DFX Intelligence

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W••••••••• C••••••• L••

Former SEC-registered adviserFormer SEC adviser1 private funds· Dayton, Nevada

Former SEC-registered adviser, based in Dayton, Nevada, reporting $365M of regulatory assets.

Composed from this adviser's Form ADV classification, location and filed figures.

As of 2021-08-09 · the latest Form ADV filing; advisor counts and movement are read from IAPD daily

Last reported RAUM: $365M
Advisors: Not applicable
Net advisor flow, 12 months: Not applicable
RAUM change, last fiscal year: +26%
Private clients: 0.0% of RAUM

Advisors Advisor movement Where the RAUM sits

As of 2021-08-09 · the latest Form ADV filing; advisor counts and movement are read from IAPD daily

Why this matters

Reported RAUM grew +26% over the last fiscal year, to $365M.
2021-08-09
RAUM a year earlier $289MRAUM now $365M

Every filed figure, and the identifiersCRD 269920 · SEC 801-106557 · 26 filingsShow

CRD 269920SEC 801-106557First filing on the tape Aug 13, 2015, latest Aug 9, 2021IAPD

RAUM

$365M

reported, Item 5.F

Discretionary

100%

of RAUM

Private clients

0.0%

$0 individuals and HNW

Advisors

registered through the firm on IAPD

RAUM per advisor

n/a

derived; firm RAUM over IAPD count

Employees

1 advisory (5.B.1)

Offices

beyond the principal office

Private funds

$28.9M gross assets

History

26 filings and snapshots on the tape

RAUM$365M as of Mar 24, 2021

Mar 29, 2016$0 then

HNW client RAUM: $1.0M

State-registered IARs (5.B.3)1 as of Mar 24, 2021

Mar 29, 20160 then

Employees (5.A)2 as of Mar 24, 2021

Mar 29, 20164 then

Private funds1 as of Mar 24, 2021

Mar 29, 20161 then

RAUM +26% over the last fiscal year+256% a year over threeIARs 5 to 1

Practice profile

derived from the filing of Aug 9, 2021; every figure names its basis

RAUM per advisor: $365MderivedRAUM over IAPD advisors; not a book size
Clients per advisor: unknownderivedindividual and HNW clients (5.D) over advisors
Average HNW client: unknownderivedHNW RAUM over HNW clients
Average account: $60.9MderivedRAUM over accounts (5.F.2.f)
Discretionary: 100%derivedof RAUM
Institutional: 92%derivedpensions, charities, corporations, government, insurance, banks, other advisers
Employees per advisor: 1.0derivedItem 5.A over advisors
Advisors per office: 1.0derived1 offices incl. principal (1.F.5)
RAUM growth, one year: +26%derivedbetween the last two annual amendments
Advisor growth, one year: -80%derivedItem 5.B.3 between annual amendments
Client growth, one year: unknownderived
Compensation: percentage of assets, performance-basedreportedItem 5.E
Advisory activities: portfolio management for individuals, portfolio management for pooled vehiclesreportedItem 5.G
Custody: $28.9M, 1 clientsreportedItem 9.A
Ownership: no PE, bank or public-company owner found on Schedule Aderived
Advisor book size: not public; not estimatedreported

Also answered yes on Form ADV

buys or sells securities as principal to or from clients (8.A.2)
has discretionary authority over which securities are bought or sold (8.C.1)
receives research or other products from a broker-dealer, soft dollars (8.E)
has custody of client cash or bank accounts (9.A.1.a)
has custody of client securities (9.A.1.b)
an independent public accountant performs a surprise examination (9.C.1)

Where the RAUM sits

Form ADV Item 5.D, latest filing

Insurance companies$337M92%
Pooled investment vehicles$28.9M7.9%

Individual clients: n/areported
HNW clients: n/areported
Pension plan clients: n/areported
Charitable clients: n/areported
Accounts: 6reported
Financial planning clients: n/areported
Wrap fee programs: noreported
Custody of client assets: $28.9M for 1 clientsreported
Compensation: % of AUM, performancereported
Class basis: absent from the latest SEC rosterderived

Advisors registered through the firm

0 on IAPD today, longest tenure first

No representative is registered through this CRD on IAPD.

Advisor movement

Left, latest

none on the tape

Joined, latest

none on the tape

Every departure Every arrival

Private funds

2 reported on Schedule D 7.B.(1)

Fund	Type	Gross assets	Owners	First reported
W••••••••• G••••• M•••• F••• U•• L•••	Hedge Fund	$28.9M	2	Mar 28, 2020
W••••••••• G••••• M•••• M••••• F••• C•••••• L•••no longer reported	Hedge Fund	$25.3M	3	Aug 13, 2015

Owners and control persons

Schedule A and B, latest filing

M••••••• S••••••• T•••••• · President, Cco & Ciocontrol
since 06/2015 · owns 50% to 75%

Entity owners

T•• D•••••• C••••••• A• I••••••••• E••••••• · Owner
direct · owns 25% to 50%

Related persons

Schedule D 7.A

T•• D•••••• C••••••• A• I••••••••• E•••••••
real estatey

Offices

Schedule D 1.F, the 25 largest

No branch office listed.

What changed

consecutive filings, newest first

Advisory employees · 2 to 1
Mar 24, 2021 to Jun 21, 2021
Employees · 2 to 1
Mar 24, 2021 to Jun 21, 2021
Accounts · 3 to 6
Jan 4, 2021 to Mar 24, 2021
Advisory employees · 5 to 2
Jan 4, 2021 to Mar 24, 2021
Assets in custody · $28.6M to $28.9M
Jan 4, 2021 to Mar 24, 2021
Employees · 6 to 2
Jan 4, 2021 to Mar 24, 2021
HQ city · SAN FRANCISCO to DAYTON
Jan 4, 2021 to Mar 24, 2021
HQ state · CA to NV
Jan 4, 2021 to Mar 24, 2021
State-registered IARs · 5 to 1
Jan 4, 2021 to Mar 24, 2021
Discretionary RAUM · $289M to $365M
Jan 4, 2021 to Mar 24, 2021
Pooled vehicle RAUM · $28.6M to $28.9M
Jan 4, 2021 to Mar 24, 2021
RAUM · $289M to $365M
Jan 4, 2021 to Mar 24, 2021
Accounts · 2 to 3
Sep 23, 2019 to Mar 28, 2020
Assets in custody · $25.3M to $28.6M
Sep 23, 2019 to Mar 28, 2020
Discretionary RAUM · $111M to $289M
Sep 23, 2019 to Mar 28, 2020
Pooled vehicle RAUM · $25.3M to $28.6M
Sep 23, 2019 to Mar 28, 2020
RAUM · $111M to $289M
Sep 23, 2019 to Mar 28, 2020
Assets in custody · $26.0M to $25.3M
Mar 29, 2019 to Sep 23, 2019
Discretionary RAUM · $65.0M to $111M
Mar 29, 2019 to Sep 23, 2019
Pooled vehicle RAUM · $26.0M to $25.3M
Mar 29, 2019 to Sep 23, 2019
RAUM · $65.0M to $111M
Mar 29, 2019 to Sep 23, 2019
Assets in custody · $28.0M to $26.0M
Oct 22, 2018 to Mar 29, 2019
Discretionary RAUM · $48.0M to $65.0M
Oct 22, 2018 to Mar 29, 2019
Pooled vehicle RAUM · $28.0M to $26.0M
Oct 22, 2018 to Mar 29, 2019
RAUM · $48.0M to $65.0M
Oct 22, 2018 to Mar 29, 2019
State-registered IARs · 1 to 5
Sep 7, 2018 to Sep 26, 2018
Advisory employees · 4 to 5
Aug 3, 2018 to Aug 24, 2018
Assets in custody · $48.0M to $28.0M
Aug 3, 2018 to Aug 24, 2018
State-registered IARs · 0 to 1
Jun 21, 2018 to Aug 3, 2018
Accounts · 3 to 2
Apr 2, 2018 to Jun 21, 2018
Advisory employees · 2 to 4
Apr 2, 2018 to Jun 21, 2018
HNW clients · 2.0 to unset
Apr 2, 2018 to Jun 21, 2018
Pooled vehicle clients · 2 to 1
Apr 2, 2018 to Jun 21, 2018
Assets in custody · $7.1M to $48.0M
Apr 2, 2018 to Jun 21, 2018
Employees · 3 to 6
Apr 2, 2018 to Jun 21, 2018
Discretionary RAUM · $8.1M to $48.0M
Apr 2, 2018 to Jun 21, 2018
HNW RAUM · 1011110.0 to unset
Apr 2, 2018 to Jun 21, 2018
Pooled vehicle RAUM · $7.1M to $28.0M
Apr 2, 2018 to Jun 21, 2018
RAUM · $8.1M to $48.0M
Apr 2, 2018 to Jun 21, 2018
HQ city · ROSWELL to SAN FRANCISCO
Mar 22, 2018 to Apr 2, 2018

Signals

5 dated events

••• Locked
Aug 9, 2021 · Control person left · inference
••• Locked
Mar 24, 2021 · Control person joined · fact
••• Locked
Jan 4, 2021 · Control person left · inference
••• Locked
Mar 28, 2020 · RAUM change · derived
••• Locked
Aug 13, 2015 · First SEC registration · fact

Across DFX

shared identifiers only, never a name match

No identifier-backed link to the venture, private equity, family office or sponsor graphs.

Provenance

Form ADV: SEC filing data 2011 to 2024 and the monthly roster 2025 onreportedadviserinfo.sec.gov
Advisors: IAPD individual compilation feed, dailyreportedadviserinfo.sec.gov
Class: Former SEC-registered adviserderiveda rule over Items 5.D and 7.A
RAUM per advisor: n/aderivedfirm RAUM over the IAPD count; not a book size
Loaded: Sep 14, 2026