Description of the Firm
System 2 Advisors, L.P. (“System 2” or the “Firm”) is a Delaware limited partnership with its principal
place of business in Summit, New Jersey. System 2 was founded by Anupam Ghose and Robert C. Jones
in June 2011, and commenced operations in April 2012. Anupam Ghose owns 80% and Robert C. Jones
own 20% of the interests.
Advisory Services Offered
General
Except with respect to the Funds and IOPP (as defined below), System 2 offers customized investment
advisory services using a proprietary investment process referred to as the Comprehensive Investment
Analysis (“CIA”) that is based upon findings in cognitive psychology, statistics, and behavioral economics.
The CIA uses a range of proprietary internal models, external models, and fundamental analysis to evaluate
stocks along multiple dimensions, including both fundamental and statistical assessments of each stock’s
relative attractiveness, to identify and rank stocks with potential to outperform their peers. Using the CIA
in combination with client specific investment restrictions, guidelines and goals, the strategy uses a
proprietary algorithm to quantitatively construct diversified portfolios of global equity securities traded
predominantly in the developed markets. System 2 may use a range of quantitative tools to construct
portfolios in a cost-efficient manner and to manage the overall risks. Pursuant to an advisory agreement
with the Board of Trustees (the “Board” or the “Trustees”) of Asset Management Fund (the “Trust”),
System 2 utilizes the CIA model to provide sub-advisory investment management services to a mutual fund
in a strategy that does not compete with the Funds. (See Item 10 of this Brochure for additional information.)
With respect to its Funds, System 2 provides investment advisory services tailored to the specific investment
guidelines set forth in the confidential private placement memorandum of each of the Feeder Funds (as
defined below). System 2 will advise on all investment decisions including, buying and selling securities,
issue instructions to custodians, and select broker-dealers to execute securities transactions. While the
confidential private placement memoranda gives System 2 broad latitude in providing advice, the Master
Fund (as defined below) generally invests in a diversified portfolio of equities and equity derivatives, listed
or unlisted, quoted or unquoted or traded on any stock exchange or the over the counter market, primarily
in or related to India and through investment in American Depository Receipts and/or Global Depository
Receipts representing securities of Indian companies. Underlying investors in the Feeder Funds do not have
the ability to impose restrictions on investing in certain securities or types of securities. System 2 offers
and sells interests in the Feeder Funds in private transactions solely to accredited investors and qualified
purchasers, or professional investors, as the case may be, and certain employees of System 2 and/or its
affiliates.
System 2 maintains a proprietary trading account called the Tara Strategy Development Ltd in which the
firm's portfolio managers may test new strategies from time to time. System 2’s intentions are to test
strategies that are vastly different from the current Fund's strategy to avoid conflicts of interest. Successful
strategies may then be offered to clients as part of the Fund or in a new vehicle.
System 2 may offer other products which invest in other asset classes or use different investment
methodologies in the future.
As set forth in more
detail below, the Firm currently provides investment advisory services to certain private
investment funds and separately managed accounts.
The Simplify Tara India Opportunities ETF (IOPP) seeks to provide long term capital appreciation. The
fund will invest in equity securities of Indian issuers. It is actively managed with a goal of outperforming
the MSCI India Index. IOPP is sub-advised by System Two Advisors, a firm with a deep bench of equity
analysts and portfolio managers with a proven history in managing Indian equities.
Tailoring Advisory Services to the Client
The Funds
System 2 offers investment advisory services to six private investment funds (each a “Fund” and together
the “Funds”) pursuant to an Investment Management Agreement between System 2 and each Fund. Each
Fund client is a private investment fund that is exempt from registration with the Securities and Exchange
Commission. The Funds to which System 2 provides investment advisory services are Tara Emerging Asia
Liquid Fund (US), L.P., a Delaware limited partnership (the “TEAL US Feeder”), Tara Emerging Asia
Liquid Fund (MU) Limited, a public company limited by shares incorporated under the laws of Mauritius
(the “TEAL Offshore Feeder,” and together with the US Feeder, the “TEAL Feeder Funds”), and Tara
Emerging Asia Liquid Fund, a public company limited by shares incorporated under the laws of Mauritius
(the “TEAL Master Fund,” and together with the Feeder Funds, the “ TEAL Funds”). Additionally, System
2 provides investment advisory services are Tara India Systematic Alpha (US), L.P., a Delaware limited
partnership (the “TISA US Feeder”), Tara India Systematic Alpha MU Feeder (Incorporated VCC Sub-
Fund), a public company limited by shares incorporated under the laws of Mauritius (the “TISA Offshore
Feeder,” and together with the US Feeder, the “TISA Feeder Funds”), and Tara India Systematic Alpha (
Incorporated VCC Sub-Fund), a public company limited by shares incorporated under the laws of Mauritius
(the “TISA Master Fund,” and together with the Feeder Funds, the “TISA Funds”).System 2 provides
investment advisory services tailored to the specific investment guidelines set forth in the confidential
private placement memoranda of each Feeder Fund. The Feeder Funds seek to attain their investment
objectives by investing all or substantially all of their investable assets in their respective Master Funds,
which has the same investment objective and strategy as each of the Feeder Funds. Underlying investors
in the Funds do not have the ability to impose restrictions on investing in certain securities or types of
securities.
The Advised and Sub-Advised Accounts
Investment Companies where a sub-advisory or advisory agreement is in place, clients may request that
System 2 manage their accounts with various restrictions, including security specific restrictions, risk
restrictions, geographic restrictions, liquidity restrictions, leverage restrictions, as well as other limitations
which may be agreed upon between the Investment Company ( the advisor) and System 2 (the sub-advisor).
System 2 will generally accept such restrictions and incorporate them in the client’s sub-advisory or
advisory agreement.
Wrap Fee Programs
System 2 does not participate in wrap fee programs.
Amount of Client Assets Managed
As of December 31, 2023, Systems 2 managed, on a discretionary basis, client assets totaling approximately
$48 million. In addition, System 2 managed, on a non-discretionary basis client assets totaling
approximately $474 million.