General Description of 3650IM
3650 Holdings LP (“Holdings” and, together with its affiliated entities, “3650” or the “Firm”)
was formed to be an integrated commercial real estate (“CRE”) investment and services firm with
activities across CRE debt and equity sectors. Holdings is the indirect parent company of 3650IM.
3650IM, a Delaware limited liability company and a registered investment adviser, was founded
in October 2016. Toby Cobb, Justin Kennedy and Jonathan Roth, are the Managing Partners of
3650 and collectively own a majority of 3650IM through their ownership in Holdings.
The Firm comprises the following businesses, among others: investment and risk management,
capital markets, asset management, loan and preferred equity origination/underwriting, and
servicing. Each of these business areas is part of 3650’s vertically integrated platform (i.e., each
business area contributes in a fundamental way to the analysis, origination or management of client
investments) and its investment strategy. For more information regarding these businesses and
related conflicts, please refer to Item 5 and Item 10 below.
In addition to its main office in Miami, Florida, 3650IM provides investment management services
from offices in New York, New York and Beverly Hills, California.
Description of Advisory Services
3650IM provides CRE-related advisory services principally regarding debt including mortgages,
structured finance products, bridge lending, preferred equity, direct equity investments in CRE and
other investment opportunities. All 3650IM strategies seek to emphasize the vertically integrated
approach facilitated by its platform infrastructure.
Currently, 3650IM provides investment advisory services to co-investment vehicles and joint
ventures (each, a “JV”) that pursue one of two currently available investment strategies: (1) a first
lien, fixed-rate, target loan strategy or (2) a bridge-and-event-driven strategy (e.g., bridge lending,
construction lending, preferred equity) that invests in participation interests in loans originated by
an affiliate of 3650IM. The JVs at times employ their respective investment strategy by investing
all of their assets in a designated subsidiary real estate investment trust (“REIT”) and/or a
designated subsidiary investment vehicle (“SubCo”) that originates and acquires a number of
commercial real estate loans and certain other commercial real estate debt investments. 3650IM
also provides advisory services to vehicles (“SS Vehicles”) employing a special situation strategy.
3650IM expects to provide similar services to other clients in the future (such future clients,
together with the JVs, and the SS Vehicles, the “Clients” and each a “Client”).
Notwithstanding the fact that 3650IM does not consider REITs, SubCos wholly owned by Clients
or intermediate holding companies, to be investment advisory clients, for ease of review “Clients”
includes the designated subsidiary REITs and SubCos of the JVs, unless the context otherwise
requires. 3650IM also offers CRE-related advisory services regarding singular, one-off,
opportunistic transactions.
The advisory services provided each Client
and any limitations thereon are detailed in each
Client’s governing documents, offering documents, investment management agreement or similar
agreement with 3650IM, as applicable (“Operative Documents”).
Various entities that are affiliated with the 3650 serve as general partners (each, a “General
Partner”) to certain of our Clients. 3650 Bridge Cal – SMA Manager LLC (“Manager”) is a
relying adviser and serves as the managing member and adviser to one of our Clients. As
applicable, references to 3650IM herein shall include the General Partners and/or the Manager.
Please see “Other Financial Industry Activities and Affiliations” below for a further discussion of
certain entities affiliated with 3650IM. These affiliates are also disclosed in the Part 1A of
3650IM’s Form ADV.
3650IM does not participate in wrap fee programs and does not manage wrap fee accounts.
Co-Investments.
3650IM or its affiliates have provided in the past and anticipate providing in the future co-
investment opportunities to one or more strategic and relationship co-investors. Subject to any
contractual obligations to a Client or the underlying investors of a Client regarding co-investments,
3650IM, in its sole discretion, will determine the potential strategic and relationship co-investors,
which will include persons that provide, or are expected to provide, strategic benefits in connection
with sourcing or consummating the investment opportunity or following consummation of the
investment, such as operational or similar strategic benefits, committed financing or lending
support, certainty or expediency of closing, support in diligence or industry expertise, benefits to
the investment in terms of regulatory or tax profile, or otherwise.
Availability of Tailored Services.
3650IM manages each Client in accordance with its governing documents and investment
management agreement which include negotiated guidelines, restrictions regarding investments
and other investment criteria and certain consent requirements including, but not limited to,
consent rights with respect to: (1) any origination, acquisition or financing of any loan or other
investment made by the JV the securitization of loans, (2) certain work-out decisions relating to
the loan assets, (3) certain dispositions of investments and (4) certain other actions taken by the
JV (including action taken by parallel investment holding companies and REITs). Each JV has
been tailored to meet specific investor requirements including, e.g., (1) investment type (e.g.,
senior secured or mezzanine loans), (2) portfolio diversification (e.g., loan size and property type)
and (3) loan maturity (e.g., minimum and maximum terms). Advisory services regarding singular,
one-off, opportunistic transactions also are tailored to meet specific investor preferences.
Client Assets Under Management.
As of December 31, 2023, 3650IM had regulatory assets under management of approximately
$2,726,645,343, of which approximately $1,173,986,485 were managed on a discretionary basis
and approximately $1,552,658,858 were managed on a non-discretionary basis.