A. Describe your advisory firm, including how long you have been in business. Identify
your principal owner(s).
Firm Description
RGP is an investment management firm focused on investing in insurance-linked instruments and
products. Formed in 2011, RGP seeks to opportunistically participate in the insurance and reinsurance
market with the primary objective of achieving risk-adjusted returns superior to those available in the
capital markets.
RGP, a limited liability company incorporated under the laws of Bermuda, serves as the Investment
Manager for and provides discretionary investment advisory services to The 1609 Fund Ltd. (the
“Fund”), a Bermuda exempted company, which has been classified by the Bermuda Monetary
Authority as an institutional fund pursuant to the Investment Funds Act, 2006 of Bermuda. The Fund
offers investors a diversified portfolio of direct insurance and reinsurance exposure, operating as a
multi-strategy vehicle investing across different lines of insurance including property catastrophe,
marine, energy, crop, aviation, aerospace, and U.S. auto, among others.
The Fund currently offers six series of shares: Series 1 Shares, Series 2 Shares, Series 3 Shares, Series
4 Shares, Series 5 Shares and Series O Shares, which have different fee schedules as described more
fully below in Items 5 and 6 and in the Fund’s offering memorandum. RGP may in the future provide
investment management services to additional funds.
RGP has overall responsibility for managing the business and affairs of the Fund in its capacity as
Investment Manager of the Fund. RGP has been appointed as Investment Manager to the Fund
pursuant to an investment management service agreement entered into between the Fund and RGP.
To facilitate the Fund’s access to the traditional reinsurance market, RGP has established Prospero
Re Ltd. (“Prospero”), a class 3a segregated account Bermuda registered reinsurance company.
Prospero issues preference shares to the Fund which are linked to reinsurance contracts. Prospero has
an ‘A’ rating from Kroll Bond Rating Agency LLC (“KBRA”). RGP is the insurance manager of
Prospero and currently expects that all reinsurance-related transactions for the Fund will be entered
into with Prospero rather than through a third-party reinsurance company. The main purpose of using
Prospero is to eliminate the “mark-up” that would otherwise be charged to the Fund by a third-party
reinsurance company. RGP owns 100% of the voting shares of Prospero. The Fund, in turn, owns
100% of the preference shares of Prospero.
To access the primary insurance market, the Fund has taken an equity interest in Producers National
Corporation (“PNC”), an Illinois domiciled holding company. Through PNC and its related entities,
including Unique Insurance Company and Stonegate Insurance Company, the Fund is able to access
and analyze opportunities in the primary insurance market. The Fund’s relationship with PNC
eliminates the “mark-up” that would otherwise be charged to the Fund by a third-party insurance
company. The Fund owns 97% of the voting stock of PNC and maintains control of the Board of
Directors. Furthermore, to access opportunities at Lloyd’s of London, RGP has formed a Lloyd’s
Corporate Member (“RGP Corporate Member”). Through this entity the Fund is able to participate
in specific Lloyd’s syndicates.
RGP is also affiliated with the following related parties:
RGP owns 100% of the voting shares of Boatswain Capital Management Ltd (“Boatswain”),
a private company incorporated in the United Kingdom in July 2015 to act as a corporate
partner to ILS Capital Management UK LLP (“ILS UK”).
ILS UK is a limited liability partnership incorporated in the United Kingdom in July 2015. ILS
UK is under complete supervision by RGP. ILS UK identifies potential insurance contracts
within a pre-determined strategy and assists with modelling of insurance contracts, subject to
the review and approval of RGP.
ILS Capital Management LLC (“ILS U.S.”) is a limited liability company organized in the State
of Connecticut, U.S.A. in August 2011. ILS U.S. provides investor relations services for RGP’s
clients and prospective clients (but does not act as a placement agent), develops and assists
with modelling of insurance contracts for RGP and provides back-office
support, as directed
by RGP.
Principal Owners/Ownership Structure
RGP is employee owned, with the Managing Partners, Thomas Libassi and Paul Nealon owning a
controlling stake.
B. Describe the types of advisory services you offer. If you hold yourself out as
specializing in a particular type of advisory service, such as financial planning, quantitative
analysis, or market timing, explain the nature of that service in greater detail. If you provide
investment advice only with respect to limited types of investments, explain the type of
investment advice you offer, and disclose that your advice is limited to those types of
investments.
RGP provides discretionary investment management services to the Fund. The Fund seeks to
capitalize on insurance-linked instruments and products by offering investors a diversified portfolio
of direct insurance and reinsurance exposure. It invests across different lines of reinsurance including
property catastrophe, marine, energy, crop, aviation, aerospace and weather, as well as a range of
insurance lines including U.S. auto and specialty insurance. The Fund’s ability to access and analyze
diverse business lines allows for the tactical allocation of capital to sectors of the market that are
experiencing dislocation – capturing yield and moderating downside risk.
In addition, the Fund has utilized equity and debt instruments of participants in the insurance industry.
These instruments enable the Fund to access sectors of the insurance and reinsurance market that
may not be attractive to the Fund on a fully collateralized basis. Such investments also help the Fund
to reduce costs and control risk selection.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual
needs of clients. Explain whether clients may impose restrictions on investing in certain
securities or types of securities.
The advisory services provided by RGP to the Fund are tailored to the investment objectives,
investment strategy and investment restrictions as set forth in the Fund’s governing documents. RGP
provides investment advice directly to the Fund and not to investors in the Fund individually. RGP
does not require, nor does it seek, approval from the Fund or the investors in the Fund with respect
to its trading decisions.
Although RGP does not tailor its advisory services to the individual needs of investors in the Fund,
in order to comply with certain legal and regulatory requirements, there may be instances when an
investor in the Fund may not participate in an investment by the Fund and appropriate measures will
be taken by the Fund to comply with such laws and regulations. The Fund or RGP, however, may,
from time to time, enter into side letters or similar agreements with certain investors that have the
effect of establishing rights under, or altering or supplementing the Fund’s governing documents.
Such rights include notification and disclosure rights, certain fee arrangements, transfer rights and
certain withdrawal or redemption rights, among others. To date, no investors have limited RGP’s
ability to invest in certain investments or types of investments.
Due to the nature of its investments and structure of the Fund, investors in the Fund may receive
different portions of investments or may not receive any portion of an investment. Participation in a
particular investment will depend upon, among other factors, available cash in an investor’s account
and the timing of the investment cycle.
D. If you participate in wrap fee programs by providing portfolio management services,
(1) describe the differences, if any, between how you manage wrap fee accounts and how you
manage other accounts, and (2) explain that you receive a portion of the wrap fee for your
services.
RGP does not participate in wrap fee programs.
E. If you manage client assets, disclose the amount of client assets you manage on a
discretionary basis and the amount of client assets you manage on a non-discretionary basis.
Disclose the date “as of” which you calculated the amounts.
As of December 31, 2023, RGP managed $317,799,459 in net assets, all of it on a discretionary basis.