A. Advisory Firm
ICG Advisors, LLC is a limited liability company formed under the laws of the State of California in 2008.
ICG is majority-owned by Pippy Corp., a Delaware corporation, which is 100% owned by The Assaf Family
Trust. ICG offers personalized investment management services to separately managed account clients,
and it also serves as the investment adviser to private pooled investment funds as described below.
B. Specialization
ICG generally provides investment advice on a wide variety of U.S. and foreign investment products,
including privately placed securities, but does not hold itself out as specializing in any particular type of
investment advisory service.
C. Advisory Services
Separately Managed Accounts
ICG provides investment advisory services to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations, partnerships and other business entities (individually, a “Client
Account”, and collectively, the “Client Accounts”). Prior to ICG rendering any advisory services, a Client
Account enters into an investment consulting agreement with ICG or establishes a separately managed
entity (e.g., a limited partnership or limited liability company) that is sponsored and/or managed by ICG
pursuant to an operating agreement. Each investment consulting agreement or operating agreement (each,
an “Advisory Agreement”) sets out the terms and conditions of ICG’s advisory relationship with the Client
Account. ICG bases its investment advice and recommendations on the particular needs, investment
objectives, and investment guidelines of each individual Client Account.
With respect to most of its Client Accounts, ICG’s services include advising on the selection of unaffiliated
investment managers (“Portfolio Managers”) to provide discretionary management to the Client Account
portfolios, either directly or indirectly through an investment product such as a private fund. Prior to
recommending and selecting a Portfolio Manager, ICG will discuss the Portfolio Manager with the Client
Account. This discussion will generally provide information on the Portfolio Manager’s strategy, structure,
liquidity, fees and track record. ICG may also recommend investments in certain private funds that are
sponsored or otherwise affiliated with ICG, as outlined below.
ICG may assist Client Accounts in formulating investment objectives and guidelines, and in writing
investment policy statements. Client Accounts and potential Client Accounts are generally given an asset
management questionnaire which assists ICG in understanding the needs and risk tolerance levels of the
Client Account in order to make customized portfolio recommendations for each Client Account.
Once a Client Account’s objectives are determined and agreed upon, ICG conducts an asset allocation study
to determine the recommended portfolio asset mix and which Portfolio Managers/asset classes might best
achieve the Client Account’s risk/reward goals. The investments made by a Client Account with these
recommended Portfolio Managers/asset classes may be in the form of separate accounts, mutual or
exchange traded funds or private investment vehicles.
Discretionary and Non-Discretionary Client Accounts
Client Accounts may be discretionary or non-discretionary. For both types of Client Accounts, ICG is
available to answer questions regarding the account and to facilitate communication between the Client
Account and any Portfolio Managers.
Non-discretionary Client Accounts require ICG to obtain the Client Account’s consent for all investment
activities, including allocations to Portfolio Managers. Neither ICG nor its associated persons will have
any trading or transactional authority with respect to a non-discretionary Client Account (including with
respect to third party Portfolio Managers and their related subscription and withdrawal documentation, if
applicable).
For discretionary Client Accounts, ICG has the authority to manage the Client Account on a discretionary
basis. Such authority will generally include execution of subscription and withdrawal documentation of
underlying Portfolio Managers and the authority to transfer funds to and from the underlying Portfolio
Managers and their investment products.
Retirement Accounts (DOL PTE 2020-02)
When ICG provides investment
advice to Client Accounts regarding retirement plan accounts or individual
retirement accounts, ICG is acting as a fiduciary within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way ICG makes money may create some conflicts with your interests, so we operate under
a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this
special rule’s provisions, ICG must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
Reporting and Monitoring of Portfolio Managers
ICG provides consolidated performance reporting and ongoing monitoring of each Client Account’s
portfolio. Client Accounts will receive reports from the custodian of the Client Account and from ICG at
least on a quarterly basis. The ICG reports are generated from the Client Account’s custodial statements
and statements provided by the Portfolio Manager or the Portfolio Manager’s administrator. ICG does not
assume responsibility for the accuracy of information furnished by any third party.
ICG Private Funds
ICG also provides discretionary investment advisory services with respect to private pooled investment
vehicles that are sponsored by ICG or an affiliate of ICG (each, an “ICG Fund”). ICG will manage each
ICG Fund based on the investment objectives and investment restrictions set forth in the governing
agreement or confidential offering memorandum of the relevant ICG Fund (each, a “Memorandum”) and
in any other written materials furnished from time to time by the ICG Fund to ICG.
Currently, ICG serves as investment adviser to the following ICG Funds: ICG Access Fund, LLC, ICG
Insurance Fund II LLC, ICG CoreSci Holdings, LLC, and ICG Special Opportunities Fund 1, LP. ICG also
serves as investment advisor to a series of illiquid credit funds, including ICG Credit Opportunities Fund,
LP, ICG Credit Opportunities Fund 1A, LP, ICG Credit Opportunities Fund II, LP, and ICG Credit
Opportunities Fund 2A, LP (collectively, the “ICG Credit Funds”). Lastly, ICG serves as investment
advisor to a series of Real Estate Funds, including ICG Television City Holdings, LLC, ICG MB Holdings,
LLC, ICG Silvercup Holdings, LLC, ICG Studio Holdings, LLC and Radford Studio Center CI, LLC
(collectively the “ICG Real Estate Funds”). The ICG Funds were formed to pool assets of Client Accounts
and other investors (each an “ICG Fund Investor” or collectively, the “ICG Fund Investors”) for the purpose
of investing with one or a number of underlying Portfolio Managers selected by ICG. As such, most ICG
Funds are structured in a manner that is commonly referred to as a “fund of funds.” The ICG Funds are
intended to provide diversification, management expertise and other advantages to ICG Fund Investors or,
in the case of the ICG Real Estate Funds, access to an investment opportunity in a specific real estate asset.
The ICG Funds are managed only in accordance with their own investment objectives and are not tailored
to any particular ICG Fund Investor.
ERISA investments in ICG Private Funds
In accordance with the Department of Labor’s Final Regulations under Section 408(b)(2) of the Employee
Retirement Income Security Act of 1974, as amended, (the “Regulation”) ICG will provide retirement plan
asset investors disclosure information as required under the Regulation. This disclosure will include a
description of services, ICG’s fiduciary status, information about how ICG is compensated and information
pertaining to any termination/redemption fees that may be assessed. Additionally, ICG will ask for a signed
consent acknowledging these disclosures.
D. Wrap Fee Programs
Not applicable.
E. Assets under Management (as of December 31, 2023)
Discretionary: $1,538,479,233
Non-Discretionary: $5,386,426,826