BPCM is an SEC-registered investment adviser whose principal place of business is 1300 El Camino Real
Suite 100 Menlo Park, CA 94025. BPCM began conducting business in 2006.
Sanjeev Sardana, Chief Executive Officer, is the firm's sole principal owner (i.e., those individuals and/or
entities controlling 25% or more of this company). BPCM provides investment management and consulting
services to clients listed in Item 7 below.
INVESTMENT MANAGEMENT SERVICES
BPCM provides investment advice to clients based on the individual needs of each of its clients. After
reviewing each client’s financial circumstances and determining each client’s goals and objectives, we
create and manage a portfolio based on those goals and objectives. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Our investment
recommendations are not limited to any specific product or service offered by a broker-dealer or insurance
company. We will manage accounts on either a discretionary or non-discretionary basis. Based on the
client’s needs, portfolios will include some or all of the below-listed investments:
o Exchange-listed securities
o Securities traded over the counter (“OTC”)
o Securities of foreign issuers
o Warrants
o Corporate debt securities
o Commercial paper
o Certificates of deposit
o Municipal securities
o Mutual fund shares
o Exchange-traded funds (“ETFs”)
o United States governmental securities
o Options contracts on securities
o Interests in partnerships investing in real estate
o Interests in partnerships investing in oil and gas
o Interests in private equity, venture capital funds, and private companies
o Hedge funds and private funds
o Cash or cash equivalents
The foregoing investments will only be implemented when consistent with the clients’ stated investment
restrictions, limitations, and prohibitions. Moreover, since some investments involve certain
additional degrees of risk relative to others; they will only be implemented/recommended when consistent
with the client's stated investment objectives, tolerance for risk, liquidity, and suitability.
Where appropriate, BPCM also recommends the use of independent investment manager(s) (“Independent
Manager(s)”) to manage certain types of investments in the client’s portfolio. We will monitor and review
the performance of the recommended Independent Managers. Before making a recommendation, we
conduct extensive due diligence of an Independent Manager, generally examining the following items:
• Management style
• Performance
• Reputation in the industry generally
• Financial strength
• Reporting
• Pricing
• Research
• Keyperson risk
BPCM also may render non-discretionary investment management services to clients relative to their
individual employer-sponsored retirement plans. In so doing, BPCM either directs or recommends the
allocation of client assets among the various security subdivisions that comprise the retirement plan. The
client assets shall be maintained at the custodian designated by the sponsor of the client’s retirement plan.
As of December 31, 2023, BPCM managed $500,691,655 on a discretionary basis and $263,515,836 on a
non-discretionary basis, resulting in total assets under management of $764,207,491.
CONSULTING SERVICES
Clients may receive investment advice on a more focused basis. We provide specific consultation and
administrative services regarding investment and financial concerns of the client. We will also consult on
insurance matters, including any underlying securities. Consulting recommendations are not limited to any
specific product or service offered by a broker-dealer or insurance company.
POOLED INVESTMENT VEHICLES
BPCM is the manager of BluePointe Private Equity Partners, LLC; a Delaware limited liability company
("BluePointe PE Fund" or “the Fund”). BPCM formed BluePointe PE Fund as a fund of funds to provide
its clients and certain other qualified investors with access to a diversified portfolio of private equity
investments and private real estate investments through investment in a group of investment funds. The
objective of the Fund is to generate significant, long-term
capital appreciation for the Fund's investors. The
Fund is a closed investment vehicle and is currently not accepting new subscriptions.
BPCM is the manager of BluePointe Distressed Credit Fund, LLC; a Delaware limited liability company
("BluePointe DC Fund"). BPCM formed BluePointe DC Fund in order to provide its clients and certain
other qualified investors with access to Colony Distressed Credit Fund II, L.P., a Delaware limited
partnership (“CDCF II”). The objective of BluePointe DC Fund is to generate current income and long-
term capital appreciation for that fund’s investors. The BluePointe DC Fund has been organized to invest
substantially all of its capital in a limited partnership interest or interests in CDCF II. CDCF II will seek
investments in, and active management of, a diversified investment portfolio of performing, sub-performing
and nonperforming commercial mortgage loans and other attractively priced real estate-related debt
investments. The BluePointe DC Fund is a closed investment vehicle and is currently not accepting new
subscriptions.
BluePointe Ventures, LLC (“BPV”) is a Delaware limited liability company that is owned by Sandeep
Sardana and Sanjeev Sardana. BPV acts as the investment manager to pooled investment vehicles structured
as limited liability companies (each referred to in this Brochure as a “BPV Fund”) and is responsible for all
investment decisions by and investment activities of the BPV Funds. BPV is also responsible for the day-
to-day operations of the BPV Funds. Sandeep Sardana is primarily responsible for the BPV Funds’
investment activities and acts as the Managing Director of BPV and investment manager to the BPV Funds.
Sanjeev Sardana acts as the Chairman of BPV and provides general oversight and fundraising for the BPV
Funds. Because BPV is “operationally integrated” with BPCM, BPCM will be responsible for the reporting
of the BPV Funds as private funds on its regulatory filings and in this disclosure brochure. Because of his
ownership in BPV, Sanjeev Sardana is entitled to receive a pro rata share of the special profit allocation
payable to BPV by the BPV Funds. Some BPV Funds are structured so that Sanjeev Sardana, and BPCM,
as a firm, are entitled to receive a special profit allocation payable by the BPV Funds as outlined in the
applicable limited partnership agreement. BPCM, including Sanjeev Sardana therefore have an incentive to
encourage clients to invest in the BPV Funds, which could be viewed as a conflict of interest between
BPCM and its clients. For certain BPV Funds in which BPCM clients invest, the client will not directly pay
an advisory fee to BPCM for their investment in BPV Funds, and for certain BPV funds in which BPCM
clients invest, a portion of the management fee received by BPV will be paid to BPCM. For BPV TechFund
III, LP and BPV SOF 1, LP, BPCM advisory clients pay advisory fees to BPCM, however they pay a reduced
BPV management fee on those funds. Furthermore, there is a possibility that certain vendors, funds, or fund
managers in which BPCM directs investments, could be investors in BPV Funds. While BPCM is motivated
to maximize returns and minimize risk for its clients, the foregoing factors could impact BPCM’s objectivity
as it relates to affiliated funds and could be a factor considered by BPCM in choosing among the various
investment alternatives otherwise available to its clients. Tomitigate this conflict, BPCM recognizes its
fiduciary duty to its advisory clients and puts the clients’ interests first. All such decisions must follow these
procedures regardless of compensation structure, perceived incentives to BPCM, or any other conflicts.
BPCM is the investment sub-advisor of BluePointe Insurance Dedicated Fund of the SALI Multi-Series
Fund, L.P. (“BluePointe ID Fund”), a Delaware Limited Partnership. The investment objectives of
BluePointe ID Fund are (i) to achieve absolute returns on a risk-oriented basis; and (ii) to generate returns
through a multi-manager strategy while attempting to control risk. The emphasis will include all sectors of
publicly traded United States equities, foreign securities, options, convertible securities, debt securities, and
all other types of securities and securities of privately held companies and private funds.