Fees and Compensation — Form ADV Part 2A (3/24/2022)
[Brochure]
Item 5 Fees and Compensation
A. Advisory Fees
ILA is compensated for its advisory services by charging a fee based on the value of the
assets invested. Charges are made directly from the custodial account of the client one
month in arrears from the execution of the note or notes. ILA charges 0.95% annually on
assets below $500,000 and 0.65% on client assets $500,000 and above. Clients will pay a
fee structure based on total assets under management. If clients request that their portfolio
be partially or fully liquidated, fees will be charged until the funds are returned to the client.
ILA will allocate funds to loans based on availability of loans and investor appetite. ILA
will purchase client loans through an automated tool which connects directly to the lending
platform. The fee structure is based on assets under management regardless of how many
loans a client owns. ILA’s key offering for clients is the diversification and loan selection
as well as reporting. ILA will continue reporting and portfolio metrics throughout the life
of the loan. There are no cancellation fees charged by ILA for loans that are sold.
ILA is compensated by a performance based fee for its sub-advisory services. Under this
service, the private fund client will pay an annual fee of 1.5% of assets under management
plus a performance fee of 10% subject to a high-water mark. The performance fee will be
paid in any calculation period only if the high-water mark is surpassed, and the hurdle rate
is achieved. The performance based fee is paid monthly in arrears.
B. Other Account Fees
ILA is a “fee only” investment advisor, and other than its advisory fee described above,
neither the firm nor its employees receive or accept any direct or indirect compensation
related to investments that are purchased or sold for client accounts. This means that clients
will not be sold products or services that create additional fees or compensation to benefit
ILA or its employees or its affiliates other than those described in this Brochure.
Currently, ILA uses Millennium Trust Company as the qualified custodian for all client
accounts, and the custody fee for these accounts will never be greater than 75 basis points
per annum (three quarters of 1%). If a client requests a specific custodian or other service
provider, any additional costs will be paid by the client and communicated as part of the
investment advisory agreement for that client.
Form ADV Part 2
Form ADV Part 2 Client Brochure
Account Minimums and Types of Clients — Form ADV Part 2A (3/24/2022)
[Brochure]
Item 7 Types Of Clients
ILA looks to provide investment management services to clients who wish to have
exposure to peer to peer or marketplace loans and who wish to have advanced metrics and
analytics. ILA will utilize multiple marketplace lending platforms to create a diversified
portfolio of loans. At any time, a client may give notice to terminate an account, or
withdraw all or part of an account, or update her investment profile. In that case, unless
otherwise directed by the client, ILA will endeavor to sell the loans in the client account
(or portion of the account, in the case of a partial withdrawal or update) within 5 business
days of the termination, withdrawal or update. When a client wishes to liquidate a loan or
portfolio of loans, ILA will work with the relevant marketplace lending platform or
secondary market to sell the loan. At no time will one client sell to another directly. The
time period of five days allows for the loan sale to settle and clear and for the monies to be
available. However there is no guarantee that any given loan interest can be sold within 5
days (see Item 8 under the heading Secondary Market Risks). ILA will work to sell loans
as directed, as quickly as reasonably practicable.
For the client on-boarding process, ILA looks to have a detailed understanding of the
investor’s needs, risk tolerances and financial goals. We believe it is important for ILA to
understand the client’s current portfolio and allocations. In the onboarding process, we
look to have at least one face to face meeting with clients or a phone call if preferable.
During the onboarding process, ILA looks to build an investment profile for clients through
collecting information from each client. ILA maintains this information in strict
confidence subject to its Privacy Policy, which is provided at the end of this document.
When customizing its investment solutions, ILA relies upon the information received from
a client. Although ILA contacts its clients periodically as described further in Item 13
below, a client must promptly notify ILA of any change in her financial situation or
investment objectives that might require a review or revision of her portfolio.
Form ADV Part 2
Form ADV Part 2 Client Brochure