ADVISORY BUSINESS A. The Advisor
East End was formed in April 2008 as a New York limited liability company. The
principal owners of the firm are Brian R. Clifford, Peter A. Nadosy and David R.
Salomon.
Brian R. Clifford - Managing Partner
Bowdoin College (AB) 1993 (German)/Wharton (MBA) 2001
Principal - East End Advisors, LLC (Oct. 2010 to Present)
Partner and Head of Research - Berens Capital Management, LLC (2001 - 2010)
Peter A. Nadosy - Managing Partner
Brooks School 1964/Harvard College (AB) 1968/Columbia University (MBA) 1970
Principal - East End Advisors, LLC (2008 to Present)
Advisory Director - Morgan Stanley (1998-2008)
Vice Chairman - Morgan Stanley (1996-1998)
President - Morgan Stanley Asset Management (1985-1996)
David R. Salomon - Managing Partner
Pomfret School 1986/Brown University (BA) 1990
Principal - East End Advisors, LLC (2008 to Present)
Managing Director - Grisanti Brown & Partners LLC (2003-2008)
Millsport LLC (1997-2003)
As of the close of business on December 31, 2019, Mr. Richard E. Salomon
withdrew as a managing partner of East End. On January 1, 2020, East End
entered into a consulting agreement whereby Mr. Richard E. Salomon currently
assists East End in regard to its general business activities and long-term strategic
planning pursuant to a consulting agreement between East End and RES/Mecox
Consulting LLC, a single-member LLC that is owned by Mr. Richard E. Salomon
and has no other consulting clients other than East End.
Richard E. Salomon – Consultant
Choate School 1960/Yale University (BA)/1964 Columbia University (MBA) 1967
Principal - East End Advisors, LLC (2008 to Present)
President - Mecox Ventures, Inc. (2000-2008)
President and Managing Director - Spears, Benzak, Salomon & Farrell (1982-2000)
ADVISORY BUSINESS (continued) B. Types of Advisory Services &
C. Client-Specific Services
East End assists clients in developing a customized, overall asset allocation strategy
across all asset classes and in setting investment goals and objectives. Then, as a
manager-of-managers, we provide advice regarding which external, third-party,
unaffiliated investment managers (“Investment Managers”) would be most
appropriate to manage portions of each client’s assets to achieve their objectives.
Generally, East End will recommend Investment Managers that manage investment
funds including investment partnerships, private equity funds, separately managed
accounts, hedge funds and the like (“Investment Funds”). Accordingly, we assist
each of our clients with building broadly diversified investment portfolios.
We monitor the Investment Managers and their Investment Funds and use
benchmarks and other quantitative data as well as qualitative information to
measure the relative performance of the Investment Funds on behalf of clients. As
part of this process, and as we deem appropriate from time to time, we also consider
potential changes to our clients’ rosters of Investment Funds and Investment
Managers.
As such, since the majority of our clients’ assets are invested in Investment Funds
managed by third-party Investment Managers, East End provides primarily non-
discretionary advisory services.
To the extent a portion of a client's short-term assets are pending deployment in an
Investment Fund, or to the extent a client has determined to maintain a permanent
portion of their portfolio outside of Investment Funds, East End provides advisory
services on a discretionary basis. We typically achieve this through investments in
U.S. Government securities, although we may, to a significantly lesser extent, use
other investments from time to time at the client's request or as we deem
appropriate.
For our purposes, our clients’ portfolios (“Portfolios”) consist of their roster of
Investment Funds, their assets awaiting deployment and their assets not destined
for Investment Funds.
East End also provides general investment consultation to clients without
supervisory services for a fixed, flat, annual fee.
ADVISORY BUSINESS (continued)
D. Wrap-Fee Program Participation
This item is not applicable because East End does not participate in any wrap fee
programs.
E. Client Assets Under Management
East End managed approximately $5.1 billion in client assets on a non-
discretionary basis and approximately $0.9 billion in client assets on a
discretionary basis, as of December 31, 2019.
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FEES AND COMPENSATION
A. Advisory Fee
All of East End’s clients are “qualified purchasers” (as defined in the
Investment Company Act of 1940). For advisory services, East End charges
an annualized fee based on the amount of Portfolio assets it manages and
monitors for the particular client. Such fee is typically paid quarterly. Our fee
is based solely on the amount of assets under management and East End
does not charge performance based fees. For investment consultations
without investment supervisory services East End charges a flat fee for such
services.
All fees and payment terms are negotiated individually with each client
depending on the full nature of services provided to such client and are
subject to revision.
B. Frequency and Method of Advisory Fee Payment
We bill our clients for the fee for our investment advisory and investment
consultation services, which is generally payable in quarterly installments.
C. Other Fees or Expenses
In addition to paying East End’s advisory fees, our clients pay their own
custodian fees. East End clients also incur the cost of management fees,
performance fees and operating expenses related to their Investment Funds.
D. Timing of Advisory Fee Payments
East End’s fees are generally charged in advance. If an account is
terminated, the client is entitled to a pro rata refund of any amounts paid but
not yet earned by East End.
E. Compensation for the Sale of Investment Products
This is not applicable, since neither the Advisor nor any of its employees
accepts compensation for the sale of securities or other investment products.
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PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
This item is not applicable because East End does not charge any performance-based
fees to any clients.
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TYPES OF CLIENTS
East End provides investment advisory services to various high net worth individuals,
families, trusts and charitable institutions, foundations and endowments.
Generally, the minimum Portfolio size for an East End client is $500 million. However,
we have accepted clients with less than that amount.
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METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. Methods of Analysis and Investment Strategies
Our primary advisory service involves setting investment goals and objectives
together with a client, and then formulating a customized asset allocation
strategy including advice regarding specific Investment Managers and
Investment Funds, and assistance in building a broadly diversified investment
portfolio. We provide advice regarding change recommendations as necessary.
The majority of East End's investment recommendations are long-term in
nature and thus require long-term investments with Investment Managers or in
Investment Funds. We also use other investment strategies, which could be
long-term or short-term, as part of a client's overall asset allocation strategy or
on the portion of a client's Portfolio that is pending deployment in an Investment
Fund or that is designated by the client to be kept outside of Investment Funds.
These other investments primarily consist of investments in U.S. government
securities.
The Advisor performs on-going reviews of Investment Managers, which
includes reviews of various factors such as performance, quantitative
measures, qualitative matters and periodic meetings with and reports from
Investment Managers. In addition, East End’s sources of information for our
investment ideas may originate through the membership of our managing
partners on external boards, investment committees or the like, or may come
from financial publications and research materials prepared by others.
We also use various proprietary tools to assist in the analysis of specific
Investment Funds and the client's overall Portfolio. Additionally, East End
uses Advent Axys Portfolio software as the primary accounting/performance
reporting system for client Portfolios and for pricing and index information.
Clients should remember that investing in securities involves the risk of loss,
which they should be prepared to bear.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS (continued) B. General Material Risks &
C. Security-Specific Material Risks
East End’s predominant investment strategy is the development of an asset
allocation strategy and the subsequent recommendation of Investment Funds
to clients. The material risks involved in this strategy are general market risks
and risks specific to such funds, including:
Market Risk – The value of a client account will vary continuously as a
result of a variety of factors including macro-economic issues, global
geo-political issues and as a result of turbulence and volatility in the
financial markets in general.
Lack of Transparency – Certain types of Investment Funds often have
fewer disclosure requirements as to their portfolio, strategies and/or
risks.
Conflict of Interest – By receiving a performance fee, the manager of
an Investment Fund has an incentive to construct a riskier portfolio if it
wants to increase the chances of a higher return and therefore higher
performance fees. In some cases, however, the Investment Fund
manager will strive for more level, consistent fees and therefore may
resist this incentive.
Riskier Strategies – Investment Funds invest in securities. Certain
Investment Funds may use strategies that involve higher risk and
volatility, such as leverage, short-selling and/or trading on margin.
Others may make investments in riskier securities such as high yield
bonds, distressed securities or collateralized debt obligations. In
addition, private equity funds invest directly in businesses, ranging
from young or emerging companies to existing mature companies that
require additional capital.
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DISCIPLINARY INFORMATION
This item is not applicable because there are no legal or disciplinary events relating to
the Advisor or its employees.
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OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
This item is not applicable to the Advisor because neither it nor, to the extent the
category applies, any of its employees: (1) is registered or has an application pending to
register as a broker-dealer or a registered representative of a broker-dealer; (2) is
registered or has an application pending to register as a futures commission merchant,
commodity pool operator, commodity trading advisor, or an associated person of these
entities; (3) has a relationship or arrangement with certain specified entities or
companies that is material to our advisory business or our clients and that might cause
a material conflict of interest with clients; or (4) receives any compensation directly or
indirectly from the investment advisors that we recommend for our clients that creates a
material conflict of interest, or have any other business relationships with the investment
advisors that we recommend for our clients that create a material conflict of interest.
TRANSACTIONS AND PERSONAL TRADING
A. Code of Ethics
East End’s Code of Ethics provides that, generally, our employees may
purchase and sell securities for their personal accounts and for the accounts
of certain related persons (primarily consisting of immediate family members
and certain related entities). Our Code of Ethics is designed to ensure that
employees act with honesty, integrity and professionalism and adhere to
federal securities laws and regulations.
Employees must obtain prior written approval from the Chief Compliance
Officer before investing in initial public offerings or limited offerings (private
placements including investments in Investment Funds); the Chief
Compliance Officer must obtain this approval from the Chief Executive
Officer.
Employees are also required to submit reports detailing the personal
securities holdings of themselves and their related persons to the Chief
Compliance Officer when they are hired and on an annual basis, and they
must report on a quarterly basis about the personal securities trades that they
and their related persons have made in the prior quarter.
Our employees must give prior notice of, and under certain circumstances
receive approval for, any outside activity in which they wish to engage. This
includes outside business interests, private securities transactions, and
maintenance of personal brokerage accounts.
As a general rule, East End employees may only accept gifts of strictly
nominal value including normal and customary business entertainment (such
as business meals and entertainment where the person providing the
entertainment is present) that is not “lavish,” the cost of which would be paid
by East End as a reasonable expense if not paid by someone else.
TRANSACTIONS AND PERSONAL TRADING (continued)
Our Code of Ethics also contains policies designed to prevent insider trading
by employees and their related persons for their own account or the account
of any East End client. We take our obligation to detect and prevent insider
trading with the utmost seriousness. We may impose penalties for breaches
of the insider trading rules (and any of our other policies and procedures
contained in our compliance manual), even in the absence of any indication of
insider trading. Depending on the nature of the breach, penalties may include
a letter of censure, profit “give-ups,” fines, referrals to regulatory and self-
regulatory bodies and dismissal.
We will provide a copy of our Code of Ethics to any client or prospective
client, upon request. Please contact Mr. Christopher J. Brown at 212-218-
8137.
B. Client Trades in Securities in which there is a Material Personal Financial
Interest
As a matter of practice and as a general rule, neither the Advisor nor any of
its employees recommends to clients, or buys or sells for client accounts, any
securities in which the Advisor or any employee has a financial interest.
However, certain employees of the Advisor currently hold an interest which
represents a de minimis percentage of the equity of an unaffiliated Investment
Manager that manages an Investment Fund that the Advisor has
recommended to certain clients. This represents a conflict of interest because
fees paid to the Investment Manager in respect of client investments in the
Investment Fund indirectly benefit the employees who hold an interest in the
Investment Manager. The Advisor addressed this conflict by providing each
client to whom the investment was recommended with full disclosure of the
fact that employees held an interest in the Investment Manager and of the
resulting conflict and proceeding with each client’s investment only where
such client affirmatively chose to invest after being informed of the conflict.
The Advisor intends to take the same approach in the unlikely event that any
similar conflict should arise in the future.
TRANSACTIONS AND PERSONAL TRADING (continued)
C. Personal Investments in the Same Securities that are Bought or Sold for
Clients
East End employees and their related persons are permitted to invest in the
same Investment Funds, and do invest in certain of the same Investment
Funds, that the Advisor recommends for clients. Although the Advisor
believes this practice definitively aligns the incentives of the Advisor’s
employees with those of the Advisor’s clients, this practice also may present a
conflict of interest in that the employee or his or her related person could take
an investment opportunity away from a client if the investment opportunity is,
or becomes, limited. The Advisor addresses this conflict by requiring
employees and their related persons to obtain prior approval for investments
in Investment Funds and by prohibiting employees from making an
investment in any case where there is not sufficient availability to first satisfy
the full allocation considered by the Advisor to be appropriate for clients
(based on the considerations described in the response to Item 11.D. below).
D. East End makes decisions to recommend, purchase, sell or hold investments
for its client accounts based on the specific investment objectives, guidelines,
restrictions, risk tolerances, asset allocation goals and circumstances of each
client account. East End allocates investment opportunities to each client over
time on a fair and equitable basis relative to its other clients. Where client
accounts have competing interests in limited investment opportunities, East
End will allocate these investment opportunities based on numerous
considerations, including cash availability and/or liquidity requirements, the
time competing accounts have had funds available for investment or have
had investments available for sale, an account's participation in other or
comparable opportunities, tax considerations, the relative size of portfolio
holdings of the same or comparable investments, etc. In general, East End
favors clients holding meaningful investment weightings for their accounts.
For example, East End believes that it is generally more desirable for a
smaller client to hold a meaningful position in a particular investment, rather
than for a larger client to hold an insignificant position.
TRANSACTIONS AND PERSONAL TRADING (continued)
Employees may invest in Investment Funds recommended to clients at, or at
about, the same time as clients. In some cases, this practice enables
employees to make investments that would not otherwise be available to
them because of, for example, minimum investment thresholds. Although this
practice would pose a conflict in cases where employees’ investment
interests differed from those of clients, the Advisor believes that the interests
of its employees and clients are nearly universally aligned where they invest
concurrently in the same Investment Fund. The Advisor addresses this
potential conflict by seeking to align clients’ and employees’ interests to the
extent possible by requiring that any employees invest on the same terms as
clients that are concurrently investing and without, for example, any discount
on Investment Fund management fees or any other terms or advantages not
also afforded to such clients.
E. On certain occasions, East End may recommend that a client buy or sell a
security that is publicly traded. East End does not generally select or
recommend broker-dealers for such transactions. East End’s client will either
use a broker-dealer they select to execute transactions in the security, or
direct East End to use a specific broker-dealer. Whichever is the case, the
client will negotiate terms and arrangements for the account with that broker-
dealer, and East End will not seek better execution services or prices from
other broker-dealers.
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BROKERAGE PRACTICES
This Item is not applicable because the Advisor does not select or recommend broker-
dealers for client transactions.
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REVIEW OF ACCOUNTS
East End’s Managing Partners, along with East End’s team of investment professionals,
review client Portfolios on a weekly basis. We may also review Portfolios more
frequently because of a client’s investment strategy or objective, a client’s personal
needs, the macro-economic environment, changes in laws, the availability of new
investment products and superior or inferior performance by a previously recommended
or available Investment Manager or Investment Fund. We limit the number of clients we
manage to ensure proper oversight and the performance of regular and thorough
reviews of client Portfolios.
East End generally provides clients with written Portfolio summary reports and
performance reports monthly. Performance is reported in absolute and relative terms.
That is, the underlying Investment Funds in client Portfolios are compared to the
performance of agreed-upon indices and/or other Investment Managers with a similar
style and strategy.
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CLIENT REFERRALS AND OTHER COMPENSATION
This item is not applicable because the Advisor does not receive an economic benefit
from anyone other than a client for providing investment advice to our clients, nor does
the firm directly or indirectly compensate anyone for client referrals.
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CUSTODY
East End has engaged Grant Thornton LLP to conduct annual surprise examinations of
client accounts for which EEA maintains custody, in accordance with SEC
requirements. Following an examination, Grant Thornton LLP files a Form ADV-E with
the SEC as part of East End’s filing with the SEC. Additional information can be found at
www.adviserinfo.sec.gov.
East End’s clients should receive, at least quarterly, statements from the broker-dealer,
bank or other qualified custodian that holds and maintains their investment assets. East
End urges clients to review carefully such statements and compare such official
custodial records to any statements that East End may provide to them. East End’s
statements may vary from the custodial statements based on accounting procedures,
reporting dates or valuation methodologies of certain securities.
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INVESTMENT DISCRETION
The Advisor provides primarily non-discretionary advisory services. To the limited extent
we have discretionary authority over client accounts, a client’s objectives and guidelines
may limit that authority. Before we assume any discretionary authority over a client’s
account, we ensure that there is proper authorization in place.
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FINANCIAL INFORMATION
A. Balance Sheet
This item is not applicable because the Advisor does not require or solicit
prepayment of more than $1,200 in fees per client, six months or more in
advance.
B. Financial Condition
The Advisor has no financial condition that is reasonably likely to impair
our ability to meet contractual commitments to our clients.
C. Bankruptcy
This item is not applicable because the Advisor has never been the
subject of a bankruptcy petition.
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Open Brochure from SEC website