Lewis & Clark Equity Partners, LLC (“L&C Partners”) provides investment advisory services to
pooled investment vehicles (the “L&C Partners Funds”) that are exempt from registration under
the Investment Company Act of 1940 (the “1940 Act”) and whose securities are not registered
under the Securities Act of 1933 (the “1933 Act”).
Lewis & Clark Ventures Capital, LLC (“L&C VC” and, each of L&C Partners and L&C VC,
collectively, the “Advisers”) provides investment advisory services to and acts as general partner
to pooled investment vehicles (the “L&C VC Funds” and, collectively with the L&C Partners
Funds, the “Funds”) that are exempt from registration under the 1940 Act and whose securities
are not registered under the 1933 Act. L&C Partners and L&C VC are each wholly owned, through
a trust1, by Thomas J. Hillman.
Each Adviser, along with each Fund’s general partner (in the case of L&C Partners), identifies
investment opportunities for, and participates in the acquisition, management, monitoring and
disposition of investments of, each Fund. These investments are privately negotiated and typically
take the form of unregistered equity or equity-like investments in U.S. and non-U.S. private
companies. At times an Adviser may recommend other types of investments, consistent with the
applicable Fund’s investment strategy and objective.
L&C Partners provides investment advisory services to each L&C Partners Fund pursuant to a
separate investment advisory agreement with the Fund. L&C VC provides investment advisory
services to and serves as general partner of each L&C VC Fund pursuant to the terms of each
Fund’s respective partnership agreement. Investment advice is provided by an Adviser directly to
the applicable Fund, and not individually to the limited partners in the Fund.
Investment
restrictions for the Funds, if any, are generally established in the organizational and/or
offering documents of the applicable Fund (“Governing Documents”), which are provided to each
Fund investor prior to investing in the Fund. Once invested in a Fund, investors cannot impose
restrictions on the types of securities in which the Fund may invest.
Lewis and Clark RBIC Fund II, L.P. and Lewis and Clark RBIC Fund III, L.P. are private investment
funds which have been granted a Rural Business Investment Company Licensee by the USDA. Lewis
and Clark RBIC Fund II, L.P. has $88.1M of capital commitments of which $75.9M have been called
and deployed. It has a current a current NAV of $80.9M as of December 31, 2023, inclusive of
uncalled capital commitment. Lewis and Clark RBIC Fund III, L.P. has $70.4M of capital
commitments of which $0 have been called as of December 31, 2023. It has a current NAV of $70.4M
as of December 31, 2023, inclusive of uncalled capital commitments.
As RBIC Licensees, both of these funds are subject to the relief provided in the RBIC Advisers Relief
Act of 2018 (the “RBIC Advisers Relief Act”) which amended the Investment Advisers Act of 1940
(the “Advisers Act”) to provide one new and two expanded exemptions from registration for
investment advisers who advise rural business investment companies (“RBICs”). The RBIC Advisers
Relief Act added section 203(b)(8) to the Advisers Act and excluded RBIC assets from assets under
management by amending the definition of the term “assets under management” in Advisers Act rule
203(m)–1.
1 Thomas J. Hillman Living Trust Dated May 18, 1993.
L&C VC and L&C Partners have been in business since 2015 and 2018, respectively. As of
December 31, 2023, the Advisers collectively managed approximately $302,000,000 in client
assets, all on a discretionary basis.