A. Description of the Advisory Firm
Legacy Partners, LLC (“Legacy”) is a Delaware LLC formed on August 25, 2014, with its
principal place of business in Los Angeles, California. Legacy was previously known as
Legacy Partners Ltd., an exempted limited liability company organized in the Cayman
Islands, and it has been an SEC-registered investment adviser since 2011. In August 2014,
Legacy Partners Ltd. was re-domiciled to the State of Delaware and renamed Legacy
Partners, LLC. Control personnel remained the same.
The RIA has been in continuous operation since October 2011 and the principal owner is
Robert Choi. Legacy’s registration with the SEC does not imply a certain level of skill or
training.
B. Types of Advisory Services
Legacy provides investment management services primarily related to investments in
Greater China. Currently, Legacy provides these services to three funds: (i) Legacy
Capital, L.P.; (ii) Legacy Harmony, Ltd.; and (iii) Legacy Capital III, L.P.(the “Funds”);
which invest in private equity funds and direct co-investments. Legacy also provides
investment management services for certain non-discretionary assets it manages.
Private Equity Fund of Funds and Co-Investments Advisor
Legacy provides continuous advice and management to the Funds, through research and
analysis of various private equity investment opportunities in Greater China. In addition,
it monitors the performance
of the Funds and serves as Investment Manager of the Funds.
Legacy does not and will not hold itself out to the general public as an investment adviser,
financial planner, or any other service provider. Legacy evaluates investments the Funds
may pursue based on the goals of each of the Funds, the investment time horizon of the
Funds, risk tolerance levels, as well as other factors.
Services Limited to Specific Types of Investments
Legacy generally limits its investment advice to Greater China-focused private equity
investments. Legacy may pursue other investment opportunities to diversify the Funds’
portfolios in accordance with the goals and restrictions of each of the Funds.
C. Client Tailored Services and Client Imposed Restrictions
Legacy tailors its services to the Funds. Pursuant to the Funds’ operating and partnership
agreements, the Funds are restricted from investing in certain securities or types of
securities.
D. Wrap Fee Programs
A wrap fee program is an investment program in which the investor pays one stated fee
that includes management fees, transaction costs, fund expenses, or any other
administrative fees. Legacy DOES NOT participate in any wrap fee programs.
E. Amounts Under Management
Legacy has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 546,920,480.00 $ 244,217,762.00 December 2022