Two Prime LLC

Two Prime Inc. is an investment adviser registered with the SEC since 2019, specializing in separately managed accounts (SMAs). The firm exercises investment discretion for clients and manages assets totaling approximately $400,000,000 as of December 31, 2024. Two Prime's ownership structure includes individuals such as Marc Fleury and Alexander Blume. The firm primarily offers discretionary advisory services for limited types of investments, with potential expansion into other investments in the future. Clients are charged asset-based fees paid quarterly in arrears, as outlined in each client's Management Services Agreement. Two Prime may receive performance-based fees of up to 20% for certain client accounts, with a focus on managing risks associated with cryptocurrency assets like Bitcoin and Ethereum. The firm's investment strategy involves a derivative overlay approach to hedge against downward volatility and capture upside potential. Clients receive monthly reports on performance and allocation, and the firm conducts regular account reviews and reconciliations. Two Prime does not engage in directed brokerage or accept compensation for client referrals. The firm has custody of certain client accounts and conducts annual surprise audits. Two Prime operates with investment discretion for all client accounts and votes proxies in the best interests of clients, primarily focusing on maximizing value. The firm has no financial commitments impairing its ability to meet client obligations and has not been subject to bankruptcy proceedings.