Accion Impact Management LLC (“AIM”) commenced operations in 2022. Accion International
is the sole member of Accion Impact Management LLC. Accion International is a New York not-
for-profit corporation, tax-exempt under Section 501(c)(3) of the Internal Revenue Code of 1986,
as amended. Accion International does not have any owners or shareholders, nor is any person
entitled to the organization's profit. AIM provides discretionary investment advisory services for
private investment funds (the “Funds”). AIM has also entered into investment management
agreements to manage certain investment portfolios beneficially owned by Accion International
(referred to herein as the “SMAs” and, together with the Funds, the “Advisory Clients”).
On behalf of the Advisory Clients, AIM invests in pre-seed to growth-stage companies providing
financial services and/or financial technology to micro, small and medium enterprises (“MSMEs”)
and the Un(der)served. AIM generally invests in sub-Saharan Africa, Asia, Latin America and
United States.
The Funds are governed by limited partnership agreements that set forth the specific investment
guidelines and restrictions applicable to the Funds and the applicable investment guidelines and
restrictions are set forth in the investment management agreement with the SMAs (the “Governing
Documents”). In addition, investors in the Funds are provided with a Private Placement
Memoranda or other offering documents (“PPM”) prior to their investment, which contains
information regarding the intended investment program for the relevant Fund.
Affiliates of AIM serve as the general partners of the Funds (the “GPs”). The GPs have full and
exclusive management authority over all investments, asset dispositions, distributions, and other
affairs of the relevant Fund. The GPs are related persons of AIM and under common control with
AIM. While the GPs maintain ultimate discretionary investment authority, AIM has been delegated
the role of investment adviser for the Funds. The GPs will be subject to the Investment Advisers
Act of 1940 (the “Advisers Act”) and rules thereunder, and to all of AIM’s compliance policies and
procedures. References to AIM in this Brochure should also be considered references to the GPs in
the appropriate context.
In accordance with the terms and
conditions of the Governing Documents and subject to the
direction and control of the GPs of the Funds, AIM directs and manages the investment and
reinvestment of the Advisory Clients’ assets. Investment advice is provided directly to the Funds
and not individually to the limited partners, members or investors of the Funds (the “Investors”).
AIM does not tailor its advisory services to the individual needs of Investors in the Funds and
Investors may not impose restrictions on investing in certain securities or types of securities, other
than has been agreed in the Governing Documents.
In certain cases, the GPs have (and may in the future) entered into side letter agreements with certain
Investors establishing rights under, or supplementing or altering the terms of, the applicable
Governing Documents (including without limitation, “most favored nations” rights, transparency
rights, reporting rights, approval rights and certain other protections). Once invested in the Funds,
Investors generally cannot impose additional investment guidelines or restrictions on the Funds.
Except in limited circumstances, Investors are not permitted to withdraw from a Fund prior to the
Fund’s dissolution.
Co-Investments
Depending on the size and other relevant factors associated with an investment opportunity,
investment allocation decisions may be made with respect to a potential co-investment in an
investment opportunity. In making this determination, AIM will first ensure that the relevant
Advisory Client receives the full amount of its desired allocation in respect of a particular
investment opportunity prior to offering to any third party the opportunity to co-invest alongside
such Advisory Client. There may be times when AIM determines that co-investing with affiliates
of AIM in an investment opportunity is in the best interest of an Advisory Client. In such instances,
AIM will determine if there is a conflict of interest as a result of such co-investment and may seek
approval from the limited partner advisory committee, as required by the Governing Documents.
Wrap Fee Programs
AIM does not participate in wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2023, AIM manages $ $191,111,607.28 of Advisory Client assets on a
discretionary basis.