Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
Form ADV Part 2A
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document is Form ADV Part 2A for Aspen Grove Capital and iCapital Advisors, outlining the Code of Ethics and potential conflicts of interest. It discusses employee investment guidelines, compensation structures, and the relationship between iCapital and underlying fund managers.
Metadata
- Subject
- Aspen Grove Capital, LLC; iCapital Advisors, LLC
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0098709
- Date
- —
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| iCapital | Business | Underlying Fund Managers/Sub-Advisers | iCapital has no discretion or control over Underlying Manager's or Sub-Adviser's decisions. |
| iCapital Securities, LLC | Business | Private Access Funds | iCapital Securities, LLC may receive a placement fee for placing 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 existence of placement fees could create a potential conflict of interest for iCapital Securities, LLC.
Legal Compliance
- Potential conflict of interest due to placement fees received by iCapital Securities, LLC for placing investors in Private Access Funds.
- Potential conflict of interest if registered investment advisers or placement agents are incentivized to recommend interests to investors where they might not otherwise make such recommendation.
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCompliance/ethics
Organizations 4
Aspen Grove Capital, LLCiCapital Advisors, LLCiCapital Securities, LLCPrivate Access Funds
Text Analysis
- Tone
- Informative
- Purpose
- To disclose potential conflicts of interest and ethical guidelines for employees of Aspen Grove Capital and iCapital Advisors.
- Significance
- This document outlines the Code of Ethics and potential conflicts of interest within iCapital and its related entities, particularly regarding employee investments and compensation from underlying fund managers.
File Info
- File Name
- EFTA01393220.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:15.223971
- DOJ Source
- View on DOJ