A. Description and Overview
Hollencrest Capital Management, LLC (“HCM” or the “Firm”) is a California limited liability company registered
with the SEC as an investment adviser. The Firm was founded in 1999 and is located in Newport Beach, California.
HCM offers a range of wealth management and investment advisory services for its clients.
The following individuals comprise the Firm’s Senior Management; the Firm’s founders have worked together
since 1994:
Gregory P. Pellizzon, Managing Director, Chief Executive Officer, Senior Portfolio Manager, Founder
Peter J. Pellizzon, Managing Director, Chief Operations Officer, Portfolio Manager, Founder
Robert Wolford, Managing Director, Director of Marketing, Portfolio Manager, Founder
Cameron Akers, Managing Director, Chief Investment Officer
Susan Nakamura, Chief Compliance Officer, Director of Portfolio Administration
In addition to its registration with the SEC as an investment adviser, HCM is an insurance agency licensed with the
California Department of Insurance.1
B. Types of Advisory Services Offered
HCM provides a broad and robust range of services designed to meet the unique objectives of the Firm’s clients.
HCM offers the following main advisory services:
Wealth Management
Consulting Services
Services for the Ultra‐Affluent
Business Owner Advisory Services
1. Wealth Management
There are three components to the Firm’s wealth management services: (a) risk assessment and management;
(b) portfolio design; and (c) strategic planning. Initially, HCM works with a wealth management client (herein
referred to as “Client”) to understand the Client’s risk tolerances and investment objectives and review
current investments and liabilities in order to assess the Client’s long‐term wealth management needs. From
there, HCM creates one or more portfolios comprised of investments that HCM believes are best suited to
meet the Client’s current risk profile and investment goals. The Firm’s assessment takes into account the
following information, among other things, which helps to formulate its recommendations and security
1 The Firm is licensed with various states as an insurance agency and has an affiliated licensed insurance agency, Hollencrest Insurance
Services, LLC (“Hollencrest Insurance Services”). Hollencrest Insurance Services recommends life insurance products through its strategic
partner, TRC Financial. Clients of HCM are under no obligation to purchase insurance products through Hollencrest Insurance Services or
TRC Financial.
selections:
Individual and family needs and wishes
Total return objectives
Risk tolerance
Financial information (e.g., other assets, tax liabilities, cash flow needs, debts, financial obligations)
Personal and family planning
Gifting strategies and philanthropic activities
Any other information applicable to the Client’s investor profile
HCM generally manages Client portfolios on a fully discretionary basis. The types of investments HCM utilizes
for its Clients’ portfolios include traditional securities, such as domestic and foreign equity and fixed income
securities, and cash/cash equivalents. HCM also utilizes mutual funds and exchange traded funds (“ETFs”),
and sometimes invests in exchanged traded notes (“ETNs”), real estate investment trusts (“REITs”), options,
futures and warrants in order for Clients to gain exposure to certain asset classes or investment thesis. In
addition, HCM uses non‐traditional and at times illiquid investments, including alternative investments,
variable annuities, commodities, hedge funds, funds of funds, private equity securities, venture capital funds,
direct equity and loan investments, and private real estate investments for some clients. HCM is tax conscious
and considers ways to help Clients improve their tax efficiencies when managing portfolios. The asset mix in
Client portfolios vary and can be concentrated in a small number of investments or diversified across a variety
of investments. Although HCM does not impose a minimum account size or minimum annual fee, HCM
typically recommends Clients open accounts with a minimum of $1 million in investable assets.
Additionally, HCM’s services and interactions regarding retirement accounts and employee benefit plans
governed under Employee Retirement Income Security Act of 1974, as amended (“ERISA”), (e.g., 401(k)
accounts, IRA accounts) are designed in an effort to comply with the concerns of the Department of Labor’s
(“DOL”) references to Registered Investment Advisors as having the role of Fiduciary.
Private Investments/Alternatives
For Clients who meet certain qualifications and when appropriate, HCM recommends that a portion
of such Client’s assets be invested in private investments, including but not limited to, private equity
and venture capital funds and direct investments, loan funds, alternative funds and direct investments
in real estate (“Private Investments/Alternatives”). It is important for those Clients that receive a
recommendation to invest in Private Investments/Alternatives to read the applicable offering
documents (and/or agreements they are party to) prior to investing to understand the risks and
conflicts of interest pertaining to the Private Investments/Alternatives.
There are times when HCM (and/or its affiliates and employees) participates in Private
Investments/Alternatives. In many instances, these are investment opportunities whereby the Firm
only receives income or returns in accordance with the terms of the offering. On other occasions,
HCM is involved as the general partner or as a passive non‐controlling member of the general partner
or manager and will participate alongside Clients. In the event that HCM is compensated for its
services in this capacity and recommends the Private Investment/Alternative to a Client, a conflict of
interest exists due to HCM having a direct financial interest for recommending the Private
Investment/Alternative. HCM mitigates this conflict by disclosing its role as the general partner or as
a passive non‐controlling member of the general partner or manager, as well as a description of any
compensation to be received by Hollencrest, prior to or simultaneously with making the
recommendation to a Client. Also, in the event that HCM is compensated for its services in relation
to Private Investments/Alternatives, HCM does not charge asset‐based fees for wealth management
(discretionary) or consulting services (see “Item 5: Fees and Compensation”) on those specific assets
held by Clients.
Additionally, Private Investments/Alternatives incur sourcing and diligence expenses. These expenses
relate more generally to investment sourcing and diligence for alternative investment strategies and
include fees, costs, and expenses of identifying, investigating (including conducting due diligence with
respect to), evaluating, structuring, and negotiating potential investments for such strategy. Sourcing
and diligence expenses incurred with respect to the pursuit of particular investments that are never
actually completed are referred to as “broken deal” expenses. Examples of such “broken deal”
expenses include fees and expenses of any legal, investigative, financial, accounting, consulting, or
other advisors or lenders, investment banks and other financing sources in connection with arranging
financing for transactions that are not completed; any travel and accommodation expenses; and any
deposits or down payments that are forfeited in connection with, or amounts paid as a penalty for,
uncompleted transactions. These types of broken‐deal expenses are borne by the Client investor
accounts, any affiliated funds and other co‐investment vehicles that participate in the relevant
investment strategy. The proportions of such expenses are generally allocated pro‐rata and vary from
period to period. There are instances where an investment deal does not close due to a majority
Client investor rescinding his/her commitment. If the majority Client investor cannot be replaced by
another investor, the deal is essentially “dead” and any broken deal expenses are borne by that Client.
Once a Private Investment/Alternative is completed there are other transaction‐related expenses,
including certain organizational expenses (e.g., those related to the establishment of a multi‐
investment platform for a strategy); legal, accounting and other professional fees and expenses; travel
costs, lodging, ground transportation and meals; fees and expenses of consultants; and costs and
expenses of research and technology (such as costs of specialty data subscription and license‐based
services and risk analysis software). Transaction‐related expenses for completed investments not
reimbursed by a third‐party are generally allocated pro‐rata based on the percentages of the
investment held by the relevant Client investors.
The Hollencrest Private Investment Committee (the “Investment Committee”) establishes investment
guidelines and supervises the Firm’s investment activity in regard to private investments and
alternative assets. The Investment Committee regularly monitors investment results, reviews
compliance with the Firm’s investment objectives and guidelines, and reports to Senior Management.
The Investment Committee establishes due diligence protocols for private investments and
alternative assets, and monitors these investments after funding. In addition, the Investment
Committee determines appropriate valuation methodologies for hard to price, illiquid assets through
its Private Investment Valuation Sub‐Committee on an as‐needed basis.
2. Consulting Services
HCM provides consulting services to Clients (herein referred to as “Consulting Clients”) who desire
customized, non‐discretionary services in the following areas:
Development of Investment Policy Statements (“IPS”), guidelines, objectives, or risk tolerances
Preparation of an asset allocation study for long‐term assets or a particular strategy (including
evaluation of assets held at other securities firms)
Investment review services
Investment performance measurement for specific accounts and/or pools of assets
Consolidated reporting
Transaction and position reconciliations of outside assets
Assistance with evaluating and selecting a trustee, custodian, actuary, administrator, or other
advisory/service provider
In addition, the firm’s consulting advisory services provide financial/wealth management advice and
consultation on an “incidental” (as‐needed) basis which does not involve continuous monitoring of clients’
investments. These services include, but are not limited to, investment analysis and asset allocation and
selection as well as “non‐securities advice”, such as consultation on such matters as risk management,
retirement and education funding, cash flow management, debt reduction, tax planning, and estate planning.
3. Services to the Ultra‐Affluent
HCM offers certain non‐investment related services to ultra‐high net worth families. The Firm defines “ultra‐
affluent” as Clients having $10 million or more in investable assets. These services include the following:
Planning services including analysis of detailed financial and other quantitative and qualitative
information to assist and support clients in the decision‐making process for long term planning –
these planning services include utilizing the MoneyGuide / Wealth Studios platform to generate
analysis and reports for the benefit of the client.
Providing strategic advice on acquiring assets, including assisting with valuations, negotiations, and
deal structuring.
Assisting with structuring and running family meetings, including defining core values, teaching
wealth responsibility, and motivating next generation family members.
Mentoring and managing succession issues.
4. Business Owner Advisory Services
HCM offers non‐investment
related business owner advisory services which consist generally of financial
planning, consultation, and advisory services related to a business owner’s continued ownership interest in,
or a potential business‐related transaction regarding, their business. In connection with the business owner
advisory services, HCM will assist the business owner as follows to the extent applicable to their situation:
Assisting the business owner with understanding general cash flow requirements, asset allocation,
retirement funding, estate planning considerations, philanthropic considerations, and related
financial planning, in each case as such matters relate to the business owner’s interest in the business.
Assisting the business owner with determining options and strategies for the transfer of ownership of
or control over their business, including a transfer to family members.
Assisting the business owner with introductions to brokers, dealers, and investment banks (each a
“BD”), and assisting the business owner with the evaluation and engagement of a BD to assist with a
potential business‐related transaction. Following the engagement of a BD, HCM provides ongoing,
as‐needed consultation services to the business owner including interpretive advice regarding the
business, any business‐related transaction, or the BD.
C. Hollencrest Bayview Partners, LP
HCM is the investment adviser and general partner (“GP”) to Hollencrest Bayview Partners, LP (“Bayview Fund”),
a privately offered alternative fund of funds. HCM will recommend Bayview Partners to clients while taking into
consideration the Client’s needs, including total return objectives, risk tolerance, and other assets and obligations
of the client. Admission as an investor in Bayview Partners is not open to the general public and investors must
meet the definition of an Accredited Investor. The SEC's definition of Accredited Investor is put forth in Rule 501
of Regulation D of the Securities Act of 1933. An Accredited Investor can generally be a bank, brokerage,
registered investment adviser (RIA), some employer‐sponsored retirement plans, and some trusts. To be an
Accredited Investor at the individual level, a person must have an annual income of $200,000, or $300,000 on
joint basis, for the past two consecutive years and be able to demonstrate that this income level will continue. An
individual can also be considered an Accredited Investor if he or she has a net worth exceeding $1 million, either
individually or jointly with his/her spouse. The SEC also allows individuals who are a general partner, executive
officer, or director for the issuer of unregistered securities. In some cases, if a person can demonstrate education
and experience with unregistered securities, they may be considered an Accredited Investor. Clients are under
no obligation to consider or make an investment in the Bayview Fund. It is important that each prospective client
investor read and understand the offering materials prior to investing.
Bayview Partners is not intended as a complete investment program and is designed only for Clients who are
sophisticated persons in connection with financial and business matters and are able to bear the economic risks
associated with their investments. In its capacity as adviser to Bayview Partners, HCM is responsible for managing
the assets in the Fund. HCM does not show preferential treatment of the Fund over its other advisory Clients,
either in selection of recommended securities, or in the employment of trading and investment strategies.
The Fund’s portfolio invests in, including but not limited to, the following asset types:
• Mutual funds
• Closed‐end funds
• Exchange Traded Funds (ETFs)
• Loan funds
• Individual equity securities
• Individual fixed income securities
• Bridge lending
• Futures
• Real estate loans and mortgages
• Alternative investments (e.g., hedge funds, private equity, venture capital funds, private real
estate, and direct investments)
Apex Fund and Custody Services LLC (the “Administrator” or “Apex”) is the third‐party administrator (“TPA”) of
the Fund. The qualified custodian of the securities account for Bayview Partners is Fidelity Brokerage Services
LLC, a member of NYSE and SIPC.
D. Other Privately Offered Pooled Investment Vehicles
HCM serves as investment adviser to other privately offered pooled investment vehicles focused on single
investment strategies, typically focused on private equity or venture capital, which are formed as limited
partnerships or limited liability companies (where HCM also acts as the general partner or manager). Generally,
HCM’s pooled investment vehicles are made available to Client investors who are “accredited investors” under
the Securities Act of 1933, as amended (the “1933 Act”), and “qualified clients” under the Investment Advisers
Act of 1940, as amended (“Advisers Act”). In most cases, Client investors must also be “qualified purchasers”
under the Investment Company Act of 1940, as amended. These pooled investment vehicles are not made
available to the general public and are not registered investment companies. HCM’s private pooled investment
vehicles are managed by HCM in its sole discretion.
E. Administrative Services to the National Philanthropic Trust (NPT)
HCM provides administrative services to NPT, a Donor Advised Fund and Not‐For‐Profit Organization, through the
Administrative Service Program (DAF Administrative Services) pursuant to a separate consulting agreement.
Under this program, HCM provides asset allocation services, executes orders, issues grant requests, and provides
other administrative services on behalf of NPT. In addition, HCM helps to facilitate payments to third‐party
advisers for their services related to selecting and facilitating donations to NPT from individuals, trusts, or other
legal entities who donate cash or securities to NPT.
F. Private Real Estate Investments
HCM serves as investment adviser related to privately offered real estate investments. HCM will provide due
diligence, asset management, and other advisory services in its capacity as an adviser related to these
investments.
HCM typically has a passive non‐controlling ownership interest in the general partner formed by the sponsor for
each such real estate investment through which HCM is compensated. For any such arrangement where HCM
receives income related to an investment also offered to a Client, and such Client participates in that investment,
HCM will not charge the Client an asset‐based advisory or consulting fee for that investment. Please refer to “Item
5: Fees and Compensation” for additional information.
G. Outside Assets
Clients sometime have certain assets that pre‐date the inception of their relationship with HCM or that Clients
have independently decided to purchase without a recommendation from HCM (“Outside Assets”). Outside
Assets are likely to possess a higher degree of risk than is appropriate for a Client’s current investment objectives
or financial situation. At the mutual agreement of HCM and a Client, the Firm will agree to provide certain services
with respect to such Outside Assets. Specific services provided by HCM, per discussion with the Client, could
include monitoring, consulting, and/or reporting.
H. Affiliated Investments
Senior management and consultants of HCM (“Hollencrest Affiliated Persons”) have for their own individual
benefit invested in outside business ventures and hold equity ownership interests in said ventures. These
investments are outside the scope of investment advisory services offered through HCM as an investment advisor
(the “Affiliated Investments”). Generally, HCM Clients are not entitled to be involved in these Affiliated
Investments. Nonetheless, there are HCM Clients that have invested in one or more of said ventures with equity
interests after the initial investment of Hollencrest Affiliated Persons, albeit in circumstances in which they
typically invested directly and did not invest through HCM. In addition, as part of an offering to raise capital for
one of these ventures, certain HCM Clients have been extended the opportunity to invest (based upon specific
internal criteria established by HCM) in convertible promissory notes for that particular Affiliated Investment.
Given the existing initial investment of Hollencrest Affiliated Persons, HCM requires these Clients to acknowledge
in writing the existence of certain conflicts of interest as well as to agree that the Client’s election to invest in this
venture is non‐discretionary in nature.
I. General Information on Advisory Services
1. Information Received by Clients
HCM will not assume any responsibility for and is not obligated to verify the accuracy of any information
provided by a Client or from a Client’s other professionals (e.g., attorney, accountant, etc.) and HCM is
expressly authorized to rely on such information. Under all circumstances, Clients are responsible for
promptly notifying HCM in writing of any material changes to the Client’s financial situation, investment
objectives, time horizon, or risk tolerance. In the event that a Client notifies HCM of changes in the Client’s
financial circumstances, the Firm will review such changes and, if needed, recommend revisions to the Client’s
portfolio.
2. Client Agreements
Engagement of HCM to provide advisory services requires Clients to enter into a written agreement with HCM
setting forth the terms and conditions under which the Firm shall render its services (collectively, the
“Agreement”). The Agreement between HCM and the Client remains in effect until terminated by either party
pursuant to the terms of the Agreement. Neither HCM nor the Client will assign the Agreement without the
consent of the other party. Transactions that do not result in a change of actual control or management of
HCM shall not be considered an assignment.
3. Recommendation of Service Providers
To the extent requested by a Client, HCM will recommend the services of other professionals (e.g., attorneys
and accountants) for certain non‐investment purposes. The Client is under no obligation to engage the
services of any such recommended service provider and HCM does not receive compensation from
recommended service providers.
4. Independent Consultants / Third‐party Service Providers
Certain independent consultants and third‐party service providers associated with HCM will be used or
recommended by the Firm to its advisory Clients. For example, an independent consultant of HCM owns a
real estate consultation firm, which provides certain services on behalf of real estate private investments
recommended by HCM to its Clients. While the real estate consultation firm is not an affiliated entity, under
these circumstances HCM’s independent consultant is receiving an economic benefit as a result of HCM’s
recommendation of these real estate private investments. This arrangement poses a conflict of interest of
which investors should be aware.
J. Assets Under Management (as of Dec 31, 2023):
Type AUM in US Dollars
Discretionary RAUM $1,072,044,910
Non‐Discretionary RAUM $1,297,878,513
Assets under Advisement $449,658,579
Total $2,819,582,002
Regulatory assets under management (“RAUM”) figures are the gross market values available at the time of fee
calculations for the period ending December 31, 2023 of the accounts and assets (which include assets on which
no fees are assessed) designated as discretionary and non‐discretionary in the Agreements between HCM and its
Clients, or per client instruction for client designated non‐discretionary assets. In addition to RAUM, HCM has
assets under advisement which refer to non‐discretionary assets that are part of the firm’s overall advisory
services and/or client reporting but not eligible for being counted as RAUM.