Aristotle Pacific Capital, LLC (“Aristotle Pacific,” formerly Pacific Asset Management LLC) offers total
return credit-oriented investment strategies primarily to institutional investors. Aristotle Pacific believes
that its focus on credit investments across an issuer’s capital structure, an experienced portfolio
management group and an integrated credit analyst team, all serve to differentiate Aristotle Pacific’s
services from the services provided by its competitors.
Aristotle Pacific has its principal place of business located in Newport Beach, California. Senior members
of Aristotle Pacific and Aristotle Capital Management, LLC hold ownership interests in the firm.
Aristotle Pacific provides investment management services primarily to institutional clients. As an adviser,
Aristotle Pacific generally has discretionary authority to determine which investments are bought and sold
and the amounts of such investments that are appropriate for each client. Limitations on Aristotle Pacific’s
authority, if any, are set forth in the applicable governing documents or investment management agreement.
Certain affiliates of Aristotle Pacific, namely APC Asset Development I, LP and APC Asset Development
II, LP, established as Delaware limited partnerships and registered as investment advisers with the SEC
(collateral manager vehicles, or “CMVs”), serve as the collateral manager for collateralized loan obligation
transactions (“CLOs”). Pursuant to the applicable service agreement with each CMV, Aristotle Pacific
makes its employees, including its investment management professionals, available to the CMVs in
connection with their provision of investment functions for CLOs. Aristotle Pacific’s investment
management professionals, acting on behalf of the applicable CMV, are responsible for the portfolio
management functions to be performed under the collateral management agreement, including the
recommendation of any asset purchased or sold by the CLO issuer and the facilitation of any such purchase
or sale. Additionally, Aristotle Pacific provides operational and investment management support to the
CMVs, including research and credit analysis services, traditional middle office and back-office services,
compliance, administrative and infrastructure services.
Aristotle Pacific, together with its CMV affiliates, has approximately $24.6 billion in assets under
management as of December 31, 2023, across a broad platform of investment strategies. Note that the
method for computing assets under management is different from the method for computing regulatory
assets under management required for Item 5.F in Form ADV Part I.
Aristotle Pacific’s advisory services are generally offered through the following types of products and/or
investment vehicles:
• open-ended mutual funds (“Mutual Funds”) registered under the Investment Company Act of 1940
(the “Company Act”);
• exchange traded funds (“ETF”) registered under the Company Act;
• private investment funds offered pursuant to Regulation D of the Securities Act of 1933 and
excluded from the investment company definition under Section 3(c)(7) of the Company Act (a
“Private Fund”);
• collective trust funds and/or underlying portfolios of stable value funds (referred to as “Collective
Investment Trusts” or “CITs”) maintained by a bank or trust company and excluded from the
investment company definition under Section 3(c)(11) of the Company Act (Mutual Funds, ETFs,
Private Funds and CITs are referred to collectively as “Pooled Funds”);
• Managed custodial accounts (“Managed Accounts”) maintained by a qualified custodian on behalf
of clients; and
• Wrap Programs, as defined and discussed in greater detail below.
Pooled Funds:
Aristotle Pacific serves as the manager, adviser or sub-adviser of certain affiliated and non-affiliated Pooled
Funds. In certain circumstances, Aristotle Pacific may provide both investment advisory services and
administrative services to Pooled Funds. Investment advisory services include the selection of securities
and the placement of orders for the purchase and sale of securities. Complete information concerning each
Pooled Fund advised by Aristotle Pacific, including fees, is disclosed in the offering materials for each
applicable Pooled Fund.
Managed Accounts:
Aristotle Pacific provides discretionary investment management services directly to advisory clients
through Managed Accounts. Aristotle Pacific has full power and authority to supervise and direct
investments in Managed Accounts, subject to the investment management agreement for such clients.
Managed Accounts may pursue any of the investment strategies described below in Item 8: Methods of
Analysis, Investment Strategies And Risk of Loss.
Wrap Programs:
In addition to Pooled Funds and Managed Accounts, Aristotle Pacific offers certain of its investment
strategies and advisory services directly or indirectly to individual clients through separately managed
account programs (“Wrap Programs”) sponsored by financial intermediaries (“Program Sponsors”).
Aristotle Pacific tailors its advisory services to meet the needs and objectives of its Wrap Program clients
to ensure that their portfolios are managed in a manner consistent with their specific investment profiles.
A Wrap Program client may impose reasonable restrictions or mandates on the management of their account
if Aristotle Pacific, in its sole discretion, approves the conditions and determines that such restrictions are
not overly burdensome to Aristotle Pacific’s management of the account. Such restrictions may, however,
alter other characteristics and the risk profile of the account, such that it no longer performs in line with
other accounts within the same broader investment strategy.
In a Wrap Program, Aristotle Pacific’s services are generally limited to the provision of certain investment
advisory services, while the Program Sponsor is responsible for providing other services to the client, such
as the selection and determination of an appropriate investment strategy for the client. The client’s Wrap
Program agreement with its Program Sponsor generally sets forth the services to be provided to the client
by or on behalf of the Program Sponsor, such as manager selection and oversight of the investment manager,
trade execution, custodian services and performance reporting. Aristotle Pacific generally offers its
investment services through the following types of Wrap Programs:
• Traditional wrap programs (“Traditional Wrap”): Under a Traditional Wrap arrangement,
Aristotle Pacific enters into a contract with the Program Sponsor, but does not have a direct
agreement with the client. The Program Sponsor may select Aristotle Pacific as the investment
manager for certain Program Sponsor clients and in doing so, provides Aristotle Pacific with
the authority to provide discretionary investment services to such clients.
• Dual contract arrangements (“Dual Contract”): Dual Contract arrangements involve Aristotle
Pacific entering into an agreement with the Program Sponsor and a separate management
agreement directly with the client. Under a Dual Contract arrangement, the client agreement
provides Aristotle Pacific with discretionary investment authority to manage the client
according to the terms of the client agreement and generally, pursuant to the Program Sponsor
agreement, subject to the obligations established by the Program Sponsor.
Aristotle Pacific does not manage Wrap Program accounts differently from its other client accounts, except
to the extent a Wrap Program account has restrictions that would prevent it from participating in investments
or trades executed for other accounts. Aristotle Pacific is not responsible for, nor does it attempt to
determine, whether participation in a Wrap Program or a particular investment strategy is appropriate or
suitable for a Wrap Program participant. Such decisions are made by the Program Sponsor and the client.
In addition, Aristotle Pacific is only responsible for managing the assets of a Wrap Program client for which
we have been granted discretionary authority. The Firm is not responsible for managing other portions of
a Wrap Program client’s account, nor are we involved in determining the percentage of total assets allocated
to Aristotle Pacific.
Wrap Program clients should refer to the appropriate disclosure documents and applicable agreements
provided by the Program Sponsor for more information regarding the Wrap Program, including services,
fees charged by the Wrap Program (and those that are not covered), and termination provisions.