Firm Description
SIMS is a Delaware limited liability company. SIMS provides investment management services to its clients,
which currently consist of a single pooled master-feeder investment vehicle comprised of one feeder fund
and one master fund (together, the “Funds”). SIMS was formed in October 2013 under the name of “Strenta
Investment Management, Inc.” solely to operate the investment advisory business and to register with the
SEC. SIMS has been registered with the SEC as a registered investment adviser since January 2014. SIMS
is owned by a holding company Strenta, Inc. which is in turn owned by Kantan-Easy, LLC, an entity
beneficially owned by Carlos Feliciani and Eduardo Noguera and controlled by Eliyahu Weisz.
Consequently, Kantan-Easy, LLC, owns Strenta, Inc., and ultimately SIMS. SIMS’ day-to-day operations
are overseen by its Managing Director, William I. Lee. In February 2024, Strenta Investment Management,
Inc. was converted from a corporation to a limited liability company (LLC), and its name was changed to
“Strenta Investment Management Services, LLC”. SIMS was engaged by the Funds to make the investment
decisions for the Funds’ assets in accordance with the Funds’ confidential explanatory memorandum,
articles of association and investment policy statement (the "Governing Documents"). SIMS also provides
certain administrative services to a limited partnership, (the “Limited Partnership”) that ultimately invests in
the Funds.
SIMS is affiliated with a variety of entities owned by Strenta, Inc., (together, the “Strenta, Inc. Subsidiaries”),
including:
Strenta Intra-Operational Services, LLC provides operational support to the Strenta, Inc.
Subsidiaries, including information technology, human capital management, financial accounting
management and office management.
Strenta Administrative Services, LLC provides administrative services to various trusts and
foundations, some of which have underlying entities that invest in the Limited Partnership.
Strenta Philanthropic Granting Services, LLC provides support for the philanthropic
endeavors of
charitable trusts.
Strenta Protector Services, LLC provides protector services to foundations and trusts, some of
which have underlying entities that invest in the Limited Partnership.
Strenta Steward and Advisory Services, LLC provides services to oversee the economic interests
of the beneficiaries of foundations and trusts, some of which have entities that invest in the Limited
Partnership, including but not limited to, estate planning, tax planning and reporting, and other ad-
hoc administrative projects.
Jutaku Services Limited serves as the controlling member of the foundation council or trustee of
various trusts and foundations, some of which have underlying entities that invest in the Limited
Partnership.
Oak Services Limited (“Oak”) is the general partner of the Limited Partnership and is a SIMS relying
adviser in accordance with SEC guidance
1.
Personnel associated with the Strenta, Inc. Subsidiaries fall under SIMS’ compliance program and Code of
Ethics. More details concerning SIMS’ affiliations are provided under Item 10, Other Financial Industry
Activities and Affiliations.
Description of Advisory Services
SIMS provides advisory services to the Funds, its sole clients, on a discretionary basis based on specific
investment objectives and strategies outlined in the Governing Documents. SIMS seeks to maximize
investment returns through focus on forward-looking asymmetry between potential upside and downside
1 See SEC Staff No Action Letter (January 18, 2012) to the American Bar Association Sub Committee.
5
based on analysis of asset classes and market segments. Investors in the Funds may not impose
restrictions on investing in certain securities or certain types of securities.
As of December 31, 2023, SIMS has approximately $795.6 million dollars of regulatory assets under
management which are all managed on a discretionary basis.
Wrap fee programs
SIMS does not participate in wrap fee programs.