A. Describe your advisory firm, including how long you have been in business. Identify your
principal owner(s).
Boundary Creek is organized as a Delaware limited partnership and is an investment adviser registered
with the SEC. The firm has been in business since 2019. As of March 15, 2024, Boundary Creek and
Boundary Creek London (as defined below) have 17 employees, primarily located in New York and
London. Peter Greatrex serves as the Chief Executive Officer and Chief Investment Officer of Boundary
Creek. Mr. Greatrex is the principal owner of Boundary Creek and controls Boundary Creek Partners
LLC, the general partner of Boundary Creek.
Boundary Creek has approximately $3,899,251,408 in regulatory assets under management.1 Boundary
Creek serves as an investment adviser to pooled investment vehicles (“Fund Clients”) and institutional
accounts (“Institutional Accounts,” and, together with Fund Clients, “Advisory Clients”) that are
primarily domestic and foreign limited partnerships, and foreign companies. Boundary Creek provides
investment management and supervisory services to its Advisory Clients on a discretionary and non-
discretionary basis. Boundary Creek may establish additional Advisory Clients in the future.
Investments by Fund Clients typically are made through a master-feeder structure, with an affiliate of
Boundary Creek serving as general partner of Fund Clients organized as limited partnerships, and
Boundary Creek serving as investment adviser to both the Fund Client that invests through the master
fund and the master fund itself.
Institutional Accounts are generally organized as foreign companies and structured as separately
managed accounts (“SMAs”). Advisory Clients are generally not registered under the Securities Act of
1933, as amended, nor registered under the Investment Company Act of 1940, as amended. Accordingly,
interests in such Advisory Clients are offered exclusively to investors satisfying the applicable eligibility
and suitability requirements either in private placement transactions within the United States or in
offshore transactions. The descriptions in this Brochure do not constitute an offer to sell interests in these
Advisory Clients. Please see Item 7 of this Brochure for more information with respect to Boundary
Creek’s clients.
Boundary Creek UK LLP (“Boundary Creek London”) is an affiliate of Boundary Creek and serves as
adviser to Boundary Creek, primarily with respect to issuers based in Europe, and is compensated by
Boundary Creek for its services. Boundary Creek London is registered with the Financial Conduct
Authority. Boundary Creek London is a “relying adviser” (“Relying Adviser”) and, as such, neither is,
nor is required to be, independently registered with the SEC. Please refer to Items 10.B and 10.C for
additional information related to Boundary Creek London.
B. Describe the types of advisory services you offer. If you hold yourself 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.
Boundary Creek generally has broad and flexible investment authority with respect to the investment
portfolios that it manages for its Advisory Clients. Boundary Creeks provides investment advisory
services to its Advisory Clients with respect to investments in a broad array of instruments, among them
bonds of investment and non-investment grade credits, government and municipal bonds, loans (both
syndicated and privately traded, including private non-recourse loans supported by publicly traded
collateral or project financings), credit derivatives (including credit default swaps and loan total return
1 Calculated as of December 31, 2023.
swaps), public equities (including “new issues” as described, and subject to the limitations set forth, in
Rules 5130 and 5131 of the Financial Industry Regulatory Authority), convertible bonds and other asset-
backed securities and asset-backed financing arrangements, collateralized debt obligations, collateralized
loan obligations, insurance-linked securities,
financing trades, margin loans, repurchase agreements,
reverse repurchase agreements, private and post-reorganization equities, real estate-related assets,
privately negotiated investments, equity derivatives, mortgages, futures, commodities interest rate
derivatives (including swaps and swaptions), and spot and forward foreign currency contracts. Credit and
equity derivatives relate either to individual reference entities or to baskets or portfolios of reference
entities (including levered or de-levered tranches of such portfolios or baskets).
Boundary Creek provides such advisory services on a discretionary and non-discretionary basis.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of
clients. Explain whether clients may impose restrictions on investing in certain securities or types of
securities.
The advisory services provided by Boundary Creek to its Advisory Clients are tailored to the investment
objectives, investment strategy and investment restrictions, if any, as set forth in the governing
documents of Advisory Clients and/or the investment management agreement entered into by Boundary
Creek with such clients. With respect to Fund Clients, except as noted below, Boundary Creek typically
does not tailor its advisory services to the individual needs of investors in the Fund Client; accordingly, it
typically does not accept material investment restrictions imposed by such Fund Client investors. With
respect to Institutional Accounts, the terms of such relationship, including any investment restrictions,
are individually negotiated. Certain agreements with one or more investors (“Side Letters”) permit the
excuse and/or exclusion of a particular investor from participating in a particular investment in certain
limited circumstances, but Boundary Creek generally does not otherwise accept investment restrictions
imposed by Fund Client investors.
Advisory Clients have entered into and may in the future enter into, subject to applicable law, rule and
regulation, Side Letters with one or more of its investors whereby in consideration for agreeing to invest
certain amounts in an Advisory Client and/or other consideration deemed sufficiently material, such
investors may be granted favorable rights not afforded other investors in such Advisory Client. Such
rights may include one or more of the following: rights to receive reports from the Advisory Client on a
more frequent basis or that include information not typically provided to other investors that Boundary
Creek believes are not prejudicial to other investors; ability to transfer to affiliates or other parties;
reduced rates of performance fees/allocations and/or management fees earned by Boundary Creek, each
Advisory Client’s general partner and/or other affiliates; application of a restricted securities list; and
such other rights as are negotiated between the Advisory Client, Boundary Creek and such investors.
Such agreements may be entered into by the Advisory Client and Boundary Creek without the consent of
other investors in such Advisory Client; additionally, except as may be required by “most-favored-
nations” clauses, such agreements usually need not be disclosed to other investors in such Advisory
Client.
D. If you participate in wrap fee programs by providing portfolio 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.
Boundary Creek does not participate in “wrap fee arrangements,” whereby clients select Boundary Creek
to manage funds through an investment program presented to the clients by a third-party program
sponsor.
E. If you manage client assets, disclose the amount of client assets you 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.
As of December 31, 2023, Boundary Creek has approximately $3,849,051,389 in regulatory assets
under management which are managed on a discretionary basis and $50,200,019 in regulatory assets
under management which are managed on a non-discretionary basis.