Advisory Business
A. General Description of Advisory Firm
YieldStreet Management, LLC (the “Adviser”, “we”, “us”, and similar terms) is a
Delaware limited liability company that was formed and commenced operations on
March 25, 2015, with principal offices located in New York, New York. The Adviser also
has offices in Miami, Florida and Athens, Greece. The Adviser is a wholly owned
subsidiary of YieldStreet Inc. (the “Website Operator”), a Delaware corporation founded
in August 2014. The sole owner of the Adviser is the Website Operator. As of January
22, 2024, the Website Operator is the indirect owner of RealCadre LLC, a Delaware
limited liability company (“RealCadre”) and CCV, LLC, a Delaware limited liability
company (“CCV”).
B. Description of Advisory Services
The Website Operator operates and manages the Yieldstreet.com online platform,
including mobile applications and any related URLs (the “Website”). The Website
allows individuals and select entities to become investors in historically difficult to
access alternative investment opportunities. Through the use of the Website,
prospective investors can browse and screen alternative investment opportunities,
view details of a prospective investment and then complete the investment process
online. Website users that decide to invest in one or more Yieldstreet Funds (as defined
below) can complete their subscription and fund their investment via the Website.
Website users may elect to receive limited, non-discretionary investment
recommendations from the Adviser for guidance in their selection of investments from
the alternative and private markets investment opportunities on the Website. Such
services are referred to herein as “Digital Advice” and “Non-Digital Advice”, as more
fully described below. Additionally, Website users may elect to receive the Adviser’s
discretionary investment advisory services – referred to herein as “Managed Portfolios”
– which are managed investment portfolios offered online through our proprietary
automated advisory service. The investment options available within these advisory
services are limited to certain Yieldstreet Funds and/or certain other investment
products managed, sponsored or issued by third parties (“Third-Party Products” and,
together with Yieldstreet Funds, “Funds”). Website users enrolled in any of these
advisory services are referred to herein as “advisory clients.”
Advisory clients and Yieldstreet Funds are referred to herein collectively as “clients”.
This Brochure may also from time to time refer to investors within the Yieldstreet Funds
as “Fund Investors”. In its capacity as the manager or investment adviser to a
Yieldstreet Fund, the Adviser provides management services and/or investment
advice, as applicable, solely to the Yieldstreet Funds, and not to individual Fund
Investors.
The descriptions set forth in this Brochure of specific advisory services that we offer to
our clients, and investment strategies pursued, and investments made by us on behalf
of our clients, should not be understood to limit in any way our investment activities.
We may offer any advisory services, and, in the case of Yieldstreet Funds, engage in
any investment strategy and make any investment, including any not described in this
Brochure, that we consider appropriate, subject to each Yieldstreet Fund’s investment
objectives and guidelines. We do not provide investment advisory services to any client
except pursuant to a written advisory agreement. The investment strategies we pursue
are speculative and entail substantial risks.
Yieldstreet Funds
The several varieties of investment vehicles managed by the Adviser are:
● Investment vehicles (operated as standalone, parallel or master-feeder-type
structures) that offer exposure to alternative investment opportunities through
issuing limited liability membership interests (each, an “Equity Issuer Fund”),
including:
o investment(s)-specific special purpose vehicles (each, an “SPV”),
o a real estate investment trust (“REIT”), which offers securities under
Regulation A of the Securities Act of 1933, as amended (the “REIT
Fund”),
o investment vehicles that act, directly or indirectly, as access funds to
investment vehicles advised by third-party investment advisers (each, an
“Access Fund”), and
o investment vehicles that hold assets other than securities (except for up
to 40% of the assets of such investment vehicle) for which the Adviser
acts solely as a manager (each, a “Company”);
● Investment vehicles that offer exposure to alternative investment opportunities
through issuing notes (each, a “Note Issuer Fund”); and
● A closed-end registered investment company (the “Closed-End Fund” and
collectively with the Equity Issuer Funds and the Note Issuer Funds, the
“Yieldstreet Funds”).
Each Yieldstreet Fund has an operating agreement or other organizational documents,
a subscription agreement, the listing on the Website and disclosure documents,
including investment memoranda or private placement memoranda, which are referred
to hereafter as “Offering Documents”. The Adviser serves as the investment adviser to
each Yieldstreet Fund (except for any Yieldstreet Fund that is a Company).
i. Equity Issuer Funds
An Equity Issuer Fund is generally a limited liability company formed by
the Adviser to serve as an investment vehicle that will fund, acquire or
originate one or more investments, in accordance with its investment
guidelines, either directly or through separate investment structures or
vehicles that provide the Equity Issuer Fund with exposure to such
investments. Equity Issuer Funds include the REIT Fund, SPVs, Access
Funds and Companies. Through the Website, prospective investors
meeting the required criteria (e.g., accredited investor, qualified client
and/or qualified purchaser), if any, may purchase membership interests in
the applicable Equity Issuer Fund to participate in the investment
opportunities. Certain Equity Issuer Funds, such as SPVs, are formed
specifically to make one or more particular investments, and such SPV’s
investment guidelines limit the Fund to making only those investments.
The assets and liabilities of each SPV are kept separate and distinct from
each other SPV and there is no commingling of funds among SPVs.
The advisory services performed by the Adviser with respect to the
applicable Equity Issuer Fund include: identifying and acquiring the Equity
Issuer Fund’s investments, which is generally accomplished through the
Adviser’s network of loan, financial asset and/or other investment
originators, asset managers, sponsors and specialty finance companies,
(each, an “Originator”) who provide access to potentially attractive
investment opportunities (or selecting a sub-adviser to provide advice
thereon); monitoring and managing each Equity Issuer Fund’s
investments; and coordinating distribution of proceeds and the ultimate
liquidation of each Equity Issuer Fund. Ultimately, each Fund Investor in
an Equity Issuer Fund chooses to invest therein, including the amount of
such investment, and the Adviser has no discretion or authority with
respect to such Fund Investor’s decisions.
ii. Note Issuer Funds
We currently manage the following categories of Note Issuer Funds:
● Delaware limited liability companies that offer multiple series of
privately-placed borrower payment dependent notes (the “ALTNOTE
Funds”);
● A Delaware limited liability company that offers multiple series of
privately-placed promissory notes with terms between 30 and 270
days (the “ST NOTE Fund”); and
● A Delaware limited liability company that offers multiple series of
privately-placed obligor payment dependent notes with terms of no
more than 270 days (the “ST STRUCTURED NOTE Fund”).
The Adviser implements the ALTNOTE Funds’ investment objectives by
creating wholly-owned special purpose investment vehicles, each of
which (a) corresponds to a series of notes and (b) funds, acquires or
originates one or more investments. Payments on each series of notes
will be dependent on payments each corresponding special purpose
investment vehicle receives (and therefore, in turn, the relevant ALTNOTE
Fund receives) on one or more specific investments.
The ST NOTE Fund similarly invests in Yieldstreet Funds. No note or
series of notes issued by the ST NOTE Fund, however, is directly
associated with any particular investment, unless specifically stated
otherwise in the ST NOTE Fund’s Offering Documents. Instead, the notes
are debt obligations that are secured by all of the assets of the ST NOTE
Fund.
The Adviser implements the ST STRUCTURED NOTE Fund’s investment
objectives by creating wholly-owned special purpose investment vehicles,
each of which (a) corresponds to a series of notes and (b) acquires one
or more investments in the form of structured notes. Payments on each
series of notes will be dependent on payments each corresponding
special purpose investment vehicle receives (and therefore, in turn, the
ST STRUCTURED NOTE Fund receives) on one or more specific
structured notes.
The Adviser manages Note Issuer Funds and, in the case of the
ALTNOTE Funds, the ST STRUCTURED NOTE Fund, their underlying
special purpose investment vehicles, and is responsible for making their
investment decisions on a discretionary basis. Ultimately, each note
purchaser chooses to invest therein, including the amount of such
investment, and the Adviser has no discretion or authority with respect to
such note purchaser’s decisions.
iii. The Closed-End Fund
The Closed-End Fund is a non-diversified, closed-end management
investment company that has registered as an investment company under
the Investment Company Act of 1940 (the “1940 Act”). The Closed-End
Fund makes investments either directly or through separate investment
structures or vehicles that provide the Closed-End Fund with exposure to
such investments. Subject to oversight and monitoring by the Closed-End
Fund’s board of directors, the Adviser has investment discretion over the
Closed-End Fund. Ultimately, each Fund Investor in the Closed-End Fund
chooses to invest therein, including the amount of such investment, and
the Adviser has no discretion or authority with respect to such Fund
Investor’s decisions. The Closed-End Fund’s shares are not currently
listed on an exchange for public trading, and we do not expect a secondary
market in the shares to develop in the foreseeable future, if ever.
To the extent permitted by the 1940 Act and staff interpretations, the
Adviser has, and in the future anticipates seeking to have, the Closed-End
Fund and one or more other investment accounts managed by the Adviser
or any of its affiliates participate in investment opportunities. On November
10, 2020, the Closed-End Fund received exemptive relief from the SEC to
engage in co-investment transactions with the Adviser and/or its affiliates,
including current and future investment vehicles on the Website, subject
to certain conditions. These co-investment transactions may give rise to
conflicts of interest or perceived conflicts of interest among the Closed-
End Fund and the other participating accounts. To mitigate these conflicts,
the Adviser and its affiliates will seek to allocate investment opportunities
for all of the participating investment accounts, including the Closed-End
Fund, pursuant to an allocation policy, taking into account relevant factors,
such as the relative amounts of capital available for new investments, the
applicable investment programs and portfolio positions, regulatory
constraints, the clients for which participation is appropriate and any other
factors deemed appropriate.
Certain Yieldstreet Funds invest in debt securities and other credit instruments across
multiple sectors, either directly or indirectly, including in direct loans to borrowers or in
participation interests or other investments in income producing assets (such as
individual or pools of loans or receivables) held by a third party (collectively, “Credit
Investments”). Such Credit Investments include, without limitation, the following:
corporate and commercial loans, consumer loans, leases, working capital loans, asset-
based financing, merchant cash advances, short-term loans, litigation financing, law
firm financing, supply chain financing, purchase order financing, retail point of sale
financing, marine finance, professional athlete loans, small business loans and other
asset-based financing or other instruments which are typically secured by interests in,
without limitation: real or personal property, equipment, vehicles and other goods and
merchandise, aircraft, receivables, pre-settlement and post-settlement cases; law firm
receivables, purchase orders, cash flow, oil or gas, artwork, and residential and
commercial mortgages.
Certain Yieldstreet Funds acquire equity or similar ownership interests in securities and
other assets including, without limitation, real estate, litigation cases, securitizations or
structured investments, merchant cash advances secured by cash flow or future
earnings, aircraft, artworks, collective investment funds, common or preferred stock in
private operating companies, and limited partnership or similar interests in investment
vehicles managed by third-party investment advisers whose portfolio companies
include, without limitation, private equity, venture capital, private credit and real estate
(“Equity Investments”). Certain Yieldstreet Funds invest in both Credit Investments and
Equity Investments. The Closed-End Fund may make Equity Investments, including
common stocks, preferred stocks, convertible securities, warrants, depositary receipts,
ETFs, equity interests in real estate investment trusts and master limited partnerships,
and may enter into certain types of derivative transactions for hedging purposes or to
enhance total return.
In accordance with the foregoing strategies, we will generally seek to acquire Credit
Investments that (i) are believed to be sufficiently backed by collateral to preserve
capital, and (ii) will generate income in accordance with our desired investment
characteristics. Given the nature and risks associated with special-situation investing,
we will generally seek to focus first on the collateral available for each Credit Investment
in order to protect principal, and then second on obtaining an appropriate return given
the term, risk and liquidity associated with each specific Credit Investment. We will
generally apply similar criteria for any Equity Investment we may acquire, with a focus
on our expected risk adjusted return on such Equity Investments.
The Closed-End Fund is sub-advised by Prytania Investment Advisors LLP, a United
Kingdom limited liability partnership (“Prytania”) pursuant to a Sub-Advisory Investment
Management Agreement (the “Sub-Advisory Agreement”). Pursuant to the Sub-
Advisory Agreement, our Adviser pays Prytania a Sub-Advisory Management Fee.
Prytania is registered as an investment adviser with the SEC under the Advisers Act
and is a quantitatively focused investment management firm specializing in structured
finance, managing and advising on portfolios that consist primarily of assets originated
in the United Kingdom, Europe and the United States.
Advisory Services
The Adviser provides limited, non-discretionary advisory services and/or discretionary
advisory services directly to certain individuals and entities in their selection of
investments from the alternative and private markets investments offered on the
Website. These advisory services are only appropriate for those investors who have
independently determined that they are considering making an investment in
alternative and private markets through the Website and elect to receive guidance
solely on selecting Funds. The Adviser provides (1) Digital Advice, which generates
recommendations through a proprietary automated advisory service, (2) Non-Digital
Advice, which provides recommendations developed by a representative of the
Adviser’s client advisory team or (3) Managed Portfolios, which generates discretionary
investment advice for investing portfolios offered online through a proprietary
automated advisory service. Due to the non-discretionary nature of Digital Advice and
Non-Digital Advice, after recommendations are provided, it is the Digital Advice
advisory client’s and Non-Digital Advice advisory client’s responsibility to decide
whether to invest in any of the recommended Funds at all and to determine the amount
to invest in each Fund (subject to applicable investment minimums and increments), in
consideration of their own overall financial goals and needs. Further, the Digital Advice
advisory client and Non-Digital Advice advisory client is responsible for effecting the
desired transactions; the Adviser does not arrange or effect the recommended
investment. The Adviser does not provide overall financial, retirement, estate, or tax
planning to any advisory client.
i. Digital Advice
Through Digital Advice (referred to as “Yieldstreet Recommendations” or
similar phrases on the Website), a prospective advisory client may elect
to receive tailored Fund investment recommendations generated by the
Adviser’s proprietary automated advisory service based on their
responses to a questionnaire regarding their alternative and private
markets investment preferences. Digital Advice is an automated and
digital investment advice experience. A Website user should not
participate in the Digital Advice program if they do not wish to or are
unable to interact digitally and to receive program-related
communications and/or documents electronically. Regular Internet
access is required to enroll in Digital Advice and to access all related
program
documents.
Prospective advisory clients complete the questionnaire to indicate, in the
context of their alternative and private markets investment preferences,
their risk tolerance, preferred investment horizon, investment style
preference and eligibility status (e.g., if such prospective client is a
qualified purchaser, qualified client and/or an accredited investor)
(“Digital Advice Preferences”) and the range for the amount to be
invested, before entering into an advisory relationship directly with the
Adviser. The questionnaire will also, for data-collection purposes only,
request information from a prospective client regarding annual income,
net worth and other items. The questionnaire allows the Adviser to obtain
information directly from the advisory client.
Based solely upon the prospective advisory client’s Digital Advice
Preferences (notwithstanding the additional questions included in the
questionnaire), the Adviser’s automated advisory service generates a
tailored investment recommendation of one or more Funds. The
Adviser’s investment recommendations will consist solely of Funds that
are available for investment on the Website at the time recommendations
are given. The Digital Advice program is limited to recommendations of
investments in one or more such Funds. The Adviser does not provide
advice as to the aggregate size of the advisory client’s Fund portfolio,
amount to be invested in each Fund, or overall financial, retirement,
estate, or tax planning. Each Fund is recommended as an individual
investment recommendation; the Fund recommendations are not
provided as a recommended portfolio of Funds. Each time Digital Advice
is requested, if more than five Funds fit the Digital Advice Preferences,
five Funds will be randomly selected as recommendations to the
prospective advisory client. If fewer than five Funds fit the Digital Advice
Preferences, additional Funds that meet some but not all of the Digital
Advice Preferences will be selected as recommendations to the
prospective client, for a total of up to five recommended Funds for each
request for Digital Advice. The prospective advisory client will be required
to review and confirm their selection of Fund(s) and investment
amount(s).
The prospective advisory client may choose to accept one or more of the
recommendations from the Adviser and determine the amount(s) to
invest. If (and only if) a prospective advisory client decides to proceed,
they will agree to a written investment advisory agreement and be
directed to read and sign the relevant Fund Offering Documents and
contribute the full amount(s) to be invested in the selected Fund(s) to
complete the investment transaction. Such prospective advisory client
will then become an advisory client of the Adviser, as well as a Fund
Investor and/or an investor in a Third-Party Product.
ii. Non-Digital Advice
Certain existing and prospective advisory clients may be eligible, at the
Adviser’s discretion, for Non-Digital Advice. Through Non-Digital Advice,
such prospective advisory clients may elect to receive personalized Fund
investment ideas, Fund allocation ideas and/or Fund portfolio reviews
from the Adviser based on their discussions with an Adviser
representative about their alternative and private markets investment
preferences. While a Non-Digital Advice advisory client receives
guidance from an Adviser representative, the advisory client must use
the Website to complete the Fund investment process and access their
online account portal. A Website user should not participate in the Non-
Digital Advice program if they do not wish to or are unable to interact
digitally and to receive program-related communications and/or
documents electronically. Regular Internet access is required to enroll in
Non-Digital Advice and to access all related program documents.
Subsequent to conversations with an Adviser representative, prospective
advisory clients eligible for Non-Digital Advice can enter into an advisory
relationship with the Adviser by agreeing to a written investment advisory
agreement. Based on the advisory client’s responses to the
questionnaire or a substantially similar survey or discussion (written or
verbal) with the advisory client, a representative from the Adviser’s
advisory team develops Fund recommendations and/or sample Fund
portfolios with allocations and/or conducts Fund portfolio reviews,
depending on the scope of the services which are agreed upon between
the Adviser and the advisory client. Unless otherwise agreed in writing,
the Adviser does not consider the advisory client’s pre-existing portfolio
of Fund investments or any other investments. The Adviser’s investment
recommendations will consist solely of Funds that are available or may
soon become available for investment on the Website at the time
recommendations are given. The Non-Digital Advice program is limited
to recommendations of investments in one or more such Funds. Upon
receiving Fund recommendations and/or allocation recommendations,
the advisory client will be required to review and confirm their selected
Fund(s) and investment amount(s). The advisory client will then be
directed to read and sign the relevant Fund Offering Documents and
contribute the full amount(s) to be invested in the selected Fund(s) to
complete the investment transaction through the Website.
iii. Managed Portfolios
An advisory client enrolled in a Managed Portfolio will receive
discretionary investment advice generated by the Adviser’s proprietary
automated advisory service with respect to a designated account funded
by the advisory client (the “Managed Portfolio Account”). Discretionary
trading authority permits the Adviser to select which securities to buy and
sell and when to place orders for the execution of securities in Managed
Portfolio Accounts on the advisory client’s behalf. A Managed Portfolio is
an automated and digital investment advice experience. A Website user
should not participate in the Managed Portfolios program if they do not
wish to or are unable to interact digitally and to receive program-related
communications and/or documents electronically. Regular Internet
access is required to enroll in Managed Portfolios and to access all
related program documents.
Following completion of the eligibility and suitability questionnaires (the
“Suitability Questionnaire”), the Adviser will recommend an investment
strategy to the prospective advisory client with respect to the Managed
Portfolio Account based on their responses to the Suitability
Questionnaire, and the prospective advisory client may select the
investment strategy to be applied to the account. The prospective
advisory client completes the enrollment process by entering into an
advisory relationship directly with the Adviser and confirming via the
Suitability Questionnaire that it meets the basic requirements of a
prospective advisory client, opening the required brokerage and custodial
accounts, and funding the Managed Portfolio Account. An advisory client
acknowledges that it will be unable to adjust its selections or withdraw
any amounts from its Managed Portfolio Account for a period of one year
following the date of its enrollment into Managed Portfolios. Once an
advisory client is enrolled in Managed Portfolios, an advisory client will
not have the ability to directly buy or sell investments in its Managed
Portfolio Account, or to direct the Adviser to buy or sell investments in its
Managed Portfolio Account.
The investment advice generated is based on investment guidelines
selected for the Managed Portfolio Account. The investment products
available through the Managed Portfolio program are limited to certain
Funds selected by the Adviser as part of each investment strategy offered
and such Funds may be supplemented with additional Funds or adjusted
in the sole discretion of the Adviser. The Adviser does not provide advice
as to the overall investment portfolio of advisory clients (including, but not
limited to, the appropriate aggregate size of the advisory client’s
Managed Portfolio or the appropriate composition of the investments in
advisory client’s Managed Portfolio when combined with the investments
of the advisory client held outside of the Managed Portfolio), or overall
financial, retirement, estate, or tax planning. Adviser will provide
discretionary advisory services only with respect to the enrolled Managed
Portfolio Account and will not otherwise provide any services with respect
to an advisory client’s assets not included in such account.
Digital Advice, Non-Digital Advice and Managed Portfolios are distinct and separate
services offered by the Adviser. If an advisory client elects to receive more than one
type of service, information outside of the questionnaire provided under one type of
service will not be considered in the provision of another type of service. Each type of
advisory service employs a different questionnaire. For example, the investment
recommendations received by an advisory client pursuant to the Digital Advice program
relies solely on the Digital Advice Preferences from the questionnaire and does not
take into account such advisory client’s prior Fund investments made through the
Website directly or through previously received Digital Advice, Non-Digital Advice or
Managed Portfolio advice. Non-Digital Advice may or may not, in the Adviser’s
discretion, take into consideration responses to the questionnaire as well as various
discussions and other communications between Adviser representatives and the
advisory client. Recommendations made to an advisory client pursuant to one type of
service may differ because the investment preferences used for one type of service
may differ from the investment preferences provided by the advisory client to the
Adviser or Adviser representative for another type of service, and because of the
differences in the information used and differences in how that information is used and
analyzed in formulating the recommendations. Use of any other interactive tools on
the Website or submissions of any other questionnaire or survey on the Website or
otherwise to the Adviser or its affiliates will not update an advisory client’s questionnaire
responses or other account profiles used by the Adviser in providing any of these
advisory client services.
C. Availability of Tailored Services for Individual Yieldstreet Funds and
Advisory Clients
i. Yieldstreet Funds
Our investment decisions and advice with respect to each Yieldstreet
Fund will be subject to each Yieldstreet Fund’s investment objectives and
guidelines, as set forth in its respective Offering Documents. Fund
Investors and prospective Fund Investors should refer to the Offering
Documents for the applicable Fund for complete information regarding the
investment restrictions and other information with respect to a Fund.
ii. Advisory Clients
For Digital Advice, investment recommendations for advisory clients are
generated by the Adviser’s software-based automated advisory service,
which excludes and selects Funds based upon the advisory client’s Digital
Advice Preferences from the questionnaire. The Digital Advice program
builds upon the due diligence process run by the Adviser’s team of
investment professionals for each investment opportunity. During the due
diligence process, the Adviser analyzes the characteristics for each Fund
that are relevant to the Digital Advice Preferences such as investment
style, investment time horizon, and risk rating. Each Fund is assigned a
risk rating (i.e., Conservative, Moderate, Aggressive or Aggressive Plus)
and investment style by the Adviser. For purposes of the Digital Advice
programs, any Conservative risk rating assigned to a Fund will be
regarded as a Moderate risk rating. The Digital Advice service is
developed and managed by the Adviser’s product team in collaboration
with the investment teams and the portfolio risk management team.
For Non-Digital Advice, investment recommendations are generally based
on the advisory client’s responses to the questionnaire or a substantially
similar survey or discussions with the advisory client. The Adviser’s
representatives will also utilize the risk ratings and other characteristics
referenced above with respect to Digital Advice.
For Managed Portfolios, tailored investment advice is generated by the
Adviser’s software-based automated advisory service, which selects and
allocates among Funds based on the advisory client’s selected investment
strategy and guidelines as agreed between the Adviser and the advisory
client. When an advisory client agrees to the allocation recommended by
the Adviser’s software-based automated advisory service, such client will
open a Managed Portfolio Account and accept and electronically sign the
Yieldstreet Client Advisory Agreement (“Advisory Agreement”). The
Adviser’s software-based automated advisory service will guide an
advisory client through the account opening process. By electronically
signing the Advisory Agreement, an advisory client grants discretion over
the Managed Portfolio Account to the Adviser and it authorizes the Adviser
to invest and reinvest the assets in the Managed Portfolio Account in
accordance with the allocation model agreed to by the advisory client. The
scope of any investment advisory relationship the Adviser has with an
advisory client is defined in the Advisory Agreement. When an advisory
client is enrolled in Managed Portfolios, the Adviser acts as such advisory
client’s investment adviser only for its Managed Portfolio Account and not
for any other assets or accounts, unless otherwise separately agreed to
by the Adviser in writing. The Adviser’s advisory relationship with an
advisory client begins when the Adviser enters into an Advisory
Agreement with the advisory client. Preliminary discussions or
recommendations before the Adviser enters into an Advisory Agreement
with an advisory client are not intended as investment advice under the
Advisers Act and should not be relied on as such.
D. Other Website Operator Services
i. The Yieldstreet Wallet
The Website Operator, an affiliate of the Adviser, has entered into an
arrangement (through a third-party banking services provider) with Evolve
Bank, an unaffiliated FDIC insured bank, whereby Website users establish
an account at Evolve Bank – entitled the Yieldstreet Wallet – to deposit
funds and/or purchase investments on the Website. The Website Operator
may in the future enter into similar arrangements with other third-party
banking services providers and banks and in its sole discretion, pursuant
to any applicable agreements, conclude its relationship with Evolve Bank
or any similar provider. Investors deposit funds in their Yieldstreet Wallet,
and such money is available to be used to efficiently process investment
subscriptions on the Website. The Website Operator also uses the
Yieldstreet Wallet to process distributions from investments, as well as
cash rewards earned by a Website user from referral programs, incentive
programs and other reward opportunities. The Website Operator is a non-
advisory affiliate of the Adviser, and the Yieldstreet Wallet is a service
offered by the Website Operator, rather than the Adviser, in order to
improve the usability of the Website. In the future, the Website Operator
may offer additional services relating to the Yieldstreet Wallet, including
credit card and debit card services. Please see Item 10 for further
information relating to the Yieldstreet Wallet. As used herein, the term
“Yieldstreet Wallet” includes such other wallets, as the context permits.
ii. Individual Retirement Arrangements
The Website Operator, an affiliate of the Adviser, provides a service -
entitled the Yieldstreet IRA - to assist investors in creating Individual
Retirement Arrangements (“IRAs”) with IRA custodians that are
unaffiliated with either the Website Operator or the Adviser. Funds are
transferred from investors’ other IRAs or rolled over from qualified plans
into the IRAs to be available to invest. Funds are transferred directly into
the Yieldstreet Wallet described in Item 4, Section D, in the name of a
revocable trust distinctly owned by each individual IRA.
The Website Operator charges a facilitation fee for the Yieldstreet IRA in
the form of an annual fee for the service. This fee generally ranges
between $299 and $399, depending on the value of the IRA at the end of
each calendar year. Annual fees may be waived for certain promotions.
Further, the Website Operator has partnered with a certain unaffiliated IRA
custodian (and may in the future partner with other unaffiliated IRA
custodians) to provide a service so that the holders of self-directed
individual retirement accounts with that unaffiliated IRA custodian are able
to direct investments in investment opportunities on the Website without a
Yieldstreet Wallet or Yieldstreet IRA. Accounts held at such unaffiliated
IRA custodian are subject to the fees, expenses and terms determined by
the custodian or as arranged between the Website Operator and the
custodian.
E. Wrap Fee Programs
The Adviser does not participate in wrap fee programs.
F. Assets Under Management
The Adviser managed approximately $1,218,995,681 in regulatory assets under
management on a fully discretionary basis, determined as of December 31, 2023.
Pursuant to the instructions for the Form ADV, portfolios that are excluded from the
definition of “securities portfolios” or accounts with respect to which we do not provide
continuous and regular supervisory or management services are not included in the
Adviser’s regulatory assets under management.