ASSURED INVESTMENT MANAGEMENT LLC


A. Describe your advisory firm, including how long you have been in business. Identify your
principal owner(s).
BlueMountain, a Delaware limited liability company, is an investment adviser registered with the SEC. The firm has been in business since 2003. As of March 20, 2020, BlueMountain and its Relying Adviser (as defined below) have approximately 120 employees, primarily located in New York, as well as in London. BlueMountain has approximately $14,806,543,0001 in regulatory assets under management. BlueMountain serves as an investment adviser to pooled investment vehicles (“Fund Clients”), special purpose vehicles for collateralized loan obligations (“CLOs”), and institutional accounts (“Institutional Accounts,” and, together with Fund Clients and CLOs, “Advisory Clients”) that are primarily domestic and foreign limited partnerships, domestic limited liability companies, trusts and foreign companies. BlueMountain generally provides investment management and supervisory services to its Advisory Clients on a discretionary basis. Investments by Fund Clients typically are made through a master-feeder structure, with an affiliate of BlueMountain serving as general partner of Fund Clients organized as limited partnerships, and BlueMountain serving as investment adviser to both the Fund Client that invests through the master fund and the master fund itself. With respect to Fund Clients organized as foreign companies, in some cases a majority of the board of directors of such entities are BlueMountain personnel. Institutional Accounts are generally organized as limited partnerships with an affiliate of BlueMountain serving as the general partner of the Institutional Account, or as foreign companies with a majority of the board of directors of such entity comprised of BlueMountain personnel, and may be structured as separately managed accounts (“SMAs”). Such Institutional Accounts include other subsidiaries of AGL (as defined below). Advisory Clients are generally neither registered under the Securities Act of 1933, as amended, nor registered under the Investment Company Act of 1940, as amended. Accordingly, interests in such Advisory Clients are offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States or in offshore transactions. No offer to sell interests in these Advisory Clients is made by the descriptions in this Brochure. Please see Item 7 of this Brochure for more information with respect to BlueMountain’s clients. Blue Mountain Capital Partners (London) LLP (“BlueMountain London”) is an affiliate of BlueMountain and serves as adviser to BlueMountain, primarily with respect to issuers based in Europe, and is compensated by BlueMountain for its services. BlueMountain London is registered with the Financial Conduct Authority. BlueMountain London is a “relying adviser” (“Relying Adviser”), and, as such, it is not, and is not required to be, independently registered with the SEC. Please refer to Items 10.B and 10.C for additional information related to BlueMountain’s Relying Adviser. BlueMountain has a sub-advisory agreement with BlueVirgo Capital Management, LLC (“BlueVirgo”), pursuant to which BlueVirgo serves as an adviser to BlueMountain with respect to a limited number of tax liens and related investment products. BlueVirgo was previously a relying adviser of BlueMountain. 1 Calculated as of December 31, 2019. BlueMountain CLO Management, LLC (“BMCLO”) serves as the collateral manager to certain collateralized loan obligations (the “BMCLO CLOs”). BlueMountain has entered into a services agreement and a secondment agreement with BMCLO whereby BlueMountain provides certain services associated with the management of BMCLO CLOs in exchange for a services fee. BMCLO is registered as an investment adviser with the SEC. BlueMountain Fuji Management, LLC (“BlueMountain Fuji”) serves as the collateral manager to certain collateralized loan obligations (each, a “Fuji CLO”) and is wholly owned (directly or indirectly) by Advisory Clients. BlueMountain has entered into a services agreement and a secondment agreement with BlueMountain Fuji pursuant to which BlueMountain provides certain services associated with the management of Fuji CLOs in exchange for a services fee and a secondment fee. BlueMountain Fuji is registered as an investment adviser with the SEC.
Principal Ownership
In October 2019, Assured Guaranty US Holdings Inc., a Delaware corporation (“AGUS”), purchased 100% of the outstanding equity interests of the BlueMountain Companies. The day-to-day operations of BlueMountain’s investment management business are led by Andrew Feldstein in his capacity as Chief Executive Officer and Chief Investment Officer of BlueMountain. AGUS is a wholly-owned subsidiary of publicly traded Assured Guaranty Ltd. (NYSE: AGO), a limited company organized under the laws of Bermuda (“AGL” and, together with its subsidiaries other than the BlueMountain Companies and their subsidiaries, “Assured Guaranty”). Further information related to Assured Guaranty is provided in Item 10.
B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a
particular type of advisory service, such as financial planning, quantitative analysis, or market
timing, explain the nature of that service in greater detail. If you provide investment advice only
with respect to limited types of investments, explain the type of investment advice you offer, and
disclose that your advice is limited to those types of investments.
BlueMountain is a diversified asset manager specializing in providing advisory services with respect to investments in a broad array of instruments, among them corporate, government and municipal bonds, credit derivatives (including credit default swaps), public equities (including “new issues” as described, and subject to the limitations set forth, in Rules 5130 and 5131 of the Financial Industry Regulatory Authority), private equities, loans (both publicly and privately traded, including private non-recourse loans supported by publicly traded collateral or project financings), real estate related assets, privately negotiated investments in various industries including healthcare, specialty finance and infrastructure, equity derivatives, collateralized debt obligations, collateralized loan obligations, appraisal claims, insurance-linked securities, mortgages, forex, interest rate derivatives, commodities, convertible bonds and other asset-backed securities and asset-backed financing arrangements. Credit and equity derivatives relate either to individual reference entities or to baskets or portfolios of reference entities (including levered or de-levered tranches of such portfolios or baskets). BlueMountain’s advisory services also include advice regarding using interest rate derivatives (including futures, swaps and swaptions) and government securities to hedge interest rate risk and spot and forward foreign currency contracts to hedge currency exposures. BlueMountain generally provides such advisory services on a discretionary basis.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of
clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. The advisory services provided by BlueMountain to its Advisory Clients are tailored to the investment objectives, investment strategy and investment restrictions, if any, as set forth in the governing documents of Advisory Clients and/or the investment management agreement entered into by BlueMountain with such clients. With respect to Fund Clients, except as noted below, BlueMountain typically does not tailor its advisory services to the individual needs of investors in the Fund Client; accordingly, it typically does not accept material investment restrictions imposed by such Fund Client investors. With respect to Institutional Accounts, the terms of such relationship, including any investment restrictions, are individually negotiated. Each Advisory Client from time to time enters into agreements (“Side Letters”) with one or more of its investors whereby in consideration for agreeing to invest certain amounts in an Advisory Client and/or other consideration deemed sufficiently material, such investors may be granted favorable rights not afforded other investors in such Advisory Client. Such rights may include one or more of the following: rights to receive reports from the Advisory Client on a more frequent basis or that include information not typically provided to other investors that BlueMountain believes are not prejudicial to other investors; rights to receive reduced rates of performance fees/allocations and/or management fees earned by BlueMountain, each Advisory Client’s general partner and/or other affiliates; application of a restricted securities list; and such other rights as are negotiated between the Advisory Client, BlueMountain and such investors. Such agreements may be entered into by the Advisory Client and BlueMountain without the consent of other investors in such Advisory Client; additionally, except as may be required by “most- favored-nations” clauses, such agreements usually need not be disclosed to other investors in such Advisory Client.
D. If you participate in wrap fee programs by providing portfolio management services, (1) describe
the differences, if any, between how you manage wrap fee accounts and how you manage other
accounts, and (2) explain that you receive a portion of the wrap fee for your services.
BlueMountain does not participate in “wrap fee arrangements,” whereby clients select BlueMountain to manage funds through an investment program presented to the clients by a third-party program sponsor.
E. If you manage client assets, disclose the amount of client assets you manage on a discretionary
basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as
of” which you calculated the amounts.
As of December 31, 2019, BlueMountain has $14,806,543,000 in regulatory assets under management. All of such assets are managed by BlueMountain on a discretionary basis; provided that, with respect to certain Institutional Accounts, one or more investors therein may have consent rights in respect of certain investments. please register to get more info

Open Brochure from SEC website
Assets
Pooled Investment Vehicles $14,806,543,000
Discretionary $14,806,543,000
201720182019202016,000,000,00018,000,000,00020,000,000,00022,000,000,00024,000,000,00026,000,000,00028,000,000,00030,000,000,00032,000,000,00034,000,000,000
Non-Discretionary $
2017201820192020020,000,00040,000,00060,000,00080,000,000100,000,000120,000,000140,000,000160,000,000180,000,000200,000,000
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