TCIA, an exempted company limited by shares organized under the laws of Bermuda, is an SEC-Registered
Investment Adviser with its principal place of business located in Hamilton, Bermuda. TCIA began conducting
business in September 2021 and is a wholly-owned subsidiary of Tangency Capital Ltd. ("TCL"). TCL is
beneficially owned by certain members of the TCL and TCIA management team.
TCL, an exempted limited liability company organized under the laws of Bermuda, is the parent company of
TCIA, an exempted limited liability company organized under the laws of Bermuda, Tangency Capital Services
Ltd., a private company limited by shares organized under the laws of England and Wales, and Tangency
Capital America Corporation, a corporation organized under the laws of the State of Delaware (each an
“Affiliate,” and collectively, the “Affiliates”).
As of the date of this Brochure, TCIA provides investment management services to (i) Select Market Access
Fund Ltd, (ii) Select Market Opportunities Fund Ltd., (iii) Select Top Layer Fund Ltd., (iv) Select Lindeman
Fund Ltd., and (v) Select Banksia Fund Ltd. (each, a “Private Fund” and, together, the “Funds”). Select
Lindeman Fund Ltd. and Select Banksia Fund Ltd. were launched on January 2, 2024.
The Funds are non-U.S. domiciled investment vehicles for U.S. and non-U.S. investors, with the exception of
Select Lindeman Fund Ltd. and Select Banksia Fund Ltd., which are non-U.S. domiciled investment vehicles for
non-U.S. investors only.
The Funds primarily invest in insurance linked securities (“ILS”), derivatives and instruments related to
insurance notes, including quota share contracts, industry loss warranties or other insurance and ILS related
instruments (together “ILS instruments”). Investors in the Funds are limited partners.
The Private Funds are exempted mutual fund companies incorporated with limited liability in Bermuda as
open-ended investment companies and are exempt from registration as investment companies under the
Investment Company Act of 1940, as amended (hereinafter, the "Investment Company Act" or "40 Act"), in
reliance upon Section 3(c)(7) of the 40 Act. Investors in the Funds are "accredited investors" (as such term is
defined in Rule 501(a) of Regulation D promulgated, and the Funds' securities offerings are not registered
under the Securities Act of 1933, as amended (hereinafter, the "Securities Act")) and "qualified purchasers"
(as such term is defined under Section 2(a)(51) of the Investment Company Act and the rules and regulations
promulgated thereunder).
TCIA does not generally tailor its advisory services to the needs of individual investors; however, at the
establishment of a Fund, specific investment criteria may be created for the Fund. TCIA provides investment
advice directly to each Fund and not to individual investors.
Private Funds are managed in accordance with the particular investment objectives, strategies, restrictions
and guidelines within the Fund's limited partnership agreement, investment management agreement,
subscription agreement, and any other relevant agreements or organization documents (together, "Governing
Documents"). Prior to investing in a Fund, prospective investors should review the Fund's Governing
Documents to confirm the suitability of an
investment in a Fund based on the investor's particular
circumstances.
TCIA is the Alternative Investment Fund Manager of the Private Funds for the purposes of the Alternative
Investment Fund Managers Directive. TCIA has appointed Vittoria & Partners LLP (“Vittoria”) as Sub-Adviser
to the Private Funds. Vittoria is responsible for the management and investment of the assets of the Fund, under
the supervision of TCIA, pursuant to a sub-advisory agreement. Vittoria is authorised and regulated by the
Financial Conduct Authority. Kai H. Morgenstern and Michael Jedraszak, both supervised persons of TCIA, are
each currently seconded to Vittoria and will be primarily responsible for the management of the assets of the
Funds.
TCIA has entered into an agreement with its Affiliates to provide certain services to the Adviser in connection
with the Adviser’s investment advisory business (“Participating Affiliate Agreement”). Pursuant to the
Participating Affiliate Agreement, by and among TCIA and Affiliates, Affiliates and the Adviser express their
willingness to cooperate, pursuant to guidance issued by the SEC under a series of “no-action letters” related
to “cross-border” arrangements (“SEC Staff Letters”), in connection with the Affiliates providing the Services
to the Adviser.
Affiliates provide the use of certain designated employees for due diligence, research, investment advisory,
investment and portfolio management, sourcing, servicing, monitoring, administrative services, and other
related services to TCIA, and, through TCIA, to the Funds. The Participating Affiliate Agreement allows TCIA
to use the premises and facilities of its Affiliates for its daily operations, including for the maintenance of books
and records.
Affiliates’ officers are also officers of certain other partnerships or limited liability companies that are a limited
partner of a Fund or the directors, managing members or general partners of certain entities affiliated with
TCIA. Please see item 10 "Other Financial Industry Activities and Affiliations" below for a further discussion
of entities affiliated with TCIA.
Assets Under Management
TCIA provides discretionary investment advisory services to certain Funds and has discretionary management
authority and responsibility over their assets. As of December 31, 2023, the Adviser managed $827,661,482
on a discretionary basis.
TCIA does not manage any Client assets on a non-discretionary basis. The Adviser does not have any non-
discretionary assets under management. TCIA is authorized to follow investment guidelines in pursuing the
Fund's asset acquisition strategy based on established eligibility criteria as set forth in each Fund's respective
Governing Documents.
This Brochure generally includes information about the Adviser and its relationships with its Clients and
Affiliates. While much of this Brochure applies to all such Clients and Affiliates, certain information included
herein applies to specific Clients or Affiliates only. This Brochure does not constitute an offer to sell or
solicitation of an offer to buy any securities. In the event any terms or provisions of any of the Fund's respective
offering documents conflicts with the information contained in this Brochure, such Fund's offering documents
shall control.