General Description of Advisory Firm
West Tower Group, LLC (“WTG”) is a Delaware limited liability company formed on July 14,
2022. WTG is a privately held company with its principal place of business in Richmond, VA.
WTG is owned primarily by Charles Honey and Gerard J. Polizzi.
WTG provides discretionary investment management services to privately offered pooled
investment vehicles, exempt from registration as an “investment company” pursuant to Section
3(C)(7) of the Investment Company Act of 1940 (the “Company Act”) (each, a “Private Fund”,
and collectively, the “Private Funds”) Each Private Fund is managed in accordance with their
respective investment objectives, guidelines and limitations. Under limited circumstances WTG
may also provide investment management services to single-investor private funds or separately
managed accounts (“Managed Accounts” and together with the Private Funds, the “Clients”).
Private Funds
The investment management services provided by WTG are provided on a discretionary basis and
are typically provided to Clients through single or multi-investor funds, Direct Investments and/or
Managed Accounts. WTG also serves as investment manager to the Funds, and its affiliates serve
as general partner to Funds organized as Delaware limited partnerships or Cayman Islands exempt
limited partnerships.
Generally, the WTG Private Funds are either:
1. Multi-Strategy funds (“Multi-Strategy Funds”), in which WTG allocates a majority of
the Private Fund’s assets to internal investment teams employed by WTG as well as a
minority portion to other unaffiliated third-party external managers ( “Managers”) via
the use of segregated portfolios using Separately Managed Accounts (“SMAs”).
2. Funds of funds (“Fund of Funds”), in which WTG invests the Private Fund’s assets in
other unaffiliated private funds managed by unaffiliated third-party external managers
(also “Managers”).
3. Focused L/S funds (“Focused L/S Funds”), in which WTG invests the Private Fund’s
assets, utilizing a long/short strategy, in a concentrated portfolio of direct investments.
Third-Party Funds and External Managers are hereinafter referred to as “External Managers”
unless the context requires otherwise. The investment objective, strategies, and any applicable
investment restrictions will generally be described in the applicable Private Fund offering
documents, organizational documents, subscription documents and/or investment management
agreements (collectively, the “Private Fund Governing Documents”) and may be changed in
accordance with the Private Fund Governing Documents and as permitted by law. Item 8 provides
additional information on Private Fund investment objectives and associated risks.
The Private Funds are offered to investors who are qualified clients and accredited investors,
including high net worth individuals, banks, thrift institutions, trusts, estates, charitable
organizations, pension funds, sovereign wealth funds, endowments and other corporations. WTG
provides investment advice directly to the Private Funds and does not tailor its advice to individual
investors in the Private Funds.
Managed Accounts
For SMAs, WTG manages each in accordance with its investment objectives, strategies,
restrictions and guidelines, which are set forth in an investment management agreement with the
Client or are otherwise incorporated into the Client’s governing documents. Managed Account
investment objectives, fee arrangements and terms are individually negotiated. Managed Account
relationships are generally subject to significant account minimums.
Wrap Fee Programs
WTG does not participate in wrap fee programs.
Assets Under Management
As of December 31, 2023 WTG is managing $384 million in regulatory assets.