TAG Associates is a leading multi-client family office and portfolio management services adviser
with approximately $8.1 billion of assets under management as of December 31, 2018. Formed in
1983, TAG has an experienced staff of approximately 68 people, including senior relationship
managers, portfolio management professionals, accountants, bookkeepers and administrators.
TAG is a registered investment advisor (“RIA”), a commodity trading advisor (“CTA”) and a
commodity pool operator (“CPO”). When the company was founded in 1983, the multi-client
family office was a relatively new and somewhat unproven concept. Over the years, TAG’s
independence, steadfast commitment to its clients’ success, and continued growth allowed it to
fine tune the process of managing wealth. Maintaining the wealth of this generation for future
generations is at the heart of the decision-making process.
TAG Services
On January 1, 2002, TAG Associates LLC acquired all the operating business assets of, and
succeeded to the business of, TAG Associates, Ltd (“TAG Ltd”). All references below to activities
prior to January 1, 2002 were performed by TAG Ltd. All activities described after January 1,
2002 are performed by TAG Associates LLC.
TAG offers its clients either a comprehensive package of services (such clients are
“Comprehensive Wealth Management clients”) or, on a stand-alone basis, portfolio management
services (such clients are “Portfolio Management clients”). Comprehensive Wealth Management
clients receive both portfolio management services as well as other non-investment financial
management services. All of the Adviser’s services are customized to the individual needs of
TAG’s clients. The services TAG provides are outlined in the attached Exhibit A (at the end of
this Item 4): "Summary of Client Services."
TAG Associates LLC provides investment management services and other financial advice and
services primarily to high net worth individuals. TAG also provides services to trusts, estates,
pension and profit-sharing plans, endowments, foundations and other business entities. It also
periodically assists its individual clients in negotiating significant transactions such as entering into
or continuing employment arrangements. TAG does not issue publications or other reports on a
subscription or other fee basis.
When providing Portfolio Management services to its clients, TAG serves as an overall portfolio
manager. Its services include evaluating a client’s financial situation and needs, setting
investment goals and objectives and formulating an asset allocation strategy. TAG also discusses
and assists the client in evaluating any investment restrictions that client prefers for his or her
portfolio, such as prohibiting investments in certain securities or industries. Once consensus has
been reached with the client, TAG selects the investment managers, monitors strategies and
managers, reports periodically (no less than quarterly) on the results of the portfolio and makes
change recommendations as necessary. In addition, TAG provides financial management
services, tax planning and compliance services and estate and trust planning. TAG has also
advised clients on derivative securities transactions such as collars, swaps, etc.
TAG’s assets under management as of December 31, 2018 totaled $8,054,450,000 of which
$290,910,000 is managed on a discretionary basis and $7,763,540,000 is managed on a non-
discretionary basis.
TAG-Managed Investment Entities
TAG Associates serves as the investment manager and TAG Portfolio Management Group LLC,
an affiliate, serves as the general partner or manager to a number of Funds of Funds (the “TAG
Funds) for its clients and third party investors.
All TAG Funds are exempt from registration under the Investment Company Act of 1940 (the
“Company Act”). For those Funds that are exempt companies under Section 3(c)(1) of the
Company Act, all investors must qualify as "accredited investors" within the meaning of
Regulation D under the Securities Act of 1933. For those Funds that are exempt companies under
Section 3(c)(7) of the Company Act, all investors must qualify as “Qualified Purchasers” under
the Company Act.
In 1999, TAG Ltd established the TAG Relative Value Client Fund, L.P. (the “Client Fund”). The
Adviser is the investment manager and an affiliate of the Adviser is the general partner. This
partnership is a "fund of funds." It allows TAG clients to participate in the underlying investments
of the Client Fund.
In 2000, the TAG Relative Value Fund, L.P. was established for investors who are not clients of
the Adviser. This partnership is identical to the Client Fund, above, other than that the Adviser and
its affiliate will receive fees and compensation for serving as investment manager and general
partner of this partnership. The assets of TAG Relative Value Fund, L.P. were combined with the
assets of the Client Fund as of January 1, 2015. Investors in TAG Relative Value Fund, L.P.
became Class B Limited Partners of the Client Fund and the existing investors of the Client Fund
became Class A Limited Partners.
In 2001, the TAG Relative Value Offshore Fund Ltd. was established for investors who are
offshore or tax-exempt. The Adviser is the investment manager of the Fund. Investors that are not
clients of the Adviser will compensate the Adviser for its investment management services.
In 2003, the TAG Master Relative Value Fund, LLC was reorganized to serve as a master fund to
its feeder funds. The Adviser is the investment manager and an affiliate of the Adviser is the
manager.
In 2005, the Adviser established the TAG Diversified Strategies Fund, L.P. of which the Adviser
is the investment manager and an affiliate of the Adviser is the general partner. This entity is a
"fund of funds". Investors that are not clients of the Adviser may invest in share classes that will
pay the Adviser certain fees for serving as the investment manager of this partnership.
In 2008, the TAG Distressed Debt Fund II, LLC was established. This entity is a "fund of funds."
The Adviser is the investment manager and an affiliate of the Adviser is the manager.
It allows investors to invest in certain underlying partnerships that the Adviser has identified as
attractive investments. Investors that are not clients of the Adviser will compensate the Adviser and
its affiliate for its investments management services. It is not accepting new capital.
In 2010, the TAG Distressed Debt Fund III, LLC was established. This entity is a "fund of
funds." The Adviser is the investment manager and an affiliate of the Adviser is the manager. It
allows investors (client and non-client) to invest in certain underlying partnerships that the
Adviser has identified as attractive investments. Investors that are not clients of the Adviser will
compensate the Adviser and its affiliate for its investment management services. It is not accepting
new capital.
In 2015 the TAG Yield Opportunities Fund, LLC was established. This entity is a “fund of funds.”
The Adviser is the investment manager and an affiliate of the Adviser is the manager. It allows
investors to invest in certain underlying partnerships that the Adviser has identified as attractive
investments. Investors that are not clients of the Adviser will compensate the Adviser and its
affiliate for its investment management services. It is not accepting new capital.
The Adviser and its affiliates do not charge the Adviser's clients that invest in any of the above
mentioned Funds any additional fees, or earn other compensation for serving as investment
manager, manager or general partner of such Funds. Clients of the Adviser pay for investment
management services based on separate agreements with the Adviser. In all cases, each investor
must meet the required relevant investor suitability standards.
The Adviser may, from time to time, consider offering interests in additional similarly structured
investment vehicles. This would provide the Adviser with an opportunity to present investment
opportunities to its clients in which they would not otherwise participate. The dual-class structure
of the investment vehicles affords the Adviser an opportunity to be compensated for its efforts in
identifying, structuring and organizing such investment vehicles.
TAG as Subadvisor of a Series of the SALI Multi-Series Fund
In 2014, the TAG Associates Insurance Fund Series Interest (the “TAG Fund Series”) of the SALI
Multi-Series Fund, L.P was established. SALI Fund Management, LLC is the investment manager
of the Fund. TAG Associates LLC is the investment subadvisor of the “TAG Fund Series”. This
entity is a "fund of funds". It allows insurance companies selling private placement life insurance
to participate in the underlying investment vehicles of the TAG Fund Series on behalf of their
policyholders. Investors pay a management fee directly to the investment manager. The investment
manager remits a portion of that fee to the investment subadvisor as per a subadvisory agreement
between the investment manager and the investment subadvisor. Policyholders who are existing
fee-paying clients of TAG Associates will pay only the portion of the management fee allocable
to the investment manager. Clients of the Adviser pay for investment management services based
on separate agreements with the Adviser. It is not accepting new capital.
TAG Associates Holdings, LLC
The Principal Owner of TAG is TAG Associates Holdings, LLC, a Delaware limited liability
company, an entity majority owned by Gary L. Fuhrman and David Basner.
[Exhibit A appears on the next three (3) pages.]
TAG ASSOCIATES, LLC
Summary of Client Services, 2018
Form ADV, Part 2 – Advisory Business (Item 4)
Exhibit A
PORTFOLIO MANAGEMENT
Planning ImplementationMonitoring
Set investment goals &
objectives
Select investment managers Produce portfolio reports
Formalize an
appropriate asset
allocation strategy
Design investment reporting
system
o Typically monthly or
quarterly
Provide benchmarks to
measure performance
o On an absolute dollar
return basis
o On a relative basis
versus similar
managers & indexes
Consider changes in strategy,
managers, etc.
FINANCIAL MANAGEMENT
Consider asset/liability
oriented issues
Design customized financial
reporting system
Produce financial reports
o Need for
liquidity, etc.
o Focus on highlighting
tax issues, liquidity
needs, etc.
Update versus projections, etc.
Asset cash flow
considerations
Establish banking/credit
relationships
Communicate results to
appropriate third party advisors
Plan for large tax
payments, etc.
Review hedging options
o One large block
of stock, etc.
TAX RELATED
Identify tax savings
opportunities
Manage IRS and state tax
audits
Consider changes in:
Prepare periodic tax
projections
Periodically review estate
plan
o Tax laws
Prepare tax returns Investment related
o Investment products
o Interfamily driven o Business relationships
o Residence driven o Employee benefit plans
o Transaction driven o Family relationships
ADMINISTRATIVE/
CONTROLLERSHIP
Consider asset/liability
management techniques
Select advisors/systems Consider changes in:
o Insurance
alternatives
Pay bills/Collect receipts
o New products/services
o Custodial
alternatives
Handle domestic staff
o Personal circumstances
o Cash management
systems
Negotiate house
closing, mortgages
o Professional
relationships
Determine optimum
information flow
Manage “the process” Revisit “the process”
o Which
professionals?
o Right People
o What information? o Right Information
o In what time
frame?
o Right time
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TAG offers its clients two alternative sets of services and fee arrangements: (1) Comprehensive
Wealth Management services, and (2) Portfolio Management services. Fees may vary from the
stated fee schedule and are subject to negotiation.
TAG is objective in its recommendations regarding the selection and retention of investment
managers and other professionals when choosing investment products and developing strategies
for our clients. TAG chooses from the entire universe of available talent.
TAG receives no fees, directly or indirectly, from investment managers or investment funds in
which its clients invest. Nor does it accept any indirect payments from other professionals it may
hire on behalf of its clients. Clients will, however, pay investment advisory fees to investment
managers in addition to fees payable to TAG for non-affiliated fund investments, as well as any
customary brokerage and related fees.
Separate management and performance-based fees are charged to investors who are not clients of
the Adviser who invest in some of the funds of funds it manages. Additional information on these
TAG Funds is available in Item 4.
TAG charges an annual retainer for its Comprehensive Wealth Management services under which
the client is provided with portfolio management, tax and/or financial advisory services. The fee
for tax and for advisory services is based upon an analysis of the volume and complexity of the
client's financial affairs. Comprehensive Wealth Management clients may also pay a fee that is
based on a percentage of assets under management for portfolio management services. In some
cases a fixed fee is negotiated for all services. TAG’s stated minimum fee for Comprehensive
Wealth Management services is $150,000 per year. The specific manner in which fees are charged
is established in each client’s written agreement with TAG.
The annual portfolio management fee for stand-alone Portfolio Management clients is based on
a percentage of assets under management. This fee is applied to currently investable assets only.
TAG's stated minimum fee for stand-alone Portfolio Management services is $100,000 per
year. The stated fee schedule, when calculated based on assets under management, is as
follows:
Assets under Management
First $10 Million
Annual Fee
1.00%
Next $10 Million 0.75%
Assets above $20 Million 0.50%
Payment of TAG’s fees may be made directly by the client or by the custodian, if any,
holding the client's securities and funds. If made by such custodian, TAG will send the
client a copy of any bills sent to a custodian for payment reflecting the specific manner in
which the fee was calculated, and in turn, such custodian will send a statement of fees paid
out of the client's account to the client. Fees and payment terms for special projects are
negotiated individually.
This management fee is payable quarterly during the quarter in which the fees are incurred.
(For example, the bill sent to a client on February 15 relates to the quarter beginning
January 1 and ending March 31.) The fee is based on the net asset value of the assets being
managed on the closing of the last day of the preceding quarter (for example, the fee on
February 15 is based on the net asset values on December 31 of the preceding quarter).
Billings for partial quarters, in a start-up mode or in a termination mode are pro-rated based
on the number of days during which the services are rendered. Under the Portfolio
Management Agreement, the Adviser does not receive any other fees or payments, either
from the client or any third party, in connection with providing such services.
Non-Client Investors in TAG Managed Funds of Funds
Separately, TAG and TAG Portfolio Management Group charge investors who are not
clients of the Adviser management and performance-based fees on some of the funds of
funds it manages. These TAG Funds are identified in Item 4. Investors that are not clients
of TAG Associates with investments in TAG Diversified Strategies Fund and the TAG
Relative Value Funds pay fees quarterly in advance, unless other fee arrangements have
been made. Investors that are not clients of the Advisor in the TAG Distressed Debt Funds
and the TAG Yield Opportunities Fund pay quarterly in arrears. See Item 6 for a further
explanation of the performance-based fees charged to investors that are not clients of TAG
in such TAG Funds.
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broker- dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions).
Item 6 - Performance-Based Fees and Side-By-Side Management
Performance-based fees are fees based on a share of capital gains on, or capital
appreciation of, the assets of an investor. Investors (non-clients of the Adviser) of the
following funds pay performance-based fees:
TAG Relative Value Client Fund, L.P.: Class B Limited Partners (“Incentive
Allocation”)
TAG Relative Value Offshore Fund, Ltd.: share classes AA and BB (“Incentive
Fees”)
TAG Distressed Debt Fund II, LLC and TAG Distressed Debt Fund III, LLC: Class
B Members (“Carried Interest”)
These performance-based fees are subject to hurdle-rates and high-water marks. TAG
structures any performance or incentive fee arrangements in conformity with the
requirements of Section 205(a)(1) of the Investment Advisers Act of 1940. Since these
investors are not TAG clients, they also pay management fees as stated in the offering
documents of such TAG Funds.
As noted in the offering documents (Private Placement Memorandums) of the TAG Funds,
performance-based fees may create an incentive for the General Partner or the Investment
Manager of each such Fund to make investments that are riskier or more speculative than
would be the case in the absence of performance-based fees. Before making an investment
in any such Fund, each prospective investor (client or non-client of TAG) is provided with
a copy of the Private Placement Memorandum that detail the fee arrangements, risk factors
and potential conflicts of interest applicable to such TAG Fund, including risks associated
with performance fees charged by underlying managers of such TAG Funds.
Item 7 - Types of Clients
TAG Associates LLC provides investment management services and other financial advice
and services primarily to high net worth individuals. TAG also provides services to trusts,
estates, pension and profit-sharing plans, endowments, foundations and other business
entities.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
INVESTING IN SECURITIES AND OTHER ASSETS INVOLVES RISK OF LOSS THAT CLIENTS SHOULD BE PREPARED TO BEAR.
In formulating investment strategies, capital preservation is TAG’s paramount
consideration. Portfolio Information - Data Sources
TAG currently utilizes computer software and databases in evaluating various investment
products as follows:
PerTrac 7.3.1 (PerTrac Financial Solutions) is a statistical analysis/asset allocation software
product.
Morningstar Mutual Fund provides qualitative and quantitative information/data on
approximately 65,000 + mutual funds, ETFs, Money Market Funds and indices. This
information can be accessed and analyzed through the PerTrac system.
Through PerTrac, TAG also maintains internal databases of qualitative and quantitative
information covering over 90,000 records of investment Limited Partnerships, Registered
Investment Advisor management organizations, and indices.
The majority of this information is obtained through various money manager direct data
vendors and on-line services, e.g., HFR & EurekaHedge. However, in some instances TAG
obtains information directly from various investment limited partnerships and managed
account managers.
To perform valuations of assets, TAG uses the Advent Axys Portfolio software as its
brokerage accounting/performance analysis system. Advent Custodial Data (ACD)
downloads through Dataport provide custodial prices and reconciliation for most of the
brokerage accounting. Remaining pricing information not available through ACD is
provided through Advent/Interactive Data Corp. Index information is also provided
through Advent/Interactive Data Corp and Bloomberg.
TAG utilizes a Bloomberg Terminal to access financial and other news in real time format,
as well as business-related data, access analytics, and research tools. TAG believes it is one
of the most comprehensive sources of daily business and financial information available.
BCA is a leading provider of global macro research and independent investment strategy
research. TAG receives BCA’s Global Investment Strategy reports via email.
Investment Strategies
In general, TAG Associates serves as an overall portfolio manager. The Adviser’s services
include setting investment goals and objectives and formulating an asset allocation strategy
for our clients based on his or her financial situation and needs, together with establishing
investment objectives and restrictions (if any). There are situations where investment
restrictions required by a particular client may increase the portfolio’s risk and these are
discussed with the client before implementation. Once consensus has been reached with
the client, TAG recommends the investment managers, monitors the strategies and
managers, reports periodically (no less than quarterly) on the results of the portfolio and
makes change recommendations as necessary. Certain clients also engage TAG to provide
financial management services, tax planning and compliance services and estate and trust
planning as part of offering overall wealth management services to those clients.
In establishing investment goals for TAG clients, we consult financial newspapers and
magazines, research materials prepared by others, corporate rating services and the
portfolio information data sources discussed above. Where appropriate to a particular
client’s investment goals, TAG engages in classic security analysis of evaluating the
expected performance of a particular security or type of investment. To implement TAG’s
investments strategies, clients are introduced and may engage traditional third-party
managers of stocks and/or bonds, including mutual funds. Long-term investment
recommendations often include subscriptions to hedge funds or private equity managers,
including TAG Funds managed by the Adviser and discussed in Item 4 above.
On occasion, TAG recommends short term purchases of securities sold within a year;
trading in securities sold within 30 days; short sales; margin transactions; option writing,
including covered options, uncovered options or spreading strategies.
Suitability Considerations
As a firm, TAG constantly seeks to identify portfolio managers whose management style,
policies and practices are suitable for its clients in general. Prior to selecting any manager,
TAG conducts due diligence on his or her portfolios and performance, background and
experience. Once selected as suitable for TAG Associates’ clients, in general, we monitor
their portfolio management and performance, including, without limitation, any material
changes in policies, procedures and performance.
After TAG’s assessment of a client’s financial situation and investment objectives, it
recommends a number of investment managers we believe suitable for that client’s
circumstances. As specified above, these third-party managers include mutual funds,
traditional managed account managers of stocks and bonds, hedge fund managers and/or
private equity managers. Once the client invests with the investment manager(s), TAG
monitors the account to verify that its client’s selected investment strategy is being
implemented and tracks the manager’s overall performance. This includes reviewing a
particular client’s account to avoid, for example, undue concentration in a particular
security. TAG also assesses whether adjustments are needed due to changes in the
particular client’s circumstances or the manager’s ability to accommodate client
investment goals and restrictions.
In some instances, TAG may determine that a particular portfolio manager no longer meets
its investment criteria or can no longer effectively manage funds for the kinds of clients it
services. If that were to occur, TAG would recommend that some or all of its clients
redeem their investments in such manager, recognizing that redemption may be limited due
to various restrictions on withdrawals such fund may have in place. Nonetheless, a client
may elect to remain with that particular manager, despite the Adviser’s recommendation
to redeem.
Risk of Loss
Most hedge fund documents, including those of the TAG Funds and other investment Funds
recommended by TAG, state: “Investments in Funds are speculative, illiquid and involve
a high degree of risk.”
The multi-manager approach recommended by TAG to its clients is designed to lessen
portfolio volatility by investing with managers who employ diverse investment styles,
including, without limitation, managers who have the ability and mandate to engage in short
sales, which generally have the potential to be profitable in down markets. Prior to investing
in any manager, TAG reviews with its client the various strategies that may be employed
by such third party manager it recommends, as well as the risks of such investments. TAG
provides its clients with the offering documents that describe their investment strategies
and risks.
Item 9 - Disciplinary Information
None
Item 10 - Other Financial Industry Activities and Affiliations
TAG is registered with the National Futures Association (“NFA”) as a commodity trading
advisor and commodity pool operator.
In addition, David Basner, Stanley Pantowich, Gary L. Fuhrman, Jeffrey Tumolo, John
Pantowich, Jonathan Bergman, Ted Katramados, Robyn Transport, Neil Shapiro, and
Jorge Gonzalez are registered as associated persons of TAG. Each is also registered as an
associated person with an affiliate, TAG Portfolio Management Group, LLC, which is
registered with the NFA as a commodity pool operator and commodity trading advisor.
GF Capital Asset Advisors, LLC (“GF Capital”), is under common ownership with TAG
Associates. GF Capital, a registered investment adviser, and its affiliated investment
entities provide “investment supervisory services” to their clients, which consist of private
investment- related funds. GF Capital was formed in 2005, but did not commence
operations as a registered investment adviser until February 2012. GF Capital is controlled
by its manager and 100% owner, GF Capital Management & Advisors, LLC. Additional
information concerning GF Capital Asset Advisors, LLC (CRD #160144) can be found on
the Securities & Exchange Commission’s website at www.adviserinfo.sec.gov.
As detailed in Item 4, above, TAG provides products or services other than investment
advice to clients.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A client or prospective client may obtain a copy of our Code of Ethics (the “Code”) by
contacting David Basner or Jorge Gonzalez at 212-275-1500.
TAG Associates LLC (“we” or “us”) has adopted a Code of Ethics (the “Code”) for all
supervised persons of the firm discussing its high standard of business conduct and
fiduciary duty to its clients. The Code includes provisions relating to protecting the
confidentiality of client information, a prohibition on insider trading, a prohibition on
rumor mongering, restrictions on the acceptance of significant gifts and the reporting of
certain gifts and business entertainment items, and personal securities trading procedures,
among other issues. All supervised persons at TAG must acknowledge the terms of the
Code of Ethics annually, or as amended.
As a firm we impose no general prohibition on the security transactions of our associated
persons and employees other than those imposed by our insider trading policies and
applicable securities law and regulations. However, we do prohibit any TAG employees
from investing in public companies in which our clients maintain influential or controlling
positions. Accordingly, it is permissible for an individual member of our investment
committee to invest personally in a fund or place personal funds with an advisor that we
are also recommending to our clients. Any such investment or arrangement would be made
at arms' length and on the same terms as are available at the time to any other client
investors. TAG employees that are members of the investment committee or otherwise
meet certain investor suitability requirements may also invest in the TAG Funds described
in Item 4.
The Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of TAG employees will not interfere with (i) making decisions in the best
interest of our advisory clients and (ii) implementing such decisions while, at the same
time, allowing employees to invest for their own accounts. Under the Code certain classes
of securities have been designated as exempt transactions (e.g., mutual funds), based upon
a determination that these would not materially interfere with the best interest of our clients.
Nonetheless, because the Code of Ethics in some circumstances permits employees to invest
in the same securities as clients, there is a possibility that employees might benefit from
market activity by a client in a security also held by an employee. Investments by both clients
and TAG employees in a private placement, however, should not result in benefit to a TAG
employee to the disadvantage of our clients. The Code requires monthly monitoring of
employee trades (other than investments in mutual funds) to reasonably prevent conflicts of
interest between TAG and its clients.
We do not effect any principal transactions for client accounts. “Principal transactions” are
generally defined as transactions where an adviser, acting as principal for its own account
or the account of an affiliated broker-dealer, buys from or sells any security to any advisory
client.
Brokerage Discretion
TAG recommends brokers based on its analysis of their performance and how such
performance compares to those of other brokers. TAG receives no fee or economic
inducement of any sort from such brokers for making such a recommendation.
Recommendations are limited to those brokers who have been reviewed by TAG. Criteria
such as performance and years of operation are important in determining fit or quality when
making such recommendations.
Research and Other Soft Dollar Benefits
TAG Associates LLC does not receive research or other products or services other than
execution from a broker-dealer or a third party in connection with client securities
transactions (“soft dollar benefits”).
Aggregating Securities Transactions for Client Accounts; Directed Brokerage
TAG primarily serves as the investment portfolio manager for its clients and generally does
not directly or indirectly execute trades (see Item 4). However, TAG does from time to time
execute trades for its clients. If trades in the same security are to be executed
contemporaneously for two or more clients the Managing Director placing the trades will
aggregate those trades.
TAG permits clients to direct TAG as to the choice of broker(s) for transactions on their
behalf. Client-directed brokerage may result in TAG being unable to obtain the most
favorable execution of transactions for those clients. For example, client-directed brokerage
may mean such clients pay higher brokerage commissions because TAG is unable to
aggregate orders with those of other clients to reduce transaction costs and may mean that
such clients receive less favorable prices.
Other Potential Conflicts
Due to legal and investment business considerations and as set forth in TAG’s Code of
Ethics, in managing any client account TAG employees may not act on material nonpublic
information learned by them through these relationships or otherwise. Accordingly, TAG
may suspend effecting transactions for client accounts with respect to a security when it
becomes aware of material nonpublic information affecting such security.
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Accounts
Client Performance Reviews
Client portfolio accounts are reviewed periodically by a Managing Director and/or other
qualified personnel in charge of a particular client’s account. Portfolio changes can result
from a change in a client’s personal needs, macro-economic changes, change in laws,
availability of new investment products, and superior or inferior performance by a
recommended or available investment advisor or product.
A Managing Director is primarily responsible for the review process associated with his
or her clients' portfolio accounts. The number varies among such directors but averages
10-20 clients per individual Managing Director. Some Managing Directors are part of
TAG’s Investment Committee. Investment Committee members are also primarily
responsible for investment decisions related to the TAG Funds described in Item 4.
Nature/Frequency of Reports
All clients receive monthly brokerage reports from the account custodians. TAG urges
clients to carefully review these brokerage statements and call us with any questions.
TAG's Comprehensive Wealth Management clients receive periodic (generally, quarterly)
reports that may include balance sheets, income statements, cash flows and tax projections
in addition to portfolio reporting. In some cases, monthly reports are generated. In rare, and
in agreed upon situations, the above-named reports may be generated on a semi-annual or
annual basis.
TAG's Portfolio Management clients receive either monthly or quarterly reports reflecting
overall portfolio performance as well as performance of the individual investment
managers. Performance is reported in absolute dollar terms and in relative terms. That is,
the portfolio and its component investment managers are compared in relation to agreed
upon indexes and other like styled investment managers that form part of such client’s
portfolio of investments.
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TAG from time to time enters into formal referral agreements with introducers providing
for payment to such introducer of a portion of any fee income TAG receives from such
referral clients. The arrangements fully comply with the requirements of Rule 206(4)-3
under the Investment Advisers Act.
Once TAG and the referred client enter into an investment advisory relationship, such
client is treated in the same manner as other clients similarly situated, based on the category
of services the client selects. Despite TAG’s ongoing obligation to pay referral fees, it does
not differentiate among clients in providing personalized investment advisory services
based on how such client became a client, including, without limitation, the fees TAG
charges any client, which are based on the extent of the services it provides. Thus, no
conflicts of interest arise as a result of any client referral.
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TAG maintains custody of client cash and/or securities in accounts of clients who have
authorized TAG to implement certain types of client transactions. TAG also maintains
custody for certain other accounts due to the fact that supervised persons act as trustees or
other types of fiduciaries for those accounts and as such have authority to withdraw assets
or otherwise disburse funds without the client’s specific consent. Under Securities and
Exchange Commission (“SEC”) rules custody is imputed to TAG.
TAG has retained Grant Thornton LLP to conduct an examination of client accounts in
which TAG has custody of client assets. As a result, Grant Thornton LLP files a Form
ADV-E with the Securities and Exchange Commission (“SEC”) as part of TAG’s filing
with the SEC. Additional information can be found at www.adviserinfo.sec.gov.
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains their investment assets. TAG urges
clients t o review carefully such statements and compare such official custodial records to
the account statements that TAG may provide to them. TAG’s statements may vary from
the custodial statements based on accounting procedures, reporting dates or valuation
methodologies of certain securities.
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As detailed in Item 4, TAG provides overall portfolio management advice to our clients and
does not generally exercise discretion over client brokerage accounts. In some instances our
clients have given us discretion over their brokerage accounts. Investment advice is provided
pursuant to a Management Agreement between the Client and TAG. With respect to the
clients for which TAG has discretion over their account, the clients grant TAG the authority
to enter into agreements, including agreements with brokers, and take all steps to fully
manage the Client’s assets in accordance with the Client’s investment strategy.
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With the exception of those securities held by the TAG Funds that TAG manages, as detailed
in Item 4, TAG does not exercise voting authority over its clients’ proxies. Clients retain the
responsibility for receiving and voting proxies for any and all securities maintained in their
portfolios. Occasionally, TAG may provide advice to clients regarding the voting of proxies
related to private placement investments (e.g., hedge funds) made directly by the client.
While the securities evidencing the private equity investments made by the TAG Funds are
not typically the subject of proxies, there could be certain circumstances where we, having
discretionary authority over the accounts of the TAG Funds, may be asked to vote the
securities of such Funds on restructuring or other corporate matters. We will ensure that a
record of each securities position held by each TAG Fund is maintained and, where any such
vote is to occur, we will ensure that we receive all relevant information, disclosure materials
and such proxies or consents as are necessary for us to be able to cast votes in a timely
manner.
We will also determine whether there is, or appears to be, a material conflict of interest that
could influence the voting decision in a manner that would be adverse to the interests of a
TAG Fund. If we determine that there is no material conflict of interest, then we will make
the voting determination and take the required voting action. If we determine that, due to a
conflict of interest, we are not capable of making an independent determination as to the
voting decision, we will appoint an independent third party to make the applicable voting
decision.
A TAG affiliate serves as general partner of each TAG Fund. As a result, each TAG Fund is
aware of how we voted with respect to its securities.
We will provide a copy of our policies and procedures concerning the voting of client
securities to clients upon request. Requests may be made to Jorge Gonzalez at 212-275-1500.
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Registered investment advisers are required in this Item to provide certain financial
information or disclosures about the Adviser’s financial condition since it has custody over
certain client accounts; discussed in Items 4 and 15. TAG Associates LLC believes it has no
financial commitments that would impair its ability to meet contractual and fiduciary
commitments to clients, and has not been the subject of a bankruptcy proceeding.
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