Overview
ACIM has been in business since February 2006 and started advising its first client in April 2006. ACIM
offers the services described below to several private investment funds (each a “Fund” and collectively
referred to as the “Funds”). The firm is principally owned in the majority by Ms. Daphne W. Scalamandre
(“Scalamandre”). As of March 27, 2024, ACIM managed discretionary client assets valued at approximately
$282,044,638 and manages no non-discretionary assets.
ACIM is filing a single Form ADV in reliance on the position expressed in the letter of the SEC staff to the
American Bar Association, Business Law Section, dated January 18, 2012, regarding the Investment
Advisers Act of 1940 – Section 203(a) and 208(d). Also included in this filing in reliance on this letter:
Aurelian Capital GP, LLC the general partner of AGR Master, LP; Aurelian Holdings, LLC the general
partner of Aurelian Plus, LLC; AC Energy Partners, LLC the general partner of AC Energy, LLC; and AC
FTR, LLC the general partner of AC Energy, LLC.
Typically, ACIM provides investment advice to Funds formed as “master-feeder” structures which have a
foreign entity (a Cayman Island exempt company) that “feeds” into a domestic entity (either a limited
partnership or limited liability company) with the same investment strategy. These
Funds serve as multi-
manager portfolios for investors. The Funds are “Qualified Purchasers” as such definition is set forth in
Section 3(c)(7) of the Investment Company Act of 1940, which generally requires investors to have a net
worth greater than $5,000,000. ACIM typically invests its client assets in investment vehicles trading in
physical commodities and their related financial instruments, with a lesser emphasis on the equities and
debt of companies. On an incidental basis, ACIM makes venture capital investments in sectors unrelated
to physical commodities and their related financial instruments where ACIM has identified a venture capital
portfolio company investment (each a “Portfolio Company and collectively the “Portfolio Companies”) in
which it may get involved in an active transformation with the belief that such involvement may generate a
high level of return on investment. Investments are made through private funds or accounts managed by
third-party managers and may also be made directly.
ACIM does not tailor its advisory services or investment objectives or strategies to the requests or needs
of individual Fund investors. Investors are not permitted to restrict the Fund’s investments.
For a more detailed description of ACIM’s strategies and associated risks, please see the section titled
Method of Analysis, Investment Strategies and Risk of Loss.