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 Form ADV Part 2A for iCapital Advisors, LLC, outlining the firm's Code of Ethics and potential conflicts of interest. It discusses employee investment guidelines, compensation structures, and the firm's responsibilities to its clients.
Metadata
- Subject
- iCapital Advisors, LLC - Form ADV Part 2A
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0093531
- Date
- —
Illegal Activity
- Severity
- suspicious
- Description
- The potential conflict of interest related to placement fees could incentivize recommending certain investments over others, which could be considered a breach of fiduciary duty.
- Content Type
- none
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| iCapital Securities, LLC | Placement | Private Access Funds | iCapital Securities, LLC may receive a placement fee as a result of its placement of certain investors in certain Private Access Funds. |
| Underlying Manager | Management | Fund | Each Underlying Manager or Sub-Adviser, as applicable, is responsible for making portfolio investments for any Fund it manages. |
Notable Quotes 2
Employees should not take inappropriate advantage of their position.
The spirit of the Code of Ethics is to discourage frequent trading in personal employee accounts.
Red Flags 1
- The existence of placement fees could create a potential conflict of interest. The prospect of receiving such compensation creates an incentive for iCapital Securities. LLC to place investors in the iCapital Private Access Funds from which it receives a placement fee over other investment vehicles from which it does not receive a placement fee.
Financial Information
Transactions:
- Personal investment in other private investment vehicles
- Portfolio investments for any Fund
- Placement of certain investors in certain Private Access Funds
Legal Compliance
- Potential conflict of interest due to placement fees received by iCapital Securities, LLC.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigation
Organizations 4
Georgetown University EndowmentiCapital Advisors, LLCiCapital Securities, LLCPrivate Access Funds
Text Analysis
- Tone
- Professional
- Purpose
- To disclose information about iCapital Advisors, LLC, including its Code of Ethics and potential conflicts of interest.
- Significance
- This document outlines the ethical guidelines and potential conflicts of interest for iCapital Advisors, LLC, which is important for investors to understand.
File Info
- File Name
- EFTA01389178.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:36.878393
- DOJ Source
- View on DOJ