Advisory Firm
Flat Footed is a Delaware limited liability company that commenced operations in August 2016 and
is owned by Mr. Marc Andersen and co-managed by Mr. Andersen and Mr. Paul Carpenter.
Advisory Services
The Adviser currently provides investment management services and discretionary investment
advice to private funds (each, a “Fund” and, collectively, the “Funds”) and one or more sub-advisory
account Clients (“Sub-Advisory”) and may serve as investment adviser and/or sub-adviser to various
other advisory clients, including separately managed accounts, fund of one accounts, and other
private investment funds (collectively, “Clients”).
Relying Adviser
The Adviser offers investment advisory services to a Fund through Post Union Management LLC,
which is under the common control with Flat Footed (the “Relying Adviser”). Flat Footed and the
Relying Adviser are collectively referred to as the “Adviser” in this document.
Specialization
The investments of each Fund are managed in accordance with the investment objectives, strategies
and guidelines applicable to such Fund and are not tailored to any particular investor in the Fund (an
“Investor”). The Adviser does not provide individualized investment advice to such Investors with
respect to their investment in the Fund; therefore, Investors should consider whether a particular
Fund meets their investment objectives, risk tolerance, and financial situation.
In addition, the Adviser may enter into arrangements with certain Clients (or underlying Investors)
that may in each case provide for terms of investment that are more favorable to the terms provided
to other Clients (or underlying Investors). Such
terms may include the waiver or reduction of
management and/or incentive fees, the provision of additional information or reports, more
favorable transfer rights, and more favorable liquidity rights.
Advisory Services to Sub‐Advisory Accounts
Investments for Sub-Advisory account Clients, whether separately managed accounts or fund of one
accounts, are managed in accordance with the Clients’ investment objectives, strategies, restrictions
and guidelines as set forth in the documents governing the Adviser’s relationship with such Clients or
as otherwise communicated to the Adviser by the Clients. Depending on the nature of the
relationship, these services may be offered on a discretionary or non-discretionary basis and may
include the investment and reinvestment of securities, cash and cash equivalents, futures and options
held in a Client’s account. If a Client wishes to impose certain restrictions on investing in certain
securities or types of securities or is prohibited by applicable law from investing in such securities or
types of securities, the Adviser will address those requests on a case-by-case basis.
Wrap Fee Programs
The Adviser does not participate in wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2023, the Adviser manages approximately $869,628,000 on a discretionary basis
and $0 on a non- discretionary basis.
Supervised Persons
All supervised persons acting on behalf of the Relying Adviser are also supervised persons of Flat
Footed. In addition, Flat Footed and the Relying Adviser operate under a single code of ethics (the
“Code”) and compliance manual that is administered by the Adviser’s Chief Compliance Officer (the
“CCO”).