Introduction
Weatherbie is a privately owned investment advisory firm that was founded in 1995. Weatherbie
is wholly-owned by Alger Group Holdings, LLC (“AGH”), which is wholly-owned by Alger
Associates, Inc. (“AAI” and together with Weatherbie’s affiliates, “Alger”). Weatherbie is under
common ownership with Fred Alger Management, LLC (“FAM”) and Redwood Investments, LLC
(“RI”), each a registered investment adviser. Alexandra D. Alger, Hilary M. Alger and Nicole D.
Alger together own (directly or through trusts they have created for the benefit of their families)
approximately 35%, 35% and 29%, respectively, of AAI.
Weatherbie specializes in the research and portfolio management of small- and mid-cap growth
equity stock portfolios, principally stocks traded on U.S. exchanges. The portfolios may also hold
American Depositary Receipts. To a lesser extent, Weatherbie also provides investment advice
with respect to other securities, including options contracts on various securities and securities
indices, warrants, private placements, mutual fund shares, swaps, and United States Government
and Agency securities.
Weatherbie offers multiple investment strategies, including Growth, Specialized Growth,
Enduring Growth, Long/Short, and Select 15. Weatherbie also sub-advises a portion of the
Dynamic Opportunities Strategy, which is managed by Weatherbie’s affiliate, FAM. Please see
FAM’s Form ADV Part 2A for additional information on this strategy.
Weatherbie provides both discretionary and non-discretionary investment advisory services to
institutional investors through separate accounts, U.S. and foreign registered and privately offered
funds, as well as through a third-party sponsored fund and a bank sponsored collective investment
trust; and to retail investors through wrap programs and U.S. and foreign registered funds.
Clients can and relevant laws, rules, or regulations will impose restrictions on investing in certain
securities or certain types of securities, or on the percentage of ownership in any single security,
sector or industry. In addition, each of Weatherbie’s strategies follows a specific investment
discipline with their own portfolio construction parameters. Accordingly, Weatherbie will not
enter into an advisory relationship with any prospective client whose investment objectives are
incompatible with Weatherbie’s investment philosophy or strategies or who seeks to impose
unduly restrictive guidelines.
For client accounts subject to the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”, and such accounts, “Plan Accounts”), Weatherbie provides services both as a registered
investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”),
and as a fiduciary as that term is defined in Section 3(21)(A) of ERISA.
Wrap Fee Programs
Clients can access certain of Weatherbie’s investment strategies through programs sponsored by
unaffiliated financial intermediaries, advisers or planners in which Weatherbie serves as an
investment sub-adviser (“wrap programs”). The wrap programs for which Weatherbie serves as an
investment sub-adviser are listed in Section 5.I.(2) of Weatherbie’s Form ADV Part 1, a copy of
which is available either 1) on request or 2) on the SEC’s website at the following link:
https://www.adviserinfo.sec.gov/Firm/105991
Weatherbie offers advisory services through the following types of wrap programs:
1.
Single Contract Program.
In Single Contract Wrap Programs, clients pay the sponsor of
the wrap program a single fee (the wrap fee), the sponsor pays a percentage of the wrap fee
to FAM for its investment management services, FAM pays a percentage of the wrap fee
to Weatherbie for its investment sub-advisory services, and the sponsor executes trades and
administers the account without additional charges to the clients. Each client enters into an
agreement with the sponsor to provide discretionary investment management services to
the client and each investment manager available in the program maintains a sub-advisory
agreement with the sponsor.
2.
Dual Contract Program.
In Dual Contract Wrap Programs, sponsors offer clients a package
of services including trade execution and account administration, along with a menu of
investment managers to choose from. Each client enters into a contract with the sponsor,
which covers custody, brokerage and other services, and separately enters into an
investment management agreement with FAM, who
appoints Weatherbie to act as
investment sub-advisor. In these programs, Weatherbie and its affiliates are generally
directed by clients to effect transactions for their accounts through the program sponsor or
the sponsor’s broker-dealer affiliate; however, FAM and Weatherbie have the ability to
effect transactions in these wrap accounts through a non-sponsor affiliated broker-dealer if
doing so allows FAM or Weatherbie to achieve better execution. Although fees and
services are unbundled, clients do not pay FAM or Weatherbie directly for their investment
management services, but instead direct payments through the program sponsor or the
sponsor’s broker-dealer affiliate. The sponsor or its affiliate then remits payment to FAM,
who remits payment to Weatherbie, for its investment sub-advisory services.
3. Model Portfolio Program. In a Model Portfolio Program, Weatherbie enters into an
agreement with the sponsor to provide an initial model portfolio to the sponsor, which the
sponsor then seeks to replicate for its clients. Weatherbie will then regularly provide
updated model portfolios to the sponsor as positions and position weightings change for a
strategy. Weatherbie does not place trades on behalf of accounts in these programs and
therefore has no ability to ensure that accounts conform to the model portfolio provided.
Trades for model portfolios may be placed by the sponsor after Weatherbie has placed
trades for wrap programs and other clients for which it serves as investment adviser. The
sponsor remits payment to Weatherbie for its investment advisory services.
Management of Wrap Programs
In managing accounts in a wrap program, Weatherbie generally does not invest in limited
partnerships, illiquid securities, or foreign securities not traded on a U.S. exchange, and such
accounts will not participate in allocations of initial public offerings. Weatherbie also attempts to
minimize the tax impact of portfolio transactions. In an effort to minimize the volume of trading
for accounts in a wrap program, Weatherbie generally has a minimum position size for a
transaction. Such minimum position size may not exist for non-wrap accounts. Finally, certain
wrap sponsors or clients may impose security restrictions as well as minimum cash limits on their
accounts. As a result, Weatherbie will generally impose the most restrictive limit across wrap
sponsors in the affected strategy(ies).
The timing of trades for wrap accounts will generally differ from other accounts and will generally
be made later in time than for other accounts managed by Weatherbie (see Item 12: Brokerage
Practices, for details about Weatherbie’s trading practices for wrap accounts). Further, Weatherbie
maintains relationships with multiple sponsors, and the timing of trades placed by Weatherbie for
wrap accounts is on a “rotational” basis among all sponsors.
The practices described above will cause a wrap program account’s performance to diverge from
other accounts managed by Weatherbie according to the same strategy.
Given the structure of wrap programs and the fact that payments to Weatherbie are received from
FAM, who receives payments directly from the wrap sponsor, Weatherbie does not believe it
receives any direct compensation from clients who participate in the wrap programs (including
Plan Accounts). The wrap sponsor is responsible for billing and collecting any fees owed by
clients with respect to their participation in the wrap program.
Each client’s ability to allocate, reallocate or redeem its investment under a wrap program is
governed by the terms of the client’s agreement with the wrap sponsor and the disclosure provided
by the wrap sponsor. Any termination-related provisions would be found in the agreement
between the client and the wrap sponsor.
For wrap program accounts, Weatherbie generally does not negotiate brokerage commissions or
other costs related to the execution of trades because those charges are generally included in the
single fee paid by the client to the sponsor, and the client has generally contractually agreed to
execute trades through the sponsor or the sponsor’s broker-dealer affiliate. In the event that
Weatherbie selects a broker-dealer other than the sponsor or its affiliate, the client would typically
pay a commission, concession, or dealer mark-up or mark-down, in addition to the wrap fee paid
to the sponsor, as well as other administrative fees to settle such a transaction..
Client Assets Under Management
As of December 31, 2023, Weatherbie had $2,108,351,612 in discretionary assets under
management for clients.