A. Firm Description
Kiski Alpha Partners, LLC (“Kiski Alpha” or the “Adviser”) is a Delaware Limited Liability Corporation
with its principal place of business in New York, New York. The Adviser is a wholly-owned subsidiary
of Kiski Group, Inc. (“Kiski Group” or “Parent”).
Kiski Group is majority owned and controlled by Kevin
Becker. Kiski Alpha has been in business since 2008 providing sophisticated risk and analytics services to
investment managers, family offices, pension funds and other institutional allocators.
The Adviser’s core services concentrate on enhancing investment, risk and operational processes by
focusing on transparency, quantifiable systematic analysis, operational efficiency, independent risk
monitoring, and oversight using proprietary software-based solutions.
Kiski Alpha has no regulatory assets under management and is registered as a relying adviser to Kiski
Partners, LLC, an affiliate of the Adviser and subsidiary of Kiski Group.
B. Advisory Services
Kiski Alpha provides software-based research solutions to clients that are financial asset managers and
allocators. These software solutions include the provision of quantitative analytical support and risk
services. Kiski provides research to clients with respect to portfolio assets by tailoring its services to the
individual needs of its clients, publishing information on a daily basis to a dedicated client web portal.
C. Wrap Fee Programs
Kiski Alpha does not participate in any wrap fee programs.
D. Assets Under Management
Kiski Alpha does not manage any client assets on a standalone basis, and as such does not have regulatory
assets under management.
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A. Adviser Compensation
Kiski Alpha charges a subscription fee for its research services. Such fees generally range up to and in
excess of $100,000 per month, depending on the services provided and the perceived value of the research
services. Fees are negotiable for each client and invoiced in advance. Clients who receive non-standardized
research services from Kiski Alpha pay fees based on their independent, good faith determination of the
value of the services.
B. Payment of Fees
Fee charged by Kiski Alpha may be paid directly by the client or by broker-dealers that execute securities
transactions for the client (i.e., “soft dollar” payments).
C. Other Non-Advisory Fees
Clients do not pay other types of fees in connection with the services provided by Kiski Alpha.
D. Prepayment and Timing of Fees
Clients are not required to and may not pay fees in advance.
E. Payment to Supervised Persons
Kiski Alpha and its supervised persons do not receive compensation for the sale of securities or other
investment products in connection with the services provided to Kiski Alpha’s clients.
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Kiski Alpha currently expects to provide software-based research services to investment managers, pension
funds, and institutional allocators.
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A. Methods of Analysis and Investment Strategies
Quantitative Analysis
Kiski Alpha provides data-driven risk analytics and performance statistics on portfolio assets, publishing
reports to a secure client portal on a daily basis. Performance analysis may typically include: Sharpe ratio,
Sortino ratio, drawdown, volatility and correlation to various benchmarks; security attribution; performance
relative to an appropriate benchmark; and security level performance detail. Risk analysis may typically
include (i) security level detail factor sensitivity, (ii) exposure by region, asset type, market cap, and
industry, (iii) liquidity analysis, and (iv) portfolio VaR, and (v) top contributors.
Advisory
Kiski Alpha combines portfolio management experience in all asset classes with an operations and
technology infrastructure to provide advice on customized risk analysis, process quantification, portfolio
construction and optimization, and marketing support.
B. Risks for Analysis
All investments in securities and other financial instruments include a risk of loss of a client's principal
(invested amount) and any profits that have not been realized (the securities were not sold to "lock in" the
profit). Historically, stock markets and bond markets fluctuate substantially over time. In addition, as recent
global and domestic economic events have demonstrated, performance of any investment is not guaranteed.
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Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be considered material to your evaluation of Kiski Alpha or the integrity of the services
Kiski Alpha provides.
A. Criminal or Civil Action
Neither Kiski Alpha, nor any of our access persons, has been the subject on any criminal or civil proceedings
that are required to be disclosed under this item.
B. Administrative Procedure
Neither Kiski Alpha, nor any of its access persons, has had any administrative proceedings before the SEC,
any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority.
C. Self-Regulatory Organization
Neither Kiski Alpha, nor any of its access persons, has been the subject on any proceedings before a self-
regulatory organization that are required to be disclosed under this item.
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The following relationships or arrangements with related persons are material to our business and may
create potential conflicts of interest:
A. Registered Representatives
Kiski Alpha is not registered as a broker-dealer and does not have an application pending to register with
the SEC as a broker-dealer. Some management persons of Kiski Alpha are registered representatives of
Kiski Securities, LLC (“Kiski Securities”), an affiliated SEC registered broker-dealer and member of the
Financial Industry Regulatory Authority (“FINRA”).
B. CFTC Registration Status
Kiski Alpha is not registered as a commodity pool operator with the CFTC, however, its affiliate Kiski
Partners, LLC is registered as a commodity pool operator with the CFTC. Two management persons of
Kiski Alpha are also registered as Associated Persons of the commodity pool operator.
C. Industry Relationships Material to Advisery Business
Kiski Alpha is a relying adviser of Kiski Partners, LLC, a registered investment adviser that provides
investment management and Advisory services on a discretionary and non-discretionary basis to U.S. and
non-U.S. private pooled investment vehicles.
Kiski Alpha is affiliated with Kiski Securities, a broker-dealer registered with the SEC and a member of
FINRA.
As noted above, several employees of Kiski Alpha are also registered representatives of Kiski Securities.
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A. Code of Ethics
Code of Ethics and Personal Securities Transactions The Adviser has adopted a Code of Ethics (the “Code”) to establish a standard of business conduct for the
Adviser’s associated persons that is based upon fundamental principles of openness, integrity, honesty and
trust. The Code addresses areas such as prohibited activities and standards of business conduct, conflicts of
interest, confidentiality, personal securities transactions and recordkeeping.
In accordance with Section 204A of the U.S. Investment Advisers Act of 1940, the Adviser also maintains
and enforces written policies reasonably designed to prevent the misuse of material non-public information
by the Adviser or any person associated with the Adviser. Clients or prospective clients may obtain a copy
of the Code by requesting it by e-mail directly to
[email protected]. Kiski Alpha’s Code is available
to any investors or prospective investors upon request by contacting Kiski Alpha’s Chief Compliance
Officer at (646) 412-6302.
B. Recommendations of Securities and Material Financial Interests
Generally, the Code places limitations on personal securities transactions by each employee, and such
personal securities transactions are monitored to ensure that a conflict of interest does not arise with respect
to any securities transactions. Kiski Alpha’s Code requires that all employees adhere to the highest duty of
trust and fair dealing.
C. Personal Trading
The Code limits employees engaged in personal securities transactions through the application of strict
guidelines and restrictions to avoid potential conflicts of interests with Client accounts.
All employees of Kiski Alpha: (i) must conduct their personal securities transactions in a manner that does
not interfere with any client’s portfolio transactions or take inappropriate advantage of an employee’s
relationship with a client, and (ii) may not trade while in possession of material, non-public information.
With certain exceptions, Access Person trading is generally subject to the following guidelines:
▪ Required pre-clearance on all employee trading.
▪ Limited to trading in Exchange Traded Funds, Mutual Funds, US government bonds, commercial
paper (with exceptions on individual securities owned when an employee joins the firm or
subsequently inherits - on those securities employees can request approval to sell).
▪ May not engage in short-term trading of any Exchange Traded Funds, Mutual Funds, or similar
securities (the purchase and sale, or sale and purchase within 60 days).
▪ May not purchase securities in initial public offerings or in connection with private placements
except with the express written prior approval the Chief Compliance Officer.
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Kiski Alpha does not select or recommend broker-dealers for client transactions, as it does not engage in
the purchase or sale of securities.
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Kiski Alpha does not manage client securities accounts; therefore, there is no periodic review of accounts
nor regular reporting.
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Kiski Alpha does not receive any benefits from third parties for providing investment advice or other
Advisory services to its clients, nor does Kiski Alpha or any of its related persons directly or indirectly
compensate any third party for client referrals.
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Kiski Alpha does not have authority to vote client securities and does not provide advice as to the voting of
client securities.
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Kiski Alpha has no financial condition that impairs its ability to meet contractual commitments to its clients
and has not been the subject of a bankruptcy proceeding. Kiski Alpha has not been the subject of a
bankruptcy petition in the last 10 years.
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