Cloverlay Investment Management, LLC

Cloverlay Investment Management, LLC, established in June 2015, is a registered investment adviser specializing in providing investment advisory services to private funds. The firm manages approximately $1.57B in regulatory assets under management, with $767M on a non-discretionary basis as of December 31, 2024. Cloverlay's investment objective is to achieve attractive long-term returns primarily through private equity investments in various sectors. The firm offers different investment vehicles tailored to clients' taxable, tax-exempt, ERISA plan asset, or non-U.S. status. Clients participate in the overall investment objective of the Funds managed by Cloverlay on a discretionary basis. The firm charges management fees ranging from 0.70% to 1.25% based on commitments or net invested capital, with rates decreasing after the investment period expires. Cloverlay may earn performance-based compensation based on the Fund's return. The firm's investment philosophy focuses on generating long-term returns through private market investments globally. Clients include institutions, family offices, and high net worth individuals meeting specific investor requirements. Cloverlay's Code of Ethics emphasizes client interests, honesty, and fair dealings. The firm does not engage in soft dollar arrangements and allocates transactions fairly based on client-specific factors. Cloverlay exercises investment discretion in accordance with each Fund's governing documents and provides proxy voting services for client securities. The firm maintains audited financial statements for clients and complies with custody requirements under SEC regulations. Cloverlay's financial condition is sound, ensuring the ability to meet contractual commitments.