Peter Kimmelman Asset Management LP (“PKAM”) was established (as a predecessor entity) in 1979
and became a New York State limited liability company in 1996. The principal owner is Peter
Kimmelman, with minority non-operating ownership interests held by his wife, his daughter, and his
son. PKAM provides investment supervisory and advisory services to our clients, including both
nondiscretionary and discretionary advisory services. For discretionary accounts, we provide
ongoing supervisory and management services with respect to the account. For non-discretionary
accounts, we provide continuous oversight of existing investments, make recommendations based
upon the needs of the client and, if such recommendations are accepted by the client, we arrange for
or effect the purchase or sale of the recommended securities or other investments. PKAM also
provides general advice about investments and relevant news to clients on an individual basis from
time to time as appropriate, and without fee or other additional charge. Advice is offered to clients
predominantly in the area of alternative investments, which include hedge funds that invest in
hedged long/short, relative value, distressed, and other hedged strategies, private equity funds, long
only and lastly, and funds of funds.
As of December 31, 2023, PKAM managed a total of approximately $488,587,200, of client assets, which
consists of discretionary accounts totaling approximately $249,873,200 and non-discretionary accounts
totaling approximately $238,714,000.
PKAM takes an individualized approach to its clients, creating a customized portfolio for each. We
interview each client in depth and construct each separate portfolio to respond specifically to the client’s
mandate in terms of its investment objectives, risk and volatility tolerances, liquidity needs, yield
objectives, time horizons, and general outlook.
Risk Management and Controls
Each PKAM client portfolio is constructed to respond specifically to that particular client’s mandate.
We seek to develop at the onset with each client an understanding covering the following parameters:
a) downside risk tolerances;
b) volatility parameters;
c) liquidity needs in terms of percent required to be available within three months, six months, one
year;
d) targeted objectives of investment program;
e) envisioned time horizons to measure and accomplish articulated investment goals; f) client’s tax
circumstances.
Customized to implement and express the client’s desires as set forth above, each account is designed
to give consideration to the following categories, with the guidelines indicated, subject to revision
following discussions with each client to accommodate other factors:
1) Diversification: As we are not able to foresee market movements, we believe that it is important to
assure a highly diversified portfolio, comprised of at least twenty managers, with the maximum
position size of under 10%, an average position size of approximately 5%-6%, and some starter
position sizes ranging from 0.75% to 2%.
2) Manager Size: To be considered for inclusion, vehicles must have at least $250 million under
management, of which PKAM clients should account for no more than 5%. This will ensure that
redemptions on our part will not force the manager to “fire sale” holdings or activate gate provisions,
prolonging the withdrawal process.
3) Manager Qualifications: Manager must have at least six years of experience, with a three-year
transportable record, including experience in shorting. The manager should have a significant
portion of his own liquid net worth invested in the vehicle.
4) Bias Against Certain Sectors: Commodities trading advisers and macro global managers are
generally excluded, unless there is a specific directive to the contrary from the client. Where a client
raises the issue, we explain that those styles inherently defy our ability to be familiar with the
underlying portfolios and correlations with other managers.
5) Portfolio Concentrations: We wish to de-emphasize and limit allocations to vehicles with
concentrated portfolios carrying top ten positions over 65%, top ten short positions over 25%, and
industry concentrations over 35%.
6) Leverage: We closely evaluate the leverage in different sectors of absolute return managers, and for
hedged equity, we view cautiously managers who run gross exposures greater than 250% or net long
exposures greater than 70%.
7) Service Providers: Underlying prime brokers, administrators and accountants should be of
“household familiarity.” If not, then PKAM will scrutinize such service providers with more caution.
8) Quantitative analysis is useful in providing insights into the manager’s capabilities but, in our
opinion, it is primarily and ultimately the qualitative assessment of being invested in established
managers who have been able to demonstrate over a significant period of time an ability to make
money on both the long and short sides that is more important. Generating alpha is one of the key
characteristics of a talented manager.
9) Fund’s Investor Base: Knowledge of the underlying beneficial ownership in the particular fund
under review is essential. We feel more comfortable with the manager having a high percentage of
his own liquid net worth invested in the Fund on a pari-passu basis and that holding being among
the largest investors. We seek to understand the Fund’s sourcing of its capital. Is there a mismatch
between the underlying liquidity of invested assets versus the redemption rights of the holders? Is
the capital structure such that the manager might be forced to fire-sale assets under terms that would
be disadvantageous to remaining holders? Conversely, are the lock-up provisions unduly onerous,
thereby prolonging unjustifiably the ability to withdraw?
10) Non-Correlation: In constructing or modifying portfolios, we seek to understand the possible
correlation of proposed managers with the objective of seeking non-correlation. In our experience,
economics change and markets move too rapidly to predict successful market direction. Accordingly,
we do not intend to place outsized bets on specific industries or variables such as interest rates,
exchange rates, etc. In doing so, we are conceding that it is virtually impossible for all of our vehicles
to be performing well at one time. In fact, uniformly good or poor performance throughout a PKAM
portfolio is usually an indication that the markets are at an extreme point (on either the high side or
the low side) and may be due for reversal.
11) Compounding by Preservation of Capital: A cardinal principle of PKAM portfolio management is
the power and importance of compounding positive returns over time. To work its magic,
compounding
depends upon preservation of capital, which in turn depends on minimizing overall
draw-downs as much as possible.
12) Manager Turnover: Our historical turnover of managers has run approximately 15% per year. This
long term commitment to managers has served us well, as exemplified by our long term returns,
which are generally well above the commonly used indexes. We stress to potential clients that they
should look elsewhere if their inclination is to “cut their losses” after one to three months negative
returns. We believe that an expectation of generating positive returns virtually every month is not
realistic.
13) Due Diligence: Having concentrated almost exclusively in the alternatives area since 1991, we have
formed a judgment of many players within the field and possess a deep as well as current knowledge
of that landscape and population. If the vehicle is known to PKAM but not in the portfolio at that
time, our due diligence would consist of refresher interviews.
The amount of due diligence required when investing with a new fund is a function of our general
familiarity with the particular field or niche in which that fund operates. If we are familiar, then due
diligence consists of reading the manager’s presentations, due diligence questionnaire, three years of
partners’ letters, and audited financial statements, analysis of the alpha generation record, followed
by intensive interviewing of the principal managers. At the very minimum, an on-site visit to the
manager at their own facilities is required. In preparing for that, we will subject all of the managers’
returns to analysis in terms of attribution of long and short exposures, analysis of top ten longs,
avoidance of concentrated big bets, degree of non-correlation, growth of capital under management,
analysis of tax efficiency (for domestic accounts), peer review versus managers pursuing similar
strategies, ascertaining possible drifts of management style, etc. If we are not familiar with the
manager’s field or niche, our due diligence as outlined above, would be supplemented by similarly
getting to know comparable managers pursuing the same strategies in addition to the targeted
manager.
14) Monitoring: We monitor our clients portfolio managers absolute and relative performance to peer
competitors on a monthly basis. We do not believe that it is in our long-term interests to intrude
upon the managers for “weather checks.” Managers favor us as a firm that represents long-term,
stable investors, and because we are known to be sophisticated, knowledgeable asset allocators who
do not require hand-holding. Accordingly, we see no point in taking up their time needlessly. They
should be focused entirely on running their respective portfolios. However, given our philosophy
of management by exception, we will immediately investigate if we see deviations from the expected
range. This is just as important when returns are abnormally high as when they are disappointingly
low. We seek to gain an understanding as to what is actually happening.
We generally revisit our managers on-site once or twice a year and follow up with an evaluation
memorandum by the specific PKAM analyst assigned to follow that manager.
15) Crosschecks: We rely upon our long-term relationships with representatives of some of the
wealthiest families in America, with whom we meet periodically to share general views and ideas on
a broad range of investment issues, including markets, managers, product offerings, and the impact
of global political and economic changes on financial opportunities. We have found that excellent
insights and productive follow-up ideas can often be obtained by participation in those discussions.
16) Pricing of Underlying Manager Portfolios: There is a general presumption that we are investing in
highly established, reputable managers who share with their outside investors a coincidence of
economic interests due to having large amounts of their own capital at stake on a pari-passu basis.
Nonetheless, it has been our observation that when fraud materializes, it is often traceable to
incorrect pricing of certain illiquid holdings in the underlying portfolio. Thus, it is essential to
understand the processes by which a portfolio is priced. Assuming that the pricing has been
outsourced to the fund's offshore administrator or independent third-party service provider, does
that firm have a name of “household recognition”? If so, we will assume that that portion of the
portfolio that is traded regularly on one or more major exchanges is free of error. However, if we do
not recognize the name of the firm determining the priced portfolio and N.A.V, we need to
understand the reasons for selection as well as that firm’s history, size, capabilities, list of large clients
for reference checking, etc. Again, assuming that hurdle has been crossed, we focus on a portion of
the portfolio that is not traded publicly and then explore in depth the specific methodologies and
sources employed in determining the pricing of such securities. If there are claims that the portfolio
manager himself is the best one to understand these securities well or if the engagement of an outside
pricing service is needlessly costly, we become wary. We need to pursue the issues to a natural
conclusion in order to develop the requisite confidence in the accuracy of the fund’s net asset value.
17) Liquidity: We at PKAM have a much higher comfort level with established managers who have
demonstrated alpha generative skills for extended periods of time. Since that type of record often
attracts a multitude of investors wishing to gain entrance to such a vehicle, the negotiating power
switches to the manager. We need to evaluate the balance between the manager’s justifiable need to
assure the stability of his capital base versus his natural desire to lock up capital for extended periods
of time. We routinely accept one-year lock-up periods, but we evaluate carefully and skeptically the
manager’s need for more extended lock-up periods. Private equity excepted, lockup periods beyond
24 months are viewed with concern and should be accepted only with high caution. As part of our
due diligence investigations, we seek to understand the liquidity of the manager’s underlying
portfolio. What amounts can be liquidated within 30 days without disrupting markets or depressing
price levels? Similarly, what percentage of the portfolio is in trades that have natural durations of
six, twelve or eighteen months? In starting a new relationship and maintaining it through the years,
PKAM and its client need to articulate clear expectations of the overall liquidity of the underlying
portfolio (i.e., what percent of the PKAM portfolio can be liquidated within various time periods in
the future).