Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
legal filing
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document is Form ADV Part 2A from iCapital Advisors, LLC, outlining the company's Code of Ethics and potential conflicts of interest. It discusses employee investment guidelines, compensation structures, and the management of underlying funds.
Metadata
- Subject
- Form ADV Part 2A
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0095709
- Date
- —
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| iCapital Advisors, LLC | business | Sub-Advisers of the Direct Investment Funds | iCapital provides a list of companies at which any of iCapital's related persons has a material financial interest to the Sub-Advisers. |
| iCapital Securities, LLC | business | 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. |
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 potential conflict of interest arising from iCapital Securities, LLC receiving placement fees for directing investors to certain Private Access Funds.
Financial Information
Transactions:
- Placement fees for investors in Private Access Funds
- Employee investments in the Funds
- Waiver or reduction of fees for investors, employees, and affiliates
Legal Compliance
- Potential conflicts of interest arising from compensation received by iCapital Securities, LLC for placing investors in Private Access Funds.
Raw Analysis JSON
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Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigation
Organizations 4
Third Lake CapitaliCapital Advisors, LLCiCapital Securities, LLCPrivate Access Funds
Text Analysis
- Tone
- Professional
- Purpose
- To disclose potential conflicts of interest and ethical guidelines for employees of iCapital Advisors, LLC.
- Significance
- This document outlines the Code of Ethics and potential conflicts of interest within iCapital Advisors, LLC, and its related entities.
File Info
- File Name
- EFTA01390997.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:06.336769
- DOJ Source
- View on DOJ