The Firm
CanAm Capital Management, LLC (“CACM” or the “Firm”) is an investment adviser with its
principal place of business in New York, New York. CACM is a limited liability company that was
formed on September 21, 2010, under the laws of the State of Delaware. The Firm has several
affiliated entities that, historically, have served investors who participate in the EB-5 Immigrant
Investor Program (the “EB-5 Program”). These affiliated entities include, among others: (i) CanAm
Enterprises, LLC (“CAE LLC”), a private limited liability company and full-service financial
institution with over 30 years of experience serving immigration-linked investors, including
regarding EB-5 investments and (ii) CanAm Enterprises, LP (“CAE LP”), a private limited
partnership, which acts as the servicing entity for transactions and other business activities under
the CanAm Enterprises brand.
The Firm is wholly owned by Tommy Rosenfeld through CanAm CCM Holdings, LLC. Peter W.
Calabrese is the Firm’s Chief Executive Officer (“CEO”) and Walter S. Gindin is the General
Counsel and Chief Legal Officer. Mr. Calabrese is a key investment professional and further
information about him may be found in CACM’s Form ADV, Part 2B (“Brochure Supplement”).
Investment Management Services
CACM provides investment advisory services to limited partnerships (each, a “Limited
Partnership”) which originally facilitated an EB-5 investment under the EB-5 Program and are
required pursuant to applicable guidance from the U.S. Citizenship and Immigration Services to
further deploy (“Redeployment”) some or all of the proceeds realized from such EB-5 investments
(“Realization Proceeds”) in order to enable EB-5 investors to continue their pursuit of the intended
benefits under the EB-5 program. These services are tailored to meet the immigration and
investment objectives of EB-5 investors who are limited partners of these Limited Partnerships.
Investment strategies are implemented though CACM’s selection and retention of an unaffiliated
sub-adviser. The Firm retains the sub-adviser to provide CACM’s clients with sub-advisory
services, including access to investment funds and investments across multiple asset classes, day-
to-day securities selection and other related services. As part of such services, the sub-adviser will
manage clients’ assets on a discretionary basis. The Firm is responsible for selecting sub-advisers,
determining the portion of assets allocated to the sub-adviser and monitoring their performance
quarterly. The Firm will review reports provided by the subadvisor showing any account that is five
percent or more outside targeted allocations and will document any material issues with such
deviations. This may include notations to the client file of significant cash flows that caused the
deviation or changes in investment guidelines.
Clients grant CACM and the relevant sub-adviser(s) discretionary authority. This authority allows
CACM and the sub-adviser(s) to determine the specific securities, and the amount of securities, to
be purchased or sold for client accounts without prior client approval specific to each transaction.
Discretionary authority is typically granted
(i) to CACM by each client pursuant to the investment
advisory agreement between the client and CACM and (ii) to the sub-adviser by CACM pursuant
to the sub-advisory agreement between CACM and the sub-adviser.
CACM also provides certain non-discretionary advisory services as described below. Clients also
provide consent to being placed in a portfolio consisting of Redeployment Loan(s) and/or
Redeployment Preferred Equity Investments (each as defined below).
Types of Investments
Through its selection of sub-advisers, CACM offers advice on equity securities and municipal
securities. CACM also assists Limited Partnerships with the selection of investments for the
redeployment of some or all of the Realization Proceeds into one or more loans (“Redeployment
Loans”) and/or one or more preferred equity investments (“Redeployment Preferred Equity
Investments”) in order to facilitate EB-5 investors’ compliance with the requirement of the EB-5
program.
Additionally, CACM may advise clients on any type of investment that it deems appropriate based
on a client’s stated goals and objectives, including, for example, on a non-discretionary basis, co-
investment opportunities involving assets originated by CACM’s private equity affiliate as
described below. A client may restrict its own portfolio investments to particular securities or types
of securities by submitting those restrictions to CACM in writing.
CACM may offer and allocate a co-investment opportunity associated with an investment made by
its affiliate, CanAm Capital Partners, LLC (“CACP”), a private equity originator, to one or more
clients or other persons (including CACM’s principal, employees or affiliates). In determining how
to offer and allocate such a co-investment opportunity, CACM will take into consideration a variety
of factors, including, but not limited to: (i) expressed interest in co-investment opportunities; (ii)
expertise of the prospective co-investor in the industry to which the investment opportunity relates;
(iii) perceived ability to quickly execute on transactions; (iv) tax, regulatory, securities laws and/or
other legal considerations; (v) confidentiality concerns that may arise in connection with providing
the prospective co-investor with specific information relating to the investment opportunity; (vi)
perceived ease of process in coordinating or completing the investment with the prospective co-
investor; (vii) CACM’s perception of whether the investment opportunity may subject the
prospective co-investor to legal, regulatory, reporting or other burdens that make it less likely that
the prospective co-investor would act upon the investment opportunity if offered or would impair
CACM’s ability to execute the relevant transaction in the desired time or on desired terms; (viii) the
size of the investment allocation and practicality of dividing it up among multiple co-investors; and
(ix) perceived public relations and reputational benefits or costs.
CACM does not participate in wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2023, CACM has $458,812,908 in assets under management on either a
discretionary or a non-discretionary basis.