FEG Investment Services, LLC (referred to hereafter as the “Manager”) was formed in 2016 and
is a wholly-owned subsidiary of Fund Evaluation Group, LLC (“FEG”), a registered investment
advisor. The Manager provides investment advisory services to two clients, an unregistered
private fund structured as a “fund of one” (FOO) and to FEG Select, LLC (Select), an
unregistered private fund (together the “Funds”). The Manager provides discretionary advisory
services to Select.
Fund of One The FOO is structured as a single client fund. The Manager will carefully review the fund’s
investment needs and objectives to determine which products are most suitable for the fund.
Recommendations can vary depending on the investment strategy. Although the goal of all
recommendations or investment management by the Manager is to increase investment
performance and reduce risk, no guarantees can be made. The Manager has the authority to
implement the investments on behalf of the fund, however, the fund retains the final authority to
invest in any underlying investment fund.
FEG Select FEG Select is a Delaware series limited liability company capable of investing across a broad
range of asset classes. FEG Select contains a number of separate series, or cells, for individual
strategies, as identified in FEG Select’s operating agreement. Each series is treated as a separate
legal entity. Each series invests into either an existing commingled fund (“Underlying Fund”) or
separately managed account (“SMA”), to avoid cross-contamination. The minimum investment
into FEG Select is $1 million, subject to waiver by FEG. FEG Select is available for investment
by FEG’s qualified discretionary and non-discretionary clients. FEG Select is structured as a
3(c)7 exempt private investment vehicle suitable for investors that are both “accredited
investors” and “qualified purchasers,” each as defined in the FEG Select subscription agreement.
The Manager serves as the managing member of FEG Select and each series. The Manager also
has overall responsibility for managing and administering the business affairs and investment
objectives of FEG Select. The Manager outsources some or all of its responsibilities.
FEG hires various third-party managers (“Underlying Managers”) to manage FEG Select’s
assets. Each Underlying Manager will generally have full authority for making the investment
decisions and overseeing the execution of such investment decisions. For each Series structured
as a SMA, the Underlying Manager(s) are considered Sub-Advisers of the Manager. FEG is
responsible for identifying and overseeing the Underlying Manager and Sub-Advisers for FEG
Select.
The comingled funds within FEG Select were formed to pool investments of investors for the
purpose of investing assets with various funds managed by Underlying Managers that are
selected by FEG Investment Services. Each Underlying Fund has its own prospectus or private
placement memorandum (“PPM”), which includes important disclosures with respect to
investment related risks, market considerations, fees and other potential conflict issues, and other
disclosure as are determined appropriate by the Underlying Managers. The SMA’s primarily
make investments directly in certain securities selected by a Sub-Adviser.
Each Series is managed only in accordance with its own investment objectives and restrictions
and is not tailored to any particular individual investor (“Investor”). Since FEG Investment
Services does not provide individualized advice to Investors, Investors should consider whether a
particular Series meets their investment objectives and risk tolerance prior to investing. The
Manager does not permit Investors in the FEG Select to impose limitations on the investment
activity described in the Underlying Funds’ offering documents. Information about each
Underlying Fund can be found in its offering documents, including its prospectus, PPM and
other offering documents.
As of December 31, 2018, the Manager has $808,408,781 discretionary assets under
management and $431,954,104 non-discretionary assets under management.
All investors should be aware that past performance is no guarantee of future results. Clients
should refer to the applicable Funds governing documents for further information.
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For the FOO, the Manager charges a fixed fee per year.
FEG Select For FEG Select, LLC, a 0.12% management fee shall be charged annually to all investors that do
not have an investment advisory agreement in place with FEG. This fee will be waived for all
clients with existing investment advisory agreements with FEG. Fees are based on asset value
and are paid quarterly in arrears. All fees charged by the Manager are subject to negotiation. In
addition to the management fee, the Funds also bear their own organizational and operating
expenses. This includes expenses for audit, legal, fund administration, custody, compliance and
tax-related fees.
Sub-Adviser Fees:
For the SMA’s, the Manager has sub-advisory agreements in place with multiple investment
advisers to manage the assets of certain Series of FEG Select.
In accordance with the sub-advisory agreements, each respective SMA Series pays the sub-
advisers as follows:
Series Name Sub-adviser Name Annual Mgmt. Fee Performance Fee FEG Select Structured US
Equity Series
Pacific Investment
Management Company
(PIMCO)
.10%
.15%of excess
return
FEG Select Structured
International Equity Series
PIMCO .12% .15%of excess
return
FEG Select Structured
Emerging Markets Equity
Series
PIMCO .25% .15%of excess
return
FEG Select Core Fixed Income
Series
Barrow, Hanley,
Mewhinney & Strauss
.200% of the first $200 million
.075% over $200 million
.146% - If total AUM of series
is below $350 million
None
FEG Select Core Bond Plus
Series
Doubleline Capital .25% of the first $250 million
.23% of the next $250 million
.20% of the next $250 million
.18% of the next $250 million
.16% of the next $1 billion
.15% over $2 billion
Fee schedule subject to $100
million minimum AUM
None
Underlying Fund Fees
In addition to the management fee described above, the Underlying Funds are generally subject
to their pro rata portion of any fees charged by the Underlying Funds. These fees typically
include a management fee and in some cases an incentive fee arrangement. In addition, each
Underlying Fund will generally pay the costs and expenses of the Underlying Fund, including:
the management fee; organizational expenses; liquidation expenses; expenses related to audits of
the Underlying Funds; preparation of tax returns; costs of preparing and distributing financial
statements and other reports to and other communications with the partners. Investors are
strongly encouraged to carefully read the offering documents of Underlying Managers for full
disclosure relating to fees and expenses.
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Currently, FEG Investment Services, LLC does not have any clients with performance-based fee
arrangements. However, certain investors in Select may pay performance-based fees for their
investments and are paid directly to the Underlying Managers and/or Sub-adviser. Investors are
strongly encouraged to carefully read the offering documents of Underlying Managers for full
disclosure relating to fees and expenses.
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The clients of FEG Investment Services are the Funds. There are currently two types of funds –
FOO and Select.
FOO is structured as single investor fund. The fund is designed to develop a customized portfolio
of hedge and private fund investments consistent with the fund’s investment strategy. The goal
of such a fund is to protect the client from co-investor risk while allowing transparency and
customization. Co-investor risk can be described as the risk created by other investors in a
pooled investment vehicle, such as lack of ability to withdraw from the pool of investments due
to limited control.
FEG Select, LLC is a Delaware series limited liability company capable of investing across a
broad range of assets. It is structured as a 3(c)-7 exempt private investment vehicle suitable for
accredited investors and qualified purchasers. FEG Select will contain a number of separate
series for individual strategies, as identified in FEG Select’s operating agreement. Under
Delaware law, each series will be treated as a separate legal entity. Each series will invest into
either an existing commingled fund or separately managed account, to avoid cross-
contamination.
Investors in the Funds primarily include institutional investors (e.g. endowments, community
foundations, corporate, higher education, charitable, healthcare, etc.) and some individuals and
family offices meeting the terms of the exemption under which the Funds operate and wishing to
invest in accordance with a particular Fund or Series investment objective.
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Fund of One The Manager will manage the Fund’s investment activities in a manner that is consistent with the
Fund’s investment strategy.
FEG Select Underlying Fund Manager/Sub-Adviser Selection:
FEG Select’s primary investment objective will be to allow investors to gain exposure to select
fund managers at considerably lower investment minimums than would be required for a direct
investment in any Underlying Fund or SMA. The Manager will accomplish this by leveraging
our sourcing advantages and employing an ongoing consistent diligence approach. The SMA’s
investment objective is to provide its investors access to portfolio management by a variety of
Sub-Advisers selected by FEG Investment Services.
For Underlying Funds, each Underlying Fund Manager will generally have full authority for
making the investment decisions and overseeing the execution of such investment decisions. The
Manager is responsible for identifying and overseeing the Underlying Fund Manager.
The objective of Select is to maintain a portfolio of traditional and alternative asset strategies that
clients can utilize to meet their individual investment objectives. Select allocates its assets among
various series depending on the type on asset categories, such as US equity, emerging markets
equity, fixed income, private equity, etc. These series are structured as commingled funds or
separately managed accounts that are managed by third-party investment managers.
FEG’s Investment Philosophy The Manager will capitalize on the experience of FEG and its various departments. FEG’s
investment philosophy serves as the basis for the investment solutions the Manager provides its
clients and is predicated upon the following four philosophical tenets:
• Independence: Clients come first. Objective investment decisions empower the pursuit of
better outcomes over time.
• Ardency: The disciplined application of a rigorous due diligence process uncovers
opportunities with the potential to preserve value and provide growth that may not be
obvious or available to other market participants.
• Prudence: A sound investment program is built upon deliberate portfolio design
commensurate with risk tolerance, market opportunities, and competitive advantages.
• Alignment: Comprehensive alignment between principals (client, advisor) and component
parts (managers, custodians) improve the outlook for long-term success.
Manager Selection
FEG believes investment firms that meet its quality threshold on organizational structure,
personnel, investment philosophy, and performance must also demonstrate key attributes to be
included on the recommended list. FEG’s research process uses the following six tenets:
• Conviction: Strong belief in the investment philosophy; willing to put investment
decisions ahead of business decisions; invests alongside of clients, aligning interests
• Consistency: Stability of organizational structure, composition of the investment
professionals, and the investment philosophy and process
• Pragmatism: Understand core strengths and have the ability to capitalize and sustain their
competitive edge
• Investment Culture: Strong ethical foundation; passionate about investing; proper
organizational and compensation structure; culture pervades across organization
• Risk Control: Not blind risk takers, but risk conscious; acknowledge mistakes; robust and
effective risk mitigation
• Active Return.: Ability to identify and profit from investment opportunities; successful
track record
Due Diligence
Before FEG rates an investment manager’s strategy as recommended, it assesses the manager
and strategy on rigorous quantitative and qualitative factors, its research team evaluates
managers based on the quality of the firm, strategy, philosophy, investment process,
professionals, and performance. Once managers and strategies meet FEG’s initial requirements,
further due diligence is performed, which includes in depth contact with investment
professionals. Depending on the strategy, FEG’s initial and on-going due diligence process may
vary. More complex strategies require more extensive due diligence, while simplistic strategies
in highly regulated structures, such as index funds, may require less rigor. FEG’s Investment
Policy Committee determines the extent of required due diligence for each type of manager and
strategy. FEG’s investment professionals meet on a regular basis to discuss the changing market
conditions and manager performance.
Risk of Loss and Other Risks Investing in securities and other financial instruments involves risk of loss that clients should be
prepared to bear. Summarized below are certain important risks for clients and prospective
clients to consider.
•
Equity Securities Investing: The underlying fund managers’ investments in equity
securities may involve substantial risks and may be subject to wide and sudden
fluctuations in market value, with resulting fluctuations in the relevant underlying fund’s
profits and losses
. The values of equity securities, such as common stocks and preferred
stocks, may decline due to general market conditions that are not related to a specific
company, such as: real or perceived adverse economic conditions; changes in the general
outlook for corporate earnings; and changes in interest or currency rates or ad verse
investor sentiment generally. The value of equity securities may also decline due to
factors that affect a particular industry or industries, such as workforce shortages or
increased production costs and competitive conditions within an industry.
•
Derivative Securities Investing: Some of the underlying fund managers may use options,
swaps, futures contracts, forward agreements and other derivatives contracts.
Transactions in derivative instruments present risks arising from the use of leverage
(which increases the magnitude of losses), volatility, the possibility of default by a
counterparty and illiquidity. Use of derivative instruments for hedging or speculative
purposes by the Underlying Fund Managers could present significant risks, including the
risk of losses in excess of the amounts invested.
•
Investment in Emerging Markets: In addition to the risks associated with investments
outside of the United States, investments in emerging markets (i.e., developing countries)
may involve additional risks. Emerging markets generally are not as efficient as those in
developed countries. In some cases, a market for the security may not exist locally, and
transactions will need to be made on a neighboring exchange. Volume and liquidity
levels in emerging markets are lower than in developed countries. When seeking to sell
emerging market securities, little or no market may exist for the securities. In addition,
issuers based in emerging markets are not generally subject to uniform accounting and
financial reporting standards, practices and requirements comparable to those applicable
to issuers based in developed countries, thereby potentially increasing the risk of fraud or
other deceptive practices. Furthermore, the quality and reliability of official data
published by the government or securities exchanges in emerging markets may not
accurately reflect the actual circumstances being reported.
•
Currency Risk: In trading on non-U.S. exchanges and markets, the investments will be
subject to the risk of fluctuations in the currency exchange rate between the local
currency and the U.S. dollar and to the possibility of exchange controls. It is not
anticipated that an underlying manager will hedge any international currency exposure
their investments may have.
•
Trading Decisions Based on Underlying Manager Judgment: The success of each
underlying manager in which the Funds invest depends in large part on the ability of the
underlying manager to accurately assess the markets in which it trades. An accurate
assessment of financial markets depends on a complex analysis of a number of financial
and legal factors. No assurance can be given that an underlying manager will be in a
position to assess the nature and magnitude of all material factors having a bearing on the
markets in which it trades, or that an underlying manager will accurately assess the
impact of all factors of which it is aware.
•
Reliance on the Sub-Adviser and its Personnel: Under the applicable sub-advisory
agreement in respect to certain series within FEG Select, a Sub-Adviser has complete
discretion in selecting portfolio investments on behalf of that series. The success of a
series depends, to a great extent, on a Sub- Adviser's ability to identify favorable
investment opportunities and to effectively allocate the assets of the Fund among such
opportunities. Accordingly, an investor’s success will depend substantially on the skill
and acumen of key employees of that Sub-Adviser. If a Sub- Adviser or any Sub-
Adviser's key employees should cease to participate in that series' business, the ability to
select attractive investments and manage its portfolio could be impaired. In addition, to
the extent a sub-advisory agreement is terminated for any reason, either by the applicable
Sub-Adviser or the applicable general partner, there is no assurance that any replacement
sub-adviser engaged by the general partner will have equivalent experience, skill or
resources as the existing Sub-Adviser.
•
Recently Organized Fund, Limited Operating History: Select is a recently formed entity
that has no independent operating history upon which a prospective investor can evaluate
its likely performance.
•
Illiquid Securities of Underlying Investments: The underlying funds in which the Fund
invests may be unregistered, and interests therein are subject to legal or other restrictions
on transfer. It may be impossible for the Fund to withdraw its interests in such
underlying funds when desired or to realize their fair value in the event of such
withdrawals. Certain underlying funds may permit withdrawals only on a semi-annual,
annual, or less frequent basis or be subject to “lock-ups” (where investors are prohibited
from withdrawing their capital for a specified period following investment in such fund)
and/or “gates” (where withdrawal at any given withdrawal date is restricted to a specified
percentage of the underlying fund’s assets). The Manager has no control over the
liquidity of the underlying funds and depends on the underlying fund managers to
provide valuations as well as liquidity in order to process repurchases.
•
Multiple Levels of Fees and Expenses: By investing in underlying managers indirectly
through the Funds, the investor bears asset-based fees and expense allocations at the
Funds level, as well as asset-based and performance-based fees and expense allocations
at the underlying manager level. Moreover, an investor in the Funds bears a proportionate
share of the fees and expenses of the Funds including, among other things, organizational
expenses, operating costs, and administrative fees, and indirectly, similar expenses of the
underlying managers. Thus, an investor in the Funds may be subject to higher operating
expenses than if they invested in an underlying manager directly or in a fund that did not
utilize a “fund of funds” structure.
•
Security Selection Risk: The value of an individual security and, similarly, the value of
an investment in that security, may rise or fall. FEG’s investment processes for a
particular strategy may favor specific securities, industries or sectors that underperform
investments in other securities, industries, sectors, or the market generally.
•
Valuation of the Fund’s Interests: Securities in which the underlying fund managers
invest may not have a readily ascertainable market price and will be valued by those
firms. Valuations of the securities could prove in hindsight to have been wrong, and at
times by significant amounts. Although prior to investing in any underlying funds, FEG
will conduct a due diligence review of the valuation methodology utilized by such funds,
no assurances can be given that FEG will be given access to necessary aspects of the
underlying manager’s systems, that such due diligence review will ascertain whether
accurate valuations will be provided by such funds to FEG, that the underlying
investment funds will comply with their own internal policies or procedures for keeping
records or making valuations, or that the funds’ policies and procedures and systems will
not change without notice to the Fund. Moreover, FEG will not generally have sufficient
information in order to be able to confirm or review the accuracy of valuations provided
by underlying fund managers.
•
Management Risk: Actively managed strategies are subject to management risk. The
underlying fund managers apply investment techniques and risk analyses in making
investment decisions, but there can be no guarantee that these techniques will produce the
desired results. Additionally, the securities selected by the portfolio managers of the
underlying funds may underperform the markets in general, the account’s benchmark and
other accounts with similar investment objectives. FEG is not be able to control the
investments or operations of the underlying funds. An underlying fund manager may
employ investment strategies that differ from its past practices and are not fully disclosed
to FEG and that involve risks that are not anticipated by FEG. Some managers may have
a limited operating history and some may have limited experience in executing one or
more investment strategies to be employed for its fund. Furthermore, notwithstanding
FEG’s risk monitoring of the underlying manager and its funds, there is no guarantee that
the information and reports given to FEG with respect to the underlying fund’s
investments will not be fraudulent, inaccurate, or incomplete.
•
Data Sources Risks: FEG uses external software applications to analyze performance
attribution and to assist in investment decision making or investment research. As a
result, if information that FEG receives from a third-party data source is incorrect, FEG
may not achieve the desired results. Although FEG has found the third-party data sources
to be generally reliable, FEG typically receives these services “as is” and cannot
guarantee that the data received from these sources is accurate.
•
Technology and Cyber Security Risks: The Manager depends heavily on
telecommunication, information technology and other operational systems, whether the
Manager’s or those of others (e.g., custodians, fund administrators, transfer agents and
other parties to which the Manager outsources the provision of services or business
operations). These systems may fail to operate properly or become disabled as a result of
events or circumstances wholly or partly beyond the Manager’s control. Further, despite
implementation of a variety of risk management and security measures, the Manager’s
information technology and other systems, and those of others, could be subject to
physical or electronic break-ins, unauthorized tampering or other security breaches,
resulting in a failure to maintain the security, availability, integrity and confidentiality of
data assets. Technology failures or cyber security breaches, whether deliberate or
unintentional, including those arising from use of third-party service providers, could
delay or disrupt our ability to do business and service our clients, harm our reputation,
result in a violation of applicable privacy and other laws, require additional compliance
costs, subject us to regulatory inquiries or proceedings and other claims, lead to a loss of
clients and revenues or financial loss to our clients or otherwise adversely affect our
business.
•
Risks Related to Regulation: Laws and regulations affecting our business change from
time to time. We cannot predict the effects, if any, of future legal and regulatory changes
on our business or the services we provide.
•
Risks Related to Conflicts of Interest: Various conflicts of interest are discussed
throughout this document. The officers and employees of FEG are required to devote
their time to the activities of the Funds as may be reasonably required to further the
business affairs and activities of the Funds. FEG is involved in other business ventures
and may organize or become involved in other business ventures in the future. Neither
the Funds nor any investor will share in the risks or rewards of FEG that are derived from
such other ventures. Such other ventures, however, will compete for the time and
attention of such agents of FEG and might create other conflicts of interest. In addition,
underlying managers may trade for accounts other than the Funds and may have an
incentive to favor those accounts over the Funds as they may have investments in those
accounts or receive greater compensation for managing them than they do for managing
the Funds’ investment. Similarly, FEG currently manages other accounts and may have
an incentive to favor those accounts over the Funds as it may have investments in those
accounts or receive greater compensation for managing them than they do for managing
the Funds. Please review this information carefully and contact us if you have any
questions.
•
Risk Related to Funds Not Registered: The client may invest in funds that are not
registered as investment companies under the Investment Company Act and, therefore,
the client will not have the benefit of various protections afforded by the Investment
Company Act with respect to its investment in underlying funds. In addition, some
underlying fund managers will not be registered as investment advisers under the
Advisers Act in reliance on certain exceptions from registration under that Act. In such
cases, underlying fund managers will not be subject to various disclosure requirements
that would apply to registered advisers. As an investor in the underlying funds managed
by fund managers that are not registered as investment advisers, the client will not have
the benefit of certain of the protections of the Advisers Act.
Clients should refer to the applicable fund governing documents for further information
concerning risks.
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FEG Investment Services, LLC is affiliated with the following entities that all share the same
principal address at 201 East Fifth Street, Suite 1600, Cincinnati, Ohio 45202:
• Fund Evaluation Group, LLC- a federally registered investment adviser
• FEG Investors, LLC-a federally registered investment adviser
• FEG Private Investors, LLC-a federally registered investment adviser
• FEG POF LLC-the general partner of the FEG Private Opportunities Fund, L.P.,
FEG Private Opportunities Fund III, L.P. and FEG Private Opportunities Fund
IV, L.P.
• FEG POF II LLC-the general partner of the FEG Private Opportunities Fund II,
L.P.
• FEG Absolute Access Fund LLC- a federally registered investment company
• FEG Absolute Access Fund I LLC-a federally registered investment company
• FEG Directional Access Fund LLC- Effective January 24, 2018, an unregistered
investment company
• FEG Directional Access TEI Fund LLC- Effective January 24, 2018, an
unregistered investment company
• FEG Private Opportunities Fund, L.P.-an unregistered private fund of funds
• FEG Private Opportunities Fund II, L.P.-an unregistered private fund of funds
• FEG Private Opportunities Fund III, L.P.- an unregistered private fund of funds
• FEG Private Opportunities Fund IV, L.P.- an unregistered private fund of funds
• FEG Private Opportunities AIV, LLC- a Delaware limited liability company
• FEG Private Opportunities II AIV, LLC- a Delaware limited liability company
• FEG Private Opportunities III AIV, LLC- a Delaware limited liability company
• FEG Select, LLC- an unregistered private fund
Conflicts of Interest Disclosure
FEG Investment Services, LLC has established a Conflicts of Interest policy to help
mitigate potentially perceived conflicts as a result of some directors or officers who may
also serve as officers or directors of affiliated entities. Some of our investment
professionals, officers and employees provide other services to affiliates of the Manager
and their clients. In addition, our personnel are involved in cross marketing opportunities
with our affiliates.
The Manager receives no compensation from investment managers of the underlying
funds. Occasionally, certain employees of the Manager are invited to speak at a
conference or other educational events sponsored or hosted by investment managers. In
such cases, employees may accept complimentary admission to the events. Additionally,
on occasion certain employees are asked to participate on the Advisory Board of the
underlying funds and may have related travel and accommodation expenses paid by the
respective Advisory Board.
Allocation Policy As a matter of policy, FEG seeks to fairly and equitably allocate investment opportunities
among its clients. FEG will maintain records of which clients have expressed an interest
in private placement investment opportunities and are eligible to investment in such
opportunities (“Eligible Clients”), as well as which clients have been offered and have
participated in private placement investment opportunities. FEG will generally seek to
allocate the investment opportunity in the full amount requested by each Eligible Client.
Where such allocation is not feasible, such as due to the capacity limitations of the
investment, FEG will allocate the investment opportunity pro rata among all Eligible
Clients, unless FEG determines in good faith that specific factors and applicable
restrictions necessitate an allocation other than pro-rata. In the event that more than one
client (including any of the FEG’s employees) is eligible to invest in a private placement
investment opportunity under consideration by FEG, the firm will seek to allocate the
investment opportunity in a fair and equitable manner after consideration of relevant and
applicable factors, which may include but are not limited to:
• Client’s investment profile
• Client’s risk tolerance
• Client’s target allocations
• Concentration risk
• Client’s investment restrictions
• Transaction sourcing
• Any negotiated contractual provisions
• Investment strategy
• Client’s available capital
• Client’s liquidity needs
• Size of the investment and capacity constraints
• Pre-existing relationships with a manager or fund
• Discretionary allocation decisions by the fund manager
• Availability of other, similar investments
• Legal or tax considerations
• Regulatory restrictions
• Offering terms and other constraints and restrictions relating to or imposed upon the
investment, or relating to or imposed by the Client
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General
The Manager maintains a Code of Ethics as required by applicable SEC rules. The
Manager’s Code of Ethics describes the firm's fiduciary duties and responsibilities to
clients, requiring employees to put client interests ahead of their own and disclose actual
and potential meaningful conflicts of interest. The Code of Ethics incorporates our
insider trading policies and personal trading policies that are described in greater detail
below. All officers, partners and employees of the Manager are deemed to be “Access
Persons” and are subject to the Code of Ethics. Access Persons are required to report any
violation of the Code of Ethics promptly to our Chief Compliance Officer.
A complete copy of our Code of Ethics is available upon request to the Chief Compliance
Officer at the Manager’s principal address.
Policy on Insider Trading
Our Code of Ethics includes the firm's policy prohibiting the use of material non-public
information (MNPI). Our policies require our employees to immediately report the
receipt of potential MNPI to the compliance and legal department. We do not typically
receive MNPI. However, if we receive such information, we follow appropriate
procedures to establish a restricted or watch list. Our Compliance Department must
review and approve a transaction in an issuer on the restricted list.
Personal Trading Policy
Access Persons of the Manager may buy or sell securities for their personal accounts
identical to or different than those recommended to clients. It is the express policy of the
Manager that no person employed by the Manager shall prefer his or her own interest to
that of an advisory client or make personal investment decisions based on the investment
decisions of advisory clients.
The Manager requires all Access Persons to provide annual securities holdings reports
and quarterly transaction reports to the Manager's Chief Compliance
Officer. Additionally, the Manager requires such Access Persons to obtain approval from
the Chief Compliance Officer prior to investing in any IPO's, private placements (limited
offerings), or Exchange Traded Products (ETP’s) in excess of $10,000 (other than certain
broad based index ETP’s).
The Manager requires that all employees must act in accordance with all applicable
Federal and State regulations governing registered investment advisory practices. The
Manager’s Chief Compliance Officer shall determine whether or not the Code of Ethics
has been violated and recommend disciplinary action where appropriate.
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For FOO, FEG’s Consultants, with support from FEG’s Research team, share the
responsibility of reviewing underlying funds’ performance. The primary responsibility of
account review lies with the lead Consultant for the client. FEG’s Research team is
responsible for the ongoing monitoring of managers of the underlying funds included in
the FOO.
For Select, the Manager measures the progress of the total account, as well as each
underlying fund in the client’s portfolio. The fund is reviewed for compliance with the
investment guidelines and restrictions outlined in its governing documents. Additionally,
the Manager conducts ongoing due diligence on the underlying fund managers and the
subadvisors managing assets for separately managed accounts.
The fund administrators for FOO and Select will send monthly statements reflecting the
activity/transactions and performance of the underlying fund managers.
FEG’s Research team seeks to conduct quarterly conference calls with applicable
investment managers of the underlying funds, designed to provide quality control
measures by comparing performance-driven factors, such as security and sector selection,
with present market conditions.
Required disclosure information pertaining to the underlying investment managers,
recommended by, but not affiliated with FEG or the Manager, are described in detail in
each respective manager’s Form ADV Part 2A or equivalent disclosure documents, and
should be obtained from those respective advisers selected by the client.
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FEG Investment Services, LLC is deemed to have custody over FEG Select, LLC as the sponsor
of the fund. In compliance with SEC regulations, the Manager is subject to an annual audit and
distributes its audited financial statements to all limited partners within 180 days of the end of its
fiscal year as required. The Manager encourages investors to carefully review statements from
their custodians.
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FEG Investment Services, LLC does not have discretionary authority to manage securities on
behalf of FOO.
For Select, the Manager’s discretionary authority varies based on the investment advisory
agreement between FEG and its clients. Both, discretionary and non-discretionary FEG clients
are able to make investments in Select. Pursuant to the investment advisory agreement for FEG’s
discretionary clients, the Manager generally has full authority to select the investable series on
behalf of those FEG clients. For FEG’s non-discretionary clients, the Manager makes
recommendations to those FEG clients but does not have authority to choose the investable series
on their behalf. The Manager has full discretion to hire the various third party underlying
managers to manage FEG Select’s assets. Each underlying manager will generally have full
authority for making the investment decisions and overseeing the execution of such investment
decisions. The Manager is responsible for identifying and overseeing the underlying manager.
Investors should refer to the applicable governing documents of FEG Select and underlying
managers for full information.
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The Manager has the authority to exercise the voting rights of any securities held by the Funds.
Typically, the Manager votes in accordance with its proxy voting policy and procedures as
further described below.
Proxy Voting Policy and Procedures
The Manager’s proxy voting policy is to vote proxies in the best long-term economic
interests of the Fund without regard to its own interests or the interests of their affiliates.
Copies of FEG Investment Services’ proxy voting policy and its voting record are
available upon request to the Chief Compliance Officer at 513-977-4400.
Each Underlying Manager, including the Sub-Adviser, has the authority to exercise voting rights
of any securities within the Underlying Funds.
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FEG Investment Services, LLC has no financial commitment that impairs its ability to meet
contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy
proceeding.
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