begin working on your portfolio as soon as possible, our team will complete an analysis of your current investment portfolio and draft an Executive Summary version of an IPS to outline our understanding of

account structures, investment goals and strategies. This first stage in developing the IPS includes the following:
•Outlining asset ownership and structure
•Reviewing current portfolio attributes and exposures concentrating on any out-sized positions or sources of risk on both an aggregated and individual portfolio level
•Understanding any constraints or restrictions that the portfolio(s) may be subject to
•Overview of goals, objectives, risk tolerances The Executive Summary serves as a launching point for a more comprehensive and detailed series of meetings and discussions with you. Typically, this discussion period may take place over the initial three to six months of our relationship. The resulting and fully developed IPS seeks to outline the following:
•A clear understanding of the investment goals and objectives of your portfolio(s) including income distribution targets and liquidity needs
•The parties who will participate in the development, implementation, management, and evaluation of your portfolio(s)
•Define and assign responsibilities among all parties involved
•Set limitations and define restrictions for the investment of your portfolio(s)
•The relevant investment horizon for which your portfolio(s) will be managed
•The basis of evaluating the investment results of your portfolio(s) including benchmarks
•A strategic, long-term asset allocation policy set within a goals-based framework
•The exposure limits to asset class, specific investments or types of investment
•Other considerations such as taxes, fees and general investment philosophy issues 6 b. Security, Strategy and Manager Selection (Selection of Other Advisers) For the majority of DIAL's clients, DIAL provides investment supervisory services using individual securities, separately managed portfolios and pooled investment vehicles, including, but not limited to, limited partnerships, international business companies, and hedge funds. Detailed information can be found about the partnerships and hedge funds in each of their private placement memoranda ("PPMs").
A rigorous due diligence and evaluation process is used to evaluate specific investments, investment strategies, investment managers and funds. We employ both quantitative and qualitative techniques to identify Investments and managers we believe are best qualified to meet our clients' objectives. To the extent clients are invested directly or indirectly in unaffiliated funds, the managers of such funds will have their own investment practices, and those independent investment practices will be described in each manager's Form ADVs or such funds' offering documents. With regard to its investment advisory services, DIAL's specialization is not in one given instrument or asset class, but rather in the ongoing process of: 1) Assessing our clients' objectives; 2) Developing an appropriate asset allocation to achieve those objectives and modifying that allocation when risks/opportunities are present in the markets; and 3) Evaluating investments and assessing where it is most appropriate to use active or passive strategies.
As part of our investment advisory services, we may recommend that you invest part or all of a portfolio in hedge funds which would be managed separately by hedge fund managers. After gathering information about your financial situation and objectives, we may recommend that you invest in a specific hedge fund program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the manager's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. On an ongoing basis we will monitor the manager's performance to ensure its management and investment style remains aligned with your investment goals and objectives.
c. Fund Management DIAL may serve as an investment manager to various international business companies or other hedge or private funds in which clients are solicited to invest. To the extent that DIAL advises clients to purchase interests in these private funds, or similar investment vehicles established by DIAL or an affiliate of DIAL, client assets invested in such IBCs or other types of private funds will generally be included in the total assets on which DIAL charges its regular investment management fee.
The respective offering memorandum for each of the private funds managed by DIAL or its affiliates would contain a detailed description of each fund's investment strategy and the associated investment risks, including material conflicts of interest with DIAL and its affiliates. These funds would be offered only to prospective investors who meet the qualification requirements of each respective fund pursuant to a private placement memorandum. An investment in such funds is speculative and involves a high degree of risk. The funds generally are not subject to regulatory restrictions or oversight. Opportunities for redemptions and transferability of interests in the funds are generally restricted so investors may not have access to their capital if and when it is needed. There is no secondary market for an investor's interest in the funds and none is expected to develop. Each fund's management and incentive fees/allocations (if applicable), and expenses, may offset trading profits. An investor should not invest in the funds unless the investor is prepared to lose all or a substantial portion of its investment.
7 DIAL may recommend to individual and institutional clients that they purchase shares of funds sponsored and/or advised by DIAL or an affiliate pending investment of assets or as part of their investment program. DIAL's recommendation of such funds could create a potential conflict of interest in that DIAL or an affiliate receives a management fee in connection with the management of such funds. Therefore, DIAL faces a potential conflict of interest in that it may have an incentive to recommend a fund which they manage over another vehicle that they do not manage. However, as previously mentioned, the following factors and policies mitigate such potential conflicts of interest:
•DIAL employees must act in the best interests of clients and in accordance with DIAL's fiduciary obligations to clients.
•In light of the nature of DIAL's business and client base, clients typically choose the investment vehicle utilized with respect to a particular mandate. Clients, along with other fund shareholders, bear a proportionate share of the expenses of those funds including, to the extent permitted by law, the management fee paid to DIAL or an affiliate. With respect to funds that pay distribution fees, clients may also bear a portion of the distribution fee.
2. Portfolio Aggregation & Reporting Services We offer our clients the ability to report on their investments in a variety of ways. We have the ability to provide reporting on all publicly traded investments you may own, whether that be the assets that we are directly managing or assets that you own in any type of investment or bank account. Additionally, our systems have been built to track and report on illiquid (non-publicly traded) investments, providing the capability to monitor the performance of alternative investment managers. We have the ability to report on virtually any level – from security level to portfolio level, from individual to family level. Our standard reporting package is customized to each client and can be modified on an ongoing basis.
C. Types of Investments We primarily offer advice on all types of investments including, but not limited to equity securities, warrants, government debt securities, corporate debt securities, commercial paper, municipal securities, investment company securities including mutual funds and ETFs, REITs, options contracts on securities and commodities, futures contracts on securities and commodities, and interest in partnerships investing in real estate, oil and gas interests, hedge funds, private equity, structured products, and others.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities or funds. You must provide these restrictions to our firm in writing.
D. Assets Under Management As of December 31, 2023, we provide continuous management services for $18,369,633 in client assets on a discretionary basis, and $1,716,830 in client assets on a non-discretionary basis.
8 E. Wrap Fee Program(s) A wrap fee program is an investment program where the investor pays one state fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. DIAL does not participate in any wrap fee programs.