A. Description of Advisory Business
10Talents Investors, LLC (the “Adviser”) is a Delaware limited liability company with its principal
place of business located at 124 Washington Street, Suite 101, Foxborough, Massachusetts 02035.
The Adviser was founded in April 2015. Andrew Goudy and Keith Lowey own substantially all of
the interests in the Adviser. Mr. Goudy serves as the Adviser’s Managing Member.
The Adviser also maintains an advisory committee (the “Advisory Committee”), which currently
comprises four individuals, one of whom has a minority interest in the Adviser. None of the
Advisory Committee members is compensated directly for his or her services, though, in exchange
for a member’s service on the Advisory Committee, the Adviser may reduce its fees relating to the
member’s investments in one or more Access Funds (as defined below).
B. Description of Advisory Services Offered
The Adviser provides investment advisory services to pooled collective investment funds to which
it or an affiliate also serves as the general partner (each, an “Access Fund”). Investment advice is
provided directly to an Access Fund, subject to the discretion and control of the applicable general
partner (if any), and not individually to the investors in the Access Fund. Each Access Fund is
exempt from registration under the Investment Company Act of 1940, as amended (the “1940
Act”), and its securities are not registered under the Securities Act of 1933, as amended (the
“Securities Act”). Each Access Fund is managed in accordance with its summary term sheet, if any,
and limited partnership agreement (together, the Access Fund’s “Offering Documents”). As of
December 31, 2022, there were seventeen Access Funds, all but one of which was closed to new
capital commitments.
Each Access Fund has been formed for the purpose of investing the Assets Fund’s assets generally
with a single private equity fund (an “Underlying Fund”) that has been selected by the Adviser.
(Two Access Funds have investments in more than one Underlying Funds.) No two Access Funds
invest in the same Underlying Fund. Each Underlying Fund is a closed-end private equity fund that
typically seeks capital commitments from investors in an aggregate amount of between
approximately $250 million and $3 billion. Each Underlying Fund is managed by an investment
adviser that is not affiliated with
the Adviser (an “Underlying Fund Manager”). Most, if not all,
investment advisers of the Underlying Funds are registered with the SEC as investment advisers.
An Access Fund identifies the Underlying Fund (or Underlying Funds) and the Underlying Fund
Manager (or Underlying Fund Managers) prior to the commencement of marketing the Access
Fund.
Each Underlying Fund has its own offering materials, which include important disclosures with
respect to investment related risks, macroeconomic considerations, fees and other potential
conflict issues, and such other disclosures as are determined appropriate by the Underlying Fund
Manager. Copies of those Underlying Fund offering materials provided by the Underlying Fund
Manager (or Managers) to the Adviser are included with the Access Fund’s Offering Documents
provided to investors.
Each Access Fund raises its own capital commitments and then makes a collective capital
commitment to the Underlying Fund. As the Underlying Fund makes capital calls, the
corresponding Access Fund generally will make capital calls of its investors (“Limited Partners”).
From time to time, an Access Fund may borrow from a third-party lender some or all of the
amounts necessary to satisfy an Underlying Fund’s capital call. In such cases, the loan amount is
secured by the holdings of the Access Fund, and the lender has a right to call additional capital
from the Access Fund’s Limited Partners, up to the amounts of their outstanding commitments.
The Adviser does not currently participate in any Wrap Fee Programs.
C. Investment Restrictions
Each Access Fund is managed only in accordance with its own investment objectives and
restrictions and is not tailored to any particular Limited Partner. As the Adviser does not provide
individualized advice to investors, Limited Partners should consider whether a particular Access
Fund meets their investment objectives and risk tolerance prior to investing. The Adviser does not
permit Limited Partners to impose limitations on the investment activity described in an Access
Funds’ Offering Documents.
D. Assets Under Management/Advisement
As of December 31, 2023, the Adviser managed assets on a discretionary basis, plus uncalled
capital commitments, in an aggregate amount equal to $238,934,974. Adviser does not manage
any assets on a non-discretionary basis.