Pathstone Family Office, LLC (“Pathstone”) began business in 2010 and has transacted in several
acquisitions over the past several years to significantly expand its business.
Pathstone, through Pathstone Intermediate Holdings, LLC, is a wholly owned subsidiary of Pathstone
Holdings, LLC which is further owned by investment vehicles controlled by Kelso & Company (“Kelso”)
and by Lovell Minnick Partners, LLC (“LMP”), as well as certain employees and clients of Pathstone
both directly and indirectly. See our response to Item 10 for additional information regarding Kelso
and LMP ownership.
Pathstone is an integrated wealth management organization providing multi-generational financial
management services. Pathstone provides comprehensive wealth management, for individuals,
families, and institutions, including private foundations and family entities. Pathstone also provides
family office services, including financial planning, consulting, expense management, bill pay,
concierge services, philanthropic management, tax compliance/tax return preparation to individuals,
investment limited partnerships, pension and profit- sharing plans, trusts, estates, charitable
organizations, corporations and business entities.
The aggregate assets managed, advised and/or reported on by Pathstone as of December 31, 2023,
are $62,079,370,504. This figure reflects the $38,674,446,225 in discretionary and $9,583,694,258 in
nondiscretionary regulatory assets under management, totaling $48,258,140,483, in addition to
$13,821,230,021 in supplemental client assets we advise or report on. The supplemental amount
represents assets for which Pathstone provides advisory and reporting services to clients, which may
include personal property, outside investments, and other real assets (e.g., gold, silver, etc.). These
supplemental assets are not calculated pursuant to GAAP accounting methods, do not include
liabilities, and may be valued based on information provided by the clients and not verified by
Pathstone. The assets acquired from acquisitions within the current calendar year are not included
herein and shall be updated upon the next annual updating amendment filing.
Pathstone provides its clients with a broad range of services, as described above and in more detail
below. Our services may also include tax-related and other non-investment related matters.
Pathstone advises private family clients by delivering tailored family-centric wealth management
services and solutions which are customized to address each family’s wealth dynamic. These tailored
services are based on a comprehensive understanding of each client’s unique circumstances, asset
base, interests and financial goals. Pathstone will assist clients in determining the client’s investment
needs and objectives, as well as risk tolerance through the use of an asset optimization model for asset
allocation and research on investment managers and investments. Clients are permitted to place
reasonable restrictions on investing in certain securities and may also request that Pathstone refrain
from recommending affiliated private investment funds to them. In addition to the family office
services to ultra-high-net worth families, Pathstone also provides investment management services
on a discretionary or non-discretionary basis to institutional investors and foundations.
Types of Advisory Services
For the majority of client portfolios, Pathstone has discretionary authority to engage third party,
unaffiliated investment advisers or other sub-advisors, or utilize portfolio models provided by a third-
party provider (herein “Independent Managers”) to manage portions or all of the client’s portfolio
consistent with the desired investment strategy. Portions of clients’ portfolios may be maintained as
separately managed accounts managed by an Independent Manager, or client’s assets could be
invested in mutual funds, closed-end registered investment companies, or exchanged traded funds
(“ETFs”). Pathstone performs routine due diligence on Independent Managers, as well as utilizes the
due diligence services of unaffiliated third-party wealth management solutions. Factors that
Pathstone considers in recommending Independent Manager(s) typically include, among other things,
the client’s stated investment objective(s) and risk tolerance and the Investment Manager’s
management style, performance, reputation, financial strength, reporting, pricing, and research.
Pathstone will review the performance of each Independent Manager against appropriate
benchmarks when applicable, and review the investment style of the Independent Manager against
the client’s investment parameters to ensure the Independent Manager continues to meet the client’s
investment goals. Pathstone has discretionary and nondiscretionary relationships with clients to hire
and fire Independent Managers.
For clients seeking to build investment portfolios that align with their values, Pathstone also offers an
investment strategy, including via Independent Managers, focused on impact investing. We develop
and manage custom investment strategies designed to achieve targeted environmental and social
impact without sacrificing financial performance. Our sustainable investing strategy accounts for
numerous factors, including the impact investments have on people, society, and the economy, to
properly evaluate decisions.
For a separate account, the terms and conditions under which the client will engage an Independent
Manager may be set forth in a separate written agreement between the client and the Investment
Manager. In other cases, Pathstone may have the authority to sign this agreement on behalf of the
client and/or may itself be a party to the agreement. Pathstone shall continue to render advisory
services to the client relative to the ongoing monitoring and review of account performance, for which
Pathstone shall receive an annual advisory fee which is based upon a percentage of the market value
of the assets being managed by the designated Independent Manager(s). Pathstone also provides sub-
advisory investment management services to third-party advisers for their clients on a discretionary
basis.
As discussed further in Item 5, the client may incur fees in addition to those charged by Pathstone,
the designated Independent Manager(s), and the corresponding broker-dealer and custodian. In
addition to Pathstone’s written disclosure statement, the client shall also receive the written
disclosure statement of the designated Independent Manager(s).
Pathstone provides investment advisory services to clients who choose to grant us the discretionary
authority to make securities trades without their express approval for each trade (“discretion”) or to
clients who, after receiving our investment advise, grant Pathstone approval to trade, referred to as
non-discretionary. Clients’ assets may be invested in mutual funds, ETFs, other pooled investment
vehicles, separate accounts managed by Independent Managers (as described above), and/or other
permitted private and public investments. For these services, Pathstone charges the investment
management fee further described below in Item 5.
Whether a client relationship is discretionary or non-discretionary, our services may often include
family office services, as further described below. However, clients may retain us for only our
investment advisory services, with
no family office service component (e.g., institutional or private
foundations). Multi-generational families will typically hire Pathstone for both investment advisory
services and a broad range of family office services.
In performing its services, Pathstone will not be required to verify any information received from the
client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly
authorized to rely on such information. Pathstone may recommend the services of itself and/or other
professionals to implement its recommendations. Clients are advised that a conflict of interest exists
if Pathstone recommends its own services. The client is under no obligation to act upon any of the
recommendations made by Pathstone under a family office/consulting engagement and/or engage
the services of any such recommended professional, including Pathstone itself. The client retains
absolute discretion over all such implementation decisions and is free to accept or reject any of
Pathstone’s recommendations. Moreover, each client is advised that it remains his/her/its
responsibility to promptly notify Pathstone if there is ever any change in his/her/its financial
situation or investment objectives so that Pathstone may evaluate whether its previous
recommendations and/or services should be modified for the future.
Pathstone currently manages or advises numerous advisory accounts, and these accounts may have
or will have similar investment objectives to other accounts. For ultra-high net worth and institutional
clients, it is not anticipated that accounts having identical or substantially similar investment
objectives will have identical or substantially similar investment portfolios. Differing investment
portfolios can be expected as the result of several factors, including, without limitation, the following:
different investment decisions made by the advisers assigned to the clients; regulatory constraints
that apply to certain accounts but not to others; investment constraints imposed by the client; and
the amount of cash available for investment at certain times. As a result of factors such as these,
accounts may have a different investment portfolio (and, as a result, different performance results)
from other accounts even though the accounts have identical or substantially similar investment
objectives. Portfolio advisers are authorized to invest the assets of accounts for which they have
investment responsibility in a wide range of underlying investments. In addition, there may be
circumstances when one account will sell a security while another account may purchase the security
on the same day.
For certain legacy clients, pre-existing securities holdings may be held in the clients’ portfolio as non-
managed. Non-managed assets are pre-existing investments such as a private fund, equities, mutual
fund, outside manager, ETF, or other fund product in which the Firm may have been asked to provide
information or an opinion on, however the position was not sourced by Pathstone. Non-managed
assets are contained within the client’s portfolio and/or reflected on reports as an accommodation
and the Firm generally will not provide advice relative to these assets. As such, the client, and not
Pathstone, shall be exclusively responsible for these assets. These legacy positions may not be
included in the calculation of quarterly billing. If the client desires the Firm provide investment
management services with respect to any non-managed assets, the client may engage the Firm to do
so for a separate and additional fee.
Among the assets to which Pathstone provides continuous and regular investment supervisory or
management services are assets held by clients in their 401(k) accounts with various mutual fund
companies. Because the Firm will be responsible for effecting the transactions in these accounts, it
will request the client’s username and password permitting online access to the account. Pathstone
has adopted appropriate physical and procedural safeguards to control access to the usernames and
passwords it obtains. There are other situations in which clients receive our advice about such
accounts but remain responsible for effecting recommended transactions using their own access
credentials.
Pathstone Portfolio Platform (“P-Cubed™”)
P-Cubed™ is a proprietary investment execution structure that provides the ability for investors to
hold diverse investments in a single account with the goal of lowering costs. P-Cubed™ provides for
continuous tax loss-harvesting with a continued focus on asset location in addition to asset allocation.
Investments held in P-Cubed™ may consist of both passive and active separately managed accounts
(SMAs), mutual funds, ETFs, or single stock positions across a variety of asset classes. Third-party
investment advisers are responsible for the investment decision making, while the Overlay Manager
administers all trading, reconciliation, and reporting. Third-party Independent Managers retained to
manage portions or all of a client’s portfolio charge their own asset-based fees or performance fees,
while the Overlay Manager will charge their own fees for their role within the program.
Pathstone Pooled Investment Vehicles
Pathstone, or an affiliated entity, serves as the managing member or general partner to private pooled
investment vehicles which are further disclosed in Item 10. These investment vehicles are created for
the purpose of facilitating investments by our clients in various private equity, hedge fund or private
real estate investments structured as 3(c)(7) or 3(c)(1) partnerships in client portfolios.
Pathstone’s clients are advised to promptly notify Pathstone if they wish to impose any reasonable
restrictions upon Pathstone’s discretionary investment management services.
Pathstone may also provide clients periodic investment-related white papers, research reports, and
articles related to asset allocation and investment policy development without a charge as part of its
consulting services.
Pathstone is the sub-advisor to an open-ended mutual fund which acts as a fund-of-funds and
primarily invests in other pooled vehicles such as ETFs, exchange-traded notes (ETNs), open- and
closed-end funds, and certain individual securities and futures. Unless otherwise agreed, Pathstone
may invest client assets in the mutual fund.
Professional Service Providers
As a courtesy to clients, Pathstone may introduce clients to other investment and non-investment
related service providers/professionals, such as accountants, attorneys, insurance providers, other
luxury service providers, etc. Pathstone does not receive any financial or economic benefit in
exchange for these referrals. The client is under no obligation to engage the services of any such
introduced professional. The client retains absolute discretion over all such implementation decisions
and is free to accept or reject any introduction or recommendation from Pathstone. Although
Pathstone may have experience with these service providers, Pathstone has not performed due
diligence on these service providers and is not responsible for the services provided by these service
providers and/or professionals. Pathstone is not responsible for any losses caused by the actions of
any third party recommended by Pathstone, including, without limitation, any accounting or legal
professional services.