Item 5 Fees and Compensation 4 Item 6 Performance-Based Fees and Side-By-Side Management 6 Item 7 Types of Clients and Account Requirements 6 Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss 6 Item 9 Disciplinary Information 8 Item 10 Other Financial Industry Activities and Affiliations 8 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 8 Item 12 Brokerage Practices 9 Item 13 Reviews of Accounts 9 Item 14 Client Referrals and Other Compensation10 Item 15 Custody10 Item 16 Investment Discretion10 Item 17 Voting Client Securities (Proxy Voting)10 Item 18 Financial Information11 Part 2B Supplements for: Julian Galvez12 Michael Brown13 Santiago Bouquet Roldan14 Kenneth Martin Bell15 Donald Luis Smith16 Fenix Asset Management, LLC (“Fenix”) is an investment advisory firm located in New York City, New York. Fenix was organized as a Limited Liability Company organized in the State of Delaware on October 18, 2017. The Firm also operates under the name Fenix Trading which is a trade name primarily used for marketing purposes and not the name of any incorporated or affiliated corporate entity. Any reference to Fenix Asset Management in this brochure should be considered to also refer to any activities provided under the name Fenix Trading.
As of January 31, 2023, Fenix had approximately $67,949,700.- in assets under management (“AUM”) on a discretionary basis and approximately $472,582.- under management on a non-discretionary basis.
Prior to engaging Fenix to provide investment advisory services, each client is required to enter into an Advisory Agreement (“AA”) with Fenix that defines the terms, conditions, authority and responsibilities of Fenix and the Client.
Currently, Fenix Asset Management provides the following investment advisory services: Investment Management and Supervision Fenix Asset Management has entered into agreements with Non-U.S. Investment Advisors domiciled outside the United States. These “Foreign Advisors” affiliated with Fenix Asset Management and may or may not be registered with any regulatory investment authority in the country of domicile of the client.
Foreign Advisors will refer non-U.S. clients to Fenix Asset Management which will facilitate the opening of one or more U.S.-based brokerage accounts on behalf of the advisory client. Advisory accounts may be established on either a

discretionary or non-discretionary basis. A discretionary account gives the Foreign Advisor limited discretionary authority over the client accounts and permits them to execute orders to buy or sell securities in client accounts without contacting the client. A non-discretionary account permits the Foreign Advisory to execute orders to buy or sell securities in client accounts only after contacting and receiving consent from the client. All advisory accounts, both discretionary and non-discretionary, do not permit the Foreign Advisor authority to initiate any movement of client funds or the transfer of client securities into, out of, or between client accounts.
Unless the client directs us to use a different broker-dealer, all U.S.-based brokerage accounts for advisory clients will be established through Fenix Securities, a U.S. brokerage firm and an affiliate of Fenix Asset Management. Fenix Securities has contracted with a qualified U.S. clearing firm to execute, clear and settle securities transaction conducted within the client account. The clearing firm will also be the custodian of the client funds and securities which will be maintained in a separate account, for the Client, under Client’s name. The client will retain rights of ownership of all securities and funds in the account to the same extent as if the client held the securities and funds outside their advisory account. Clients will receive from the clearing/custodian firm timely confirmations and at least quarterly statements containing a description of all transactions and all activity conducted within the client brokerage account (See sections titled “Custody” and “Other Financial Industry Activities and Affiliations”).
Fenix Asset Management willconsult with the Foreign Advisors and will assist with such matters as the collection, review and approved of account opening documentation to determine the client’s financial situation, investment objectives, time horizon and risk tolerance. Fenix Asset Management will also provide on-going supervision of client advisory accounts based on these criteria.
Fenix Asset Management seeks to provide that investment decisions are made without placing the interests of Fenix Asset Management ahead of its clients. To meet its fiduciary obligations, Fenix attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage any client account.