Describe your advisory firm, including how long you have been in business. Identify
your principal owner(s).
Coinbase Asset Management, LLC (“CBAM” or the “Adviser”) was established on March
3, 2023, following the acquisition of One River Digital Asset Management, LLC by
Coinbase Global, Inc. (“Coinbase”), a Delaware corporation publicly listed on Nasdaq.
One River Digital Asset Management, LLC, was founded in December 2020 and was a
majority-owned subsidiary of One River Asset Management, LLC. Following the
acquisition, Coinbase became the sole owner of CBAM.
Eric Peters serves as Chief Executive Officer (“CEO”) and Chief Investment Officer
(“CIO”) of the Adviser and One River Asset Management, LLC (please see additional
information under Item 10).
CBAM provides discretionary investment advisory services to multiple private
investment funds (the “Funds”) and may provide investment advisory services to
separately managed accounts (which may also be referred to as “Clients”). CBAM
advises Clients on investments in cryptocurrencies, such as Bitcoin, Ether, and Solana,
short term debt instruments of crypto firms, as well as futures contracts on
cryptocurrencies (collectively referred to as “Digital Assets”).
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.
Generally, CBAM has discretionary investment authority with respect to its Clients’
assets. Each Clients’ investment objectives and strategies are set forth in its investment
management agreement, constituting documents and other supporting documents, as
applicable (collectively, the “Governing Documents”). Investors in the Funds are
provided with a private placement memorandum (“PPM”) and are urged to review it
carefully.
CBAM’s purpose is to help institutions access and invest in the emerging digital
ecosystem, across liquid and illiquid strategies. CBAM believes the promise and risks
of digital assets require a best-in-class team, and further believe it has assembled a
highly skilled digital asset management team. CBAM invests today, cognizant of the
risks of the asset class, and the requirements of our Clients. CBAM expects blockchain
technology will re-make asset management and seeks to leverage that potential. CBAM
offers both passive and active investment strategies.
Some of the accounts to whom CBAM provides management services do not invest in
securities, including accounts that only invest in certain Digital Assets as described in
further detail in this Brochure.
Such services may not be provided by CBAM in its
capacity as a registered investment adviser.
CBAM is the investment manager of the following Funds:
o Coinbase Bitcoin Fund, Ltd. (in this brochure referred to as the “Bitcoin Master
Fund”), an exempted company incorporated under the laws of the Cayman
Islands; and Coinbase Bitcoin Feeder Fund, Ltd. (in this brochure referred to
as the “Bitcoin Feeder Fund”), an exempted company incorporated under the
laws of the Cayman Islands;
o Coinbase Ethereum Fund Ltd. (in this brochure referred to as the “Ethereum
Master Fund”), an exempted company incorporated under the laws of the
Cayman Islands; and Coinbase Ethereum Feeder Fund, Ltd. (in this brochure
referred to as the "Ethereum Feeder Fund”), an exempted company incorporated
under the laws of the Cayman Islands; and
o Coinbase Digital Income Fund, LP, a Delaware limited partnership.
CBAM is authorized to enter into any type of investment transaction it deems
appropriate for its Clients, pursuant to the terms of the Governing Documents. CBAM
also offers advice on futures, and other types of derivatives.
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.
CBAM tailors its advisory services to the needs of Clients. The Adviser accepts
investment restrictions from investors as it relates to the Funds. Because some types
of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the Clients’ stated investment
objectives, tolerance for risk, liquidity and suitability, as set forth in the Governing
Documents.
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.
Not applicable. CBAM does not participate in wrap fee programs.
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, CBAM manages approximately $281,619,847 of
regulatory
assets, on a discretionary basis. CBAM does not currently manage any Funds assets
on a non-discretionary basis.
1
1 The Adviser includes the Digital Assets it manages in the RAUM it reports; however, this should not be interpreted as an indication that the Adviser
believes that such Digital Assets are securities.