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| Sanderson Asset Management LLP
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| CRD # | 109716 |
| SEC # | 801-60032 |
| CIK # | 0001388870 |
| AUM | |
| Employees | 16 (44% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 011442074685970 |
| Address | Princes House, Suite 4C London, United Kingdom |
| Source | [IAPD] [EDGAR] [Website] [LinkedIn] |
| Total AUM ($B) |
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| Fees and Compensation — Form ADV Part 2A (8/2/2023) [Brochure] |
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Item 5. Fees and Compensation
Sanderson provides discretionary investment management services to Unitholders investing in its
Funds on the following fee scale:
Amount: Feescale
(% of funds under management per Unitholder per annum)
First $25,000,000 0.80%
Next $25,000,000 0.65%
Next $25,000,000 0.55%
Thereafter 0.45%
The above feescale has been periodically amended and Unitholders investing in one of Sanderson’s
Funds, and their successor or related entities, may be subject to different feescales based on the fee
structures and policies in effect as of the initial date of their investment. Staff of Sanderson,
Sanderson, Inc. and other connected parties may be invested in the Funds and such investments are
subject to the same fees and liquidity rights as investments by other Unitholders.
Fees are paid by each Unitholder invested in a Fund based upon the market value of the units held by
the Unitholder rather than the value of the Fund itself. Fees are normally payable monthly in arrears,
although the actual timing of fee payments will depend on the underlying legal domicile of a Fund
and the terms of its operating agreements. Fees are normally paid via the redemption of part of the
units held by each Unitholder in a Fund on a monthly basis.
August 2, 2023 -5-
Sanderson Asset Management LLP – ADV Part 2 Brochure
The Funds pay their own direct trading expenses, clearing fees, and other exchange fees and charges.
Direct trading expenses include brokerage commissions, bid-ask spreads, mark-ups, clearing fees,
registration and transfer fees, regulatory and governmental charges and duties, and transactional fees
and expenses relating to investments. The Funds are obligated to pay all income, dividend
withholding, capital gains and other taxes related to their underlying investments. In addition, in
certain rare situations, the Funds may be required to reimburse Sanderson or the third party service
providers to the Funds for legal expenses incurred to protect the Unitholders which Sanderson
determines are not routine and which are not borne by Sanderson. For example, such extraordinary
legal expenses would include those incurred in connection with litigation to protect or promote the
investment rights or obligations of the Funds and legal or accounting expenses incurred in connection
with reclaiming foreign withholding taxes.
Sanderson pays all routine legal, audit and accounting fees related to the Funds and the ongoing
offering of their units as well as annual audit fees and tax return expenses (if any). Sanderson pays
any fees payable to the custodians, trustees, fund administrators, managers, managing members,
auditors, tax advisors and other similar service providers of the Funds. Sanderson has paid all
expenses incurred in connection with the organization and the formation of Funds and will pay all
costs associated with the ongoing issuance of the units of these Funds to the extent that it remains the
appointed investment manager of the Funds. The Funds are not required to raise a minimum amount
in order to defray these costs and expenses. The Funds are not required to reimburse Sanderson in the
event that the investment management fees are insufficient to cover the expenses borne by Sanderson.
Fees are generally not negotiable, however please note the information on Side Letter Agreements
provided under Item 7 below.
Anti-dilution Levies
Prospective investor contributions to or Unitholder redemptions from Sanderson’s U.S. Funds are
available on a monthly basis. Sanderson, in its sole discretion, may elect to utilize a transition account
for contributions and redemptions, and will typically do so in situations including, but not limited to,
where a contribution or redemption is large in size relative to the respective Fund. Transition accounts
are discussed in Items 7 and 8 below. Where a transition account is utilised, trading costs are incurred
on the account and not within the respective Fund.
Where a prospective investor or Unitholder directly invests into or redeems from one of Sanderson’s
Funds then the Fund governing documents permit the use of an anti-dilution levy (i.e. transaction
charge) to cover the trading and other costs associated with that transaction. Except in extraordinary
circumstances, the levy is stated not to exceed 0.60% on contributions and 0.40% on redemptions.
August 2, 2023 -6-
Sanderson Asset Management LLP – ADV Part 2 Brochure
Where applied, these levies are credited directly to the Fund. Sanderson has set out these provisions
in order to define an equitable way of meeting prospective investor and Unitholder liquidity
requirements whilst also protecting existing investors in its Funds. Prospective investors and
Unitholders should refer to the specific provisions of the governing documents for a complete
discussion of anti-dilution levies, transition accounts and the risks involved therein. |
| Account Minimums and Types of Clients — Form ADV Part 2A (8/2/2023) [Brochure] |
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Item 7. Types of Clients Each Fund, and not the underlying Unitholders in each Fund, is considered a client of Sanderson pursuant to the Investment Advisers Act of 1940, as amended. Sanderson makes investments on behalf of the Funds for the benefit of the underlying Unitholders in each respective Fund. Units in Sanderson’s U.S. Funds are sold only to Unitholders that qualify as “accredited investors” and/or “qualified purchasers” under applicable securities laws. An investment in units of a Fund involves the risk of loss. Sanderson, in its capacity as investment manager, is responsible for reviewing and managing the holdings of each Fund based on the results of its research activities and for making appropriate recommendations to satisfy the respective investment goals of the Funds. Additional information is available in the respective offering memorandum of each Fund. Sanderson has historically offered separate account services to institutional clients, such as pension plans, foundations and endowments. Conditions for Managing Accounts Unitholders investing in Sanderson's U.S. Funds are generally required to invest a minimum of $5 million at the inception of their relationship with Sanderson. Sanderson may, in its sole discretion, accept or reject, in whole or in part, any initial or additional investment or impose conditions or restrictions on such investment. Unitholders may redeem all or part of their units in Sanderson’s U.S. Funds on any Dealing Day (as that term is defined in the Fund offering memorandum) by providing Sanderson with written notice at least ten (10) business days prior to the Dealing Day upon which the August 2, 2023 -7- Sanderson Asset Management LLP – ADV Part 2 Brochure redemption is to be effective. Certain documentation must also be returned at least four (4) business days prior to such Dealing Day. Any redemption from Sanderson’s U.S. Funds must ordinarily exceed $250,000 and, following any such redemption, a Unitholder must ordinarily maintain Units with a minimum market value of $5 million. Transition Accounts Sanderson has the discretion to direct Unitholders making cash contributions to or redemptions from the Funds to use transition accounts. Transition accounts are temporary custody accounts that are opened under a Fund’s general legal structure. They are used to facilitate large subscriptions and withdrawals. The transition account structure allows Sanderson to invest cash contributions outside of a Fund’s direct assets or to liquidate holdings outside of a Fund’s direct assets (and therefore avoid impacting existing investors or remaining investors, as the case may be). By investing new cash flows or liquidating the securities separately, the incoming or outgoing investors bear their own market risk during the investment or redemption period, as well as their own dealing costs. Sanderson believes that these procedures safeguard the benefits of commingled investing for all participants and represent a fair and equitable way of accommodating periodic subscriptions and withdrawals. The assets of multiple investors may be commingled in the same subscription or withdrawal transition account. Depending on prevailing market conditions, the use of a transition account may result in (i) the aggregate value of Units issued to the investor being greater or less than the purchase amount that was deposited by the investor into a subscription transition account; and/or (ii) the proceeds of the securities, cash and other assets liquidated in a withdrawal transition account being greater or less than the aggregate value of the Units withdrawn on the date of transfer to that account. Prospective investors should refer to the specific provisions of the respective offering memorandum of each Fund for a complete discussion of transition accounts and the risks involved therein. Side Letter Agreements Historically, Sanderson has agreed fees with certain Unitholders, as well as their successor and related entities, having multiple investments in the Funds in order to give the effect of aggregation for investment management fee purposes between those multiple investments. Going forward, Sanderson will generally only consider entering into a side letter agreement when rules governing the investment by a specific Unitholder (such as state law or the governing documents related to such Unitholder) require a specific variation, provided that such change is not expected to materially impact the other Unitholders, Sanderson or other service providers to the Funds. August 2, 2023 -8- Sanderson Asset Management LLP – ADV Part 2 Brochure It is Sanderson’s policy not to agree to any side letter or other similar agreements that grant any Unitholder or group of Unitholders preferential rights with respect to the payment or timing of redemptions, indemnification from Sanderson, the law governing Sanderson’s and each Unitholder’s responsibilities under the governing documents for the Funds, or access to data on a Fund’s holdings or trading activity. Sanderson will provide a summary of all side letter agreements currently in effect upon the written request of a current or prospective investor. As described above, where the only effect of such an agreement is to allow for the aggregation for fee purposes of multiple investments, then Sanderson will not include this in the aforementioned summary. |
| Type | Form D Funds | Date | Sold | AUM |
|---|---|---|---|---|
| Other | Sanderson International Value Fund | 2012-03-20 | 802.5 M | |
| Other | Sanderson International Value Group Trust | 2012-03-20 | 330.8 M | |
| Other | Sanderson International Value Tobacco Free Fund | 2012-03-20 | 34.8 M |
| AUM Breakdown | Accounts | AUM ($B) |
|---|---|---|
| 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 | 4 | 1.4 |
| (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 | 1.4 |
| By Discretionary | ||
| Discretionary | 4 | 1.4 |
| Non-Discretionary | 0 | 0.0 |
| Total | 4 | 1.4 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.2 | |
| United States Persons | 1.2 | |
| Total | 4 | 1.4 |
| EDGAR Form | CIK | 2011 - 2026 |
|---|---|---|
| 13F-HR | [0001388870] |
| Firm Profile (Form ADV) | |
|---|---|
| Discretionary AUM | $9.2B |
| Serves | Institutional |
| LEI | 549300NOTIF2VQODPP11 |