Reflow Services, LLC

ReFlow Services, LLC is an investment adviser firm established in 2010 and headquartered in San Francisco, California. The firm specializes in providing investment advisory services to an unregistered pooled investment vehicle subject to Rule 3(c)(7) under the Investment Company Act of 1940. ReFlow manages approximately $333.8 million in assets under management as of December 31, 2024, all on a discretionary basis. For clients, the firm generally charges a 1.00% annual management fee, which may vary based on the client's assets and agreement structure. ReFlow is also entitled to receive a performance fee based on a share of capital gains, subject to specific provisions. The firm engages in investment strategies involving various securities, derivatives, and currencies, with a focus on generating fee-driven alpha and capital appreciation. ReFlow acts as a fiduciary, with a Code of Ethics in place to ensure ethical conduct and compliance with securities laws. The firm has discretion over client accounts, allowing it to manage securities without client consultation on a transaction-by-transaction basis. ReFlow reviews accounts daily and provides monthly statements to clients for transparency. The firm has not received economic benefits for client referrals and does not have custody of client assets. ReFlow votes proxies in line with mutual fund recommendations and considers factors such as shareholder value and accountability in proxy voting decisions. The firm does not expect material conflicts of interest between itself and clients in proxy voting. ReFlow does not have any reportable disciplinary events, and its financial condition is stable. The firm is not registered with any state securities authority. Clients can request additional information, including the firm's Code of Ethics and proxy policy, for a comprehensive understanding of ReFlow's practices and services.