PPMC was formed by S. Donald Sussman in 1989 and is equally owned by Mr. Sussman and 11
senior employees of PPMC, all of whom are listed in Schedule A of PPMC’s Form ADV Part 1A.
Paloma Partners Advisors LP (“Paloma Advisors”), is a relying adviser with respect to PPMC’s
investment adviser registration. Mr. Sussman owns and controls Paloma Advisors; additional
information about Paloma Advisors is provided in Schedule R of PPMC’s Form ADV Part 1A.
PPMC has a wholly-owned subsidiary, Paloma Switzerland GmbH, which maintains an office in
Zurich, Switzerland. Paloma Switzerland GmbH primarily provides investor relations and marketing
services to the Paloma Fund (defined below). References herein to “PPMC” include Paloma
Switzerland GmbH, as applicable.
PPMC and Paloma Advisors are collectively referred to herein as Paloma Management.
Paloma Management provides discretionary investment advisory services to the Paloma Fund, and
its advice is given in accordance with the investment objectives and guidelines as set forth in the
Paloma Fund’s private offering memoranda and other organizational and governing documents, as
described and defined below. Investors in the Paloma Fund cannot obtain services tailored to their
specific needs. Paloma Management does not participate in wrap fee programs.
As of December 31, 2023, Paloma Management advised $3,318,788,440 in net asset value on a
discretionary basis. Neither PPMC nor Paloma Advisors manage assets on a non-discretionary basis.
THE PALOMA FUND
The “Paloma Fund” or the “Fund” is a multi-strategy hedge fund with a master–feeder structure
including three feeder funds, Paloma Partners L.L.C. (a Delaware entity), Paloma International
Limited (a Cayman Islands entity) and Paloma Offshore Limited (a Cayman Islands entity), which
invest their investable assets in either the master fund or one or more Cayman Islands exempted
limited partnership, as described below. The Paloma Fund seeks to achieve attractive long-term
risk-adjusted returns through dynamic capital allocation among a changing set of investment
strategies and Portfolio Managers (defined below).
Except as otherwise described below, the investment program of the Paloma Fund is exclusively
carried out through the master fund, Paloma International L.P., and other entities through which
the master fund makes investments or enters into transactions (collectively, the “Master Fund”).
The feeder funds may invest in the Master Fund or one or more Cayman Islands exempted limited
partnership (each, an “SPV Master Fund”) directly or indirectly through an intermediate vehicle.
The feeder funds will participate (directly or indirectly through an intermediate vehicle) in each SPV
Master Fund at a fixed percentage, reflecting each feeder fund’s participation percentage in the
Master Fund at the time the applicable underlying investment is made by such SPV Master Fund. In
addition, in connection with certain investments made by the Master Fund or an SPV Master Fund,
the feeder funds will participate (directly
or indirectly through an intermediate vehicle) in such
investment at a fixed percentage, as determined by Paloma Management. There are no
diversification requirements or material limitations on the strategies, investments, instruments,
leverage, markets or countries in which the Paloma Fund may invest.
Paloma Management has ultimate discretion and control over the Paloma Fund and its
investments. Investment advice is provided to the Paloma Fund pursuant to the terms of each
feeder fund’s confidential private offering memorandum and other organizational and governing
documents (collectively, “Fund Documentation”). Paloma Management’s responsibilities to the
Paloma Fund include: the selection of Portfolio Managers and strategies, managing the Master
Fund’s allocations and exposures across strategies and among Portfolio Managers, providing
investment and credit risk management advice, and hedging the Master Fund’s risk as deemed
necessary. Portfolio Managers is the collective term used for Trading Teams (defined below),
managers of Portfolio Funds (defined below) and managers of other direct investments in public or
private companies.
Trading Teams are investment teams that pursue investment strategies in the Master Fund.
Trading Teams are either engaged as independent contractors or are employed by PPMC.
Independent contractors are responsible for their own operations (e.g., compliance and
registration(s), supervision of employees, hiring of personnel and information technology) but are
subject to Paloma Management’s portfolio and risk management oversight. Descriptions of Trading
Teams and their activities in this Brochure generally apply to all Trading Teams (regardless of
whether or not a Trading Team is an independent contractor (“External Trading Team”) or PPMC
employee (“Employee Trading Team”), unless otherwise noted.
The Paloma Fund also makes direct investments in public or private companies and Portfolio Funds.
Portfolio Funds are standalone funds or other investment vehicles into which the Master Fund
invests capital.
Additional information about the Paloma Fund’s entities is included in Section 7.B of Schedule D in
PPMC’s Form ADV Part 1A.
DISCLAIMER
No guarantee or representation is made that the Paloma Fund’s investment program, including,
without limitation, its investment objectives, diversification, strategies or risk monitoring processes,
will be successful. The risk management process includes an effort to monitor and manage risk, but
does not imply low risk. There may be risks which are not monitored or controlled and risks that
may be greater than forecasted, especially in unusual market conditions. Nothing herein is
intended to imply that the Paloma Fund’s investment strategy is “conservative”, “safe”, “risk free”,
or “risk averse”. There can be no assurance that the Paloma Fund’s investment objective will be
achieved or that its portfolio design and risk monitoring strategies will be successful. Investors may
lose all or substantially all of their capital.