business. Identify your principal owner(s).
Notes: (1) For purposes of this item, your principal owners include the
persons you list as owning 25% or more of your firm on Schedule A of
Part 1A of Form ADV (Ownership Codes C, D or E). (2) If you are a
publicly held company without a 25% shareholder, simply disclose
that you are publicly held. (3) If an individual or company owns 25%
or more of your firm through subsidiaries, you must identify the
individual or parent company and intermediate subsidiaries. If you
are an SEC-registered adviser, you must identify intermediate
subsidiaries that are publicly held, but not other intermediate
subsidiaries. If you are a state-registered adviser, you must identify all
intermediate subsidiaries.
Medley Partners, a Delaware limited liability company, is a California-
based fund-of-funds manager that manages private investment funds and
other accounts which invest primarily in limited partnerships across the
private asset classes, including buyout, growth equity, venture capital, real
estate and credit in the United States, Europe and Asia. Medley Partners
was founded in 2007 by Mr. Mark Heising, the son-in-law of Mr. James
Simons, for the purpose of managing the private investments of the
philanthropic foundations affiliated with Mr. Simons’ family (including
but not limited to the Simons Foundation, the Heising-Simons Foundation,
the Foundation for a Just Society, and the Sea Change Foundation) as well
as certain other family entities. Prior to January 1, 2018, Medley Partners
was wholly owned by Mr. Heising and therefore excluded from regulation
under the Investment Advisers Act of 1940 (“Advisers Act”) pursuant to
the definition of “family offices” under Advisers Act Rule 202(a)(11)(G)-
1.
Effective January 1, 2018, Medley Partners restructured its organization
such that Medley Partners is now wholly owned by Medley Partners
Advisors, L.P., and concurrent therewith, Mr. Heising transferred a portion
of his ownership interest in Medley Partners Advisors L.P., to a group of
individuals who currently operate Medley Partners as executive officers or
in similar capacity, with each owning less than 25%.
Medley Partners’ investment advisory services are provided primarily to
the private investment funds (the “Funds”), all of which are domiciled in
Delaware as either limited partnerships or limited liability companies, and
whose beneficial owners are the aforementioned foundations and/or family
members or entities.
In addition, Medley Partners also provides discretionary investment
advisory services to other separately-managed accounts beneficially
owned by the aforementioned foundations (the “SMAs” and together with
the Funds, the “Advisory Clients”).
Affiliates of Medley Partners serve as the general partners of the Funds
(the “Affiliated General Partners”). Each of the Affiliated General
Partners is controlled by or under common control with Medley Partners.
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.
Medley Partners presently provides investment advisory services solely to
the Advisory Clients. Medley Partners does not solicit other advisory
clients or seek investors in the Funds that are not affiliated with the families
or foundations of Mr. Heising, Mr. Simons and their families.
On behalf of the Advisory Clients, Medley Partners provides investment
management and supervisory services with regard to the selection,
monitoring, reporting and realization of investments, principally in limited
partnership interests of professionally managed private equity, venture
capital, real estate and private credit funds in the United States, Europe and
Asia (the “Portfolio Funds”). The Portfolio Funds are managed by third-
party professional managers (“Portfolio Managers”). In some instances,
Medley Partners also provides investment management services with
respect to co-investments in privately held operating companies.
Generally, the beneficial owners of the SMAs are also investors in the
Funds; the SMAs were established to provide an opportunity for the
beneficial owners of the SMAs to acquire additional interests in the
underlying Portfolio Funds. As a result, the Funds take priority over the
interests of the SMAs in all instances where there is a limited investment
opportunity in a Portfolio Fund.
the individual needs of clients. Explain whether clients may impose
restrictions on investing in certain securities or types of securities.
Medley Partners provides investment advisory services to the Advisory
Clients based upon the criteria set forth in the limited partnership
agreements or operating agreements. Individual investors in the Funds do
not have the ability to impose restrictions on Medley Partners’ investments
in certain securities or types of securities.
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.
Not applicable. Medley Partners does not participate in wrap fee
programs.
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.
Note: Your method for computing the amount of “client assets you
manage” can be different from the method for computing “assets
under management” required for Item 5.F in Part 1A. However, if you
choose to use a different method to compute “client assets you
manage,” you must keep documentation describing the method you
use. The amount you disclose may be rounded to the nearest $100,000.
Your “as of” date must not be more than 90 days before the date you
last updated your brochure in response to this Item 4.E
As of December 31, 2023, Medley Partners manages $6,298,284,854 on a
discretionary basis.