Illegal Activity
suspicious
Blackmail
none
Date
Unknown
Document Type
Form ADV Part 2A
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document is a Form ADV Part 2A for Annandale Capital and iCapital Advisors, LLC, outlining potential conflicts of interest related to iCapital's business practices, including fees paid by brokerage limited partners, valuation of fund assets, and educational programs for financial advisors. It also details iCapital's privacy policy regarding investor information.
Metadata
- Subject
- Annandale Capital, iCapital Advisors, LLC
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0039986
- Date
- —
Illegal Activity
- Severity
- suspicious
- Description
- The document describes potential conflicts of interest that could lead to unethical or illegal behavior, but does not explicitly describe illegal activity.
- Content Type
- first_hand
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| iCapital | business | investment advisers | iCapital involved with soliciting investment advisers to participate in iCapital offered funds and in performing diligence on such investment advisers with which to launch access vehicles. |
| iCapital Securities | employment | iCapital management persons | compensation for management persons is not based on any transaction-based compensation received by iCapital Securities (or its affiliates). |
| Fund | financial | Underlying Fund Manager or Sub-Adviser | Values of the Fund's assets shall generally be calculated by the Fund's administrator based on estimates provided by the applicable Underlying Fund Manager or Sub-Adviser. |
| iCapital | business | financial advisers | iCapital may offer educational and professional certification programs for financial advisers that recommend products included on the Institutional Capital Network platform. |
Red Flags 4
- Potential conflicts of interest related to iCapital's business practices.
- Fees paid by brokerage limited partners may incentivize an investor's registered investment adviser or adviser representative to recommend a Fund over other investments.
- Underlying Fund Manager or Sub-Adviser will have a conflict of interest in determining such valuations if the applicable Fund charges its fees based on the value of the Fund's investments, including any performance-based compensation charged by such Fund.
- The provision of educational programs may create a conflict of interest because the offering of such programs may incentivize the advisers that participate in such programming to recommend iCapital and interests in iCapital Private Access Funds over a manager or administrative agent who has not provided such educational opportunities.
Financial Information
Transactions:
- Limited partners in one or more of the Funds may elect to be treated as brokerage limited partners and in connection therewith, pay a larger management fee than limited partners that are not brokerage limited partners for reporting, administrative and other services provided by such brokerage limited partner's registered investment adviser or adviser representative.
Legal Compliance
- Potential conflicts of interest related to iCapital's business practices.
- Fees paid by brokerage limited partners may incentivize an investor's registered investment adviser or adviser representative to recommend a Fund over other investments.
- Underlying Fund Manager or Sub-Adviser will have a conflict of interest in determining such valuations if the applicable Fund charges its fees based on the value of the Fund's investments, including any performance-based compensation charged by such Fund.
- The provision of educational programs may create a conflict of interest because the offering of such programs may incentivize the advisers that participate in such programming to recommend iCapital and interests in iCapital Private Access Funds over a manager or administrative agent who has not provided such educational opportunities.
Raw Analysis JSON
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Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigation
Organizations 4
Annandale CapitaliCapital Advisors, LLCiCapital SecuritiesInstitutional Capital Network
Text Analysis
- Tone
- Professional
- Purpose
- To disclose potential conflicts of interest and privacy policies of iCapital Advisors, LLC.
- Significance
- This document outlines potential conflicts of interest related to iCapital's business practices and its privacy policy regarding investor information.
File Info
- File Name
- EFTA01355132.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:12.704628
- DOJ Source
- View on DOJ