Overview
A. Description of the Advisory Firm
INCEPTIONR LLC (hereinafter “INC”) is a Limited Liability Company organized in the
State of California. The firm was formed in April 2019, and the principal owner is Li Lu.
B. Types of Advisory Services
Portfolio Management Services
INC provides portfolio management to pooled investment vehicles, specifically acting as
subadviser to private funds (the client).
INC will require discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction. INC
seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of INC’s economic, investment or
other financial interests. To meet its fiduciary obligations, INC attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, INC’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one
client over another over time. It is INC’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Services Limited to Specific Types of Investments
INC generally limits its investment advice to equities, although INC may use other
securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
INC offers the same suite of services to all of its clients. Clients may not impose restrictions
in investing in certain securities or types of securities in accordance with their values or
beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. INC does not participate in any wrap fee programs.
E. Assets Under Management
INC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 838,129,859 $0 May 2024