Operational and Organizational Information
Apis, is a Delaware limited liability company that is registered as an investment adviser with the U.S.
Securities and Exchange Commission (“SEC”). The Firm provides investment advisory services to its
sponsored private investment funds (each a “Fund” and collectively, the “Funds”) and a unit trust (the “Unit
Trust,” together with the Funds are each a “Client” and collectively the “Clients”). The Funds are for qualified,
sophisticated investors (“Investors”). The Firm has been in business since March 2004. The Firm was
initially registered as an investment adviser with the SEC in April 2004. The Firm remained registered with
the SEC, except for certain interim withdrawals in 2004, 2005 and 2007. In March 2012, the Firm
transitioned to an exempt reporting adviser filing status with the SEC. In September 2013, the Firm re-
applied for registered investment adviser status with the SEC, based on the types of clients it managed.
The principal owners of the Firm and their percentage ownership interests are as follows: Mr. Daniel Barker
(50%) and Mr. Eric Almeraz (50%).
Advisory Services
The Firm provides investment management services on a discretionary basis to its Clients in accordance
with the respective Client’s investment management agreement and other relevant governing documents.
For example, the Clients operate as pooled investment vehicles and attempt to provide diversification,
management expertise and other advantages to their investors. The Firm’s advisory services include,
among other things, providing advice regarding asset allocation and the selection of investments. The
Clients’ investment objective is to seek consistent positive absolute returns by taking long and/or short
positions in stocks that are undervalued or overvalued compared to their peers, in a range of market
capitalizations, with an emphasis on small and mid-capitalization equity
securities, on a global basis. The
Firm seeks to limit losses by selecting companies that in the Firm’s view are trading at a discount to intrinsic
value. No assurance can be given, however, that the Clients will achieve their investment objectives, and
investment results may vary substantially over time and from period to period.
In addition, the Firm has, and may in the future, enter into agreements, such as side letters, with certain
underlying Investors of the Funds that may, in each case, provide for the terms of investment that are more
favorable to the terms provided to other underlying Investors of the Funds.
The Firm does not hold itself out as specializing in a particular type of advisory service. Please review the
Firm’s investment guidelines, specified below under “Client Investment Guidelines and Parameters.”
Client Investment Guidelines and Parameters
As stated above, the Firm provides investment advisory services to Clients primarily investing in globally
traded public equity securities. The Firm does take long and short positions and trade in a wide variety of
securities and financial instruments, domestic and foreign, of all kinds and descriptions, whether publicly
traded or privately placed, including, but not limited to, common and preferred stocks, bonds and other debt
securities, convertible securities, limited partnership interests, mutual fund shares, options, warrants,
commodities, futures, derivatives (including swaps, forward contracts and structured instruments),
currencies, monetary instruments and cash and cash equivalents. The Firm also may utilize derivative
securities (primarily options).
Wrap Fee Programs
The Firm does not participate in wrap fee programs.
Client Regulatory Assets Under Management (“RAUM”)
As of December 31, 2023, the Firm managed approximately $582,714,808 of advisory assets, all of which
were on a discretionary basis.