Item 7. Types of Clients
The Investment Policy and Strategy Committee (IPSC) is
responsible for setting the investment direction for each
We offer investment advice to individuals, high net worth
Tortoise Credit taxable investment strategy, themes, and
individuals, pension and profit-sharing plans, Taft-Hartley
overall portfolio investment risk. In addition to developing
and other ERISA plans, state or municipal government
industry and sector strategies based upon the firm’s top-
entities, financial intermediaries, insurance companies,
down economic viewpoint, the IPSC develops and
charitable organizations, foundations, endowments, other
implements a duration strategy based on our intermediate
investment advisers, pooled investment vehicles, trust
and long term cyclical view of the movements of US interest
programs, registered funds, corporations and other
rates. Our stated Duration range for this decision could be
businesses, and other entities. Minimum account sizes and
up to +/- 25% of the benchmark.
minimum fees will apply for certain strategies. Please refer
to Item 5.
Portfolio trading strategies include long-term purchases,
short-term purchases, and active trading. Frequent trading
To the extent we manage client accounts that are covered
can negatively impact investment performance due to the
by the Employee Retirement Income Security Act of 1974
potential of increased tax liability and transaction costs.
(ERISA) or that are tax-qualified retirement plans, including
Investing in securities involves the risk of loss that clients
individual retirement accounts (IRAs), we acknowledge that
should be prepared to bear.
we are a fiduciary as defined under Section 3(21) of ERISA
and Section 4975(e)(3) of the Internal Revenue Code of
Methods of analysis employed during strategy
1986 with respect to the services provided under the Client
implementation and portfolio monitoring include statistical,
Agreement (defined below).
fundamental, technical, relative valuation, and cyclical
analysis. Industry analysts review operating and credit
trends within assigned industries and perform financial
analysis on individual issuers to develop recommendations Cash Position Risk: An account may hold any portion of
for each of their respective industries. Portfolio Managers its assets in cash, cash equivalents, or other short-term
and Analysts conduct relative valuation analysis by investments at any time or for an extended time. Tortoise
examining current and historical relative pricing in relation Credit will determine the amount of an account’s assets to
to an issuers capital structure, a general industry or asset be held in cash or cash equivalents at its sole discretion,
class, and across sectors. based on such factors as it may consider appropriate under
the circumstances. To the extent that an account holds
Portfolio tools are used to monitor and manage the risks in assets in cash or is otherwise uninvested, an account’s
the investment strategy. We employ a fixed income ability to meet its objective may be limited.
analytics and attribution system to assist in managing and
quantifying the portfolio risks. Commodities Risk: An account’s value could be affected
by changes in the values of one or more commodities to
Material Risks which the account has indirect exposure. Commodities may
be extremely volatile, difficult to value and illiquid.
Tortoise Credit is primarily a fixed income investment Commodities may also include costs associated with
manager, although it may manage other strategies. The delivery, storage, and maintenance.
material risks of the strategies that will be pursued by
Tortoise Credit are described below. All of Tortoise Convertible Securities Risk: Convertible securities share
Credit’s investment strategies involve significant investment characteristics of both fixed income and equity
investment risk, including the risk that clients could securities. However, the value of these securities tends to
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