Aetna Capital Management LLC

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Aetna Capital Management LLC
CRD #132957
SEC #801-64865
CIK #
AUM
Employees 10 (40% Investors, 0% Brokers)
Fees
Minimum
Phone860-380-1230
Address29 South Main Street
West Hartford, CT 06107-2449
Source [IAPD] [Website]
Total AUM ($M)
100080060040020002003201020172025
Fees and Compensation — Form ADV Part 2A (3/30/2017) [Brochure]
Item 5            Fees and Compensation

A.       ACM’s fees for services provided to APDF and APDF Cayman include a
         management fee (the “Management Fee”), which is a fixed, asset-based fee, and
         incentive compensation (“Incentive Compensation”), which is a performance-
         based allocation (in the case of APDF) or a performance-based fee (in the case of
         APDF Cayman). ACM’s fees for services provided to Aetna 1099 Fund include a
         management fee (the “Investment Management Fee”), which is a fixed, asset-
         based fee.

         The Management Fee is generally between 1% and 1.5% per annum of the net
         asset value of each investor's investment in APDF or APDF Cayman, as
         applicable, calculated and payable monthly in arrears.                The Incentive
         Compensation for APDF and APDF Cayman is generally allocable or payable
         annually. The Incentive Compensation for APDF and APDF Cayman is generally
         between 5% and 10% of the net realized and unrealized capital appreciation
         attributable to each investor's investment. The Incentive Compensation for APDF
         and APDF Cayman is subject to a cumulative “high water mark,” requiring the
         recovery of an investor's prior losses before such allocation or fee is made or paid.

         The Investment Management Fee is 1.0% per annum of the net asset value of the
         Aetna 1099 Fund, calculated and payable monthly in arrears.

         ACM may waive, reduce or calculate differently the APDF and APDF Cayman
         Management Fee and Incentive Compensation with respect to certain investors
         (including, without limitation, to ACM itself and any of its affiliates, in their
         capacities as investors).

         Because APDF, APDF Cayman and Aetna 1099 Fund invest in underlying hedge
         funds that typically have their own management, incentive, and other fees,
         investors will be indirectly subject to fees and expenses of such underlying hedge
         funds as well as the fees and expenses of APDF, APDF Cayman or Aetna 1099
         Fund, as applicable.

         No fees are paid by the Affiliated Client with respect to services provided by
         ACM.

B.       ACM deducts fees from the assets of APDF, APDF Cayman and Aetna 1099
         Fund on a monthly basis. For APDF and Aetna 1099 Fund, investors’ capital
         accounts are debited their pro rata portion of the amount of the fees owed. For
         APDF Cayman, both the management and incentive fees are debited from the
         value of APDF Cayman, resulting in a pro rata diminution in the value of each
         investor’s shares. With respect to the Affiliated Client, ACM neither deducts fees
         nor bills the client for its services.
C.       Each of APDF, APDF Cayman and Aetna 1099 Fund generally pays all of the
         expenses incurred in its operation, including, but not limited to: (i) fees for

ACM Brochure March 2017.docx

Form ADV: Part 2A                                                                   Page 6

         administrative, custodial, legal, audit and tax services; and (ii) the cost of
         insurance, background checks, litigation and other extraordinary matters. Each of
         APDF, APDF Cayman and Aetna 1099 Fund also pays the management fees and
         incentive compensation owed to managers of underlying hedge funds in its
         portfolio, as well as investment-related expenses incurred in cash management.
         All of the above-described fees and expenses result in the diminution of the net
         asset value of APDF, APDF Cayman and Aetna 1099 Fund, and, therefore, cause
         pro rata reductions in the value of investors’ interests in these entities on a
         monthly basis.

         ACM may use placement agents to assist in the placement of interests in APDF,
         APDF Cayman or Aetna 1099 Fund. The placement agents would generally be
         entitled to placement fees, the amount of which may depend on the size of an
         investment. The placement fees are paid by ACM and are not an expense paid by
         APDF, APDF Cayman, Aetna 1099 Fund or their respective investors.

         To date, no brokerage commissions have been incurred by APDF, APDF Cayman
         or Aetna 1099 Fund because the nature of their investment activities do not
         require the payment of brokerage commissions.

D.       Fees are paid in arrears; no mechanism for a refund is required.

E.       Neither ACM nor any of its supervised persons accepts compensation for the sale
         of securities or other investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2017) [Brochure]
Item 7            Types of Clients

ACM currently provides investment advice to private investment funds, a registered
investment company and the Affiliated Client as described below, but may also provide
investment advice to individuals, trusts, corporations, institutional investors and other
entities that seek to invest in private investment funds.

APDF is a Delaware limited liability company. APDF Cayman is an exempted company
with limited liability under the laws of the Cayman Islands. It is registered as a regulated
mutual fund with the Cayman Islands Monetary Authority. Aetna 1099 Fund is a
Delaware statutory trust that is registered with the SEC under the Investment Company
Act of 1940 as a non-diversified, closed-end management investment company. Both
APDF and APDF Cayman are excepted from the definition of an investment company
under Section 3(c)(7) of the Investment Company Act of 1940. APDF Cayman is a
“benefit plan investor,” as defined in ERISA, because more than 25% of the net asset
value of one of its share classes is held by benefit plan investors.

ACM provides discretionary investment advice to APDF, APDF Cayman and Aetna 1099
Fund. The Affiliated Client is the defined benefit pension plan sponsored by ACM’s
ultimate parent. ACM provides non-discretionary investment advice to the Affiliated
Client.
Type Form D Funds Date Sold AUM
HF Aetna Partners Diversified Fund Cayman Limited 2012-03-29 154.0 M
HF Aetna Partners Diversified Fund LLC 2012-03-29 529.2 M
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 4 938.3
By Discretionary
Discretionary 3 747.1
Non-Discretionary 1 191.2
Total 4 938.3
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 938.3
Total 4 938.3
Firm Profile (Form ADV)
Discretionary AUM$0.7B
Clients3 (25 non-US)
ServesInstitutional
Fund TypesHedge Fund
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