Nature of Advisory Business
Enhanced provides securities-related investment advisory services to its Clients (defined below)
with its principal business activities focused on participation in renewable energy, historic real
estate rehabilitation and affordable housing projects through federal and state incentive programs
and other public policy investment strategies as detailed more in Item 10 – Other Financial
Industry Activities and Affiliations.
Enhanced is a Delaware limited liability company that was organized in 2013 and was succeeded
by reorganization to the business of Enhanced Capital Partners, Inc. (“Predecessor”) following a
change in control of the Predecessor (the “Reorganization”). The Predecessor was a Delaware
corporation that was organized in 2008 and was succeeded by merger to the business of Enhanced
Capital Partners, LLC (“Enhanced Capital”), a former Delaware limited liability company,
organized in 1999. The Predecessor registered with the SEC as an investment adviser for the first
time in 2012. Enhanced registered with the SEC as an investment adviser for the first time in
2014, through succession by application to the investment advisory business of the Predecessor.
As detailed in Schedule R of Enhanced’s ADV Part 1, Enhanced has relying advisers, including,
Enhanced Capital Group, LLC (“ECG”), Enhanced Capital SBIC Management, LLC (the “SBIC
Manager”), Enhanced Puerto Rico LLC (“PR Manager”), Council & Enhanced Tennessee
Manager, LLC (the “Tennessee Manager”), Enhanced Capital Impact Lending, LLC (the “Impact
Manager”), and Enhanced Climate Finance LLC (“Climate Finance”) and collectively with the
foregoing, the “Relying Advisers”). Enhanced, together with its Relying Advisers, conducts a
single advisory business subject to a unified compliance program. References to “Enhanced”
throughout this Brochure refer to Enhanced together with its Relying Advisers, unless the context
otherwise requires.
The Texas Fund, the Tennessee Fund, the SBIC Fund, the PR Account, the CRSS Account and the
Sub-Advised Funds (all defined in this Brochure) constitute the only third-party clients for whom
Enhanced provides securities-related investment advisory services (the “Clients”). Enhanced also
participates in certain State Investment Funds (defined below) that are proprietary in nature and
are included on Part 1A of Enhanced’s Form ADV as proprietary accounts.
Investment advice to each of the Clients is tailored to the Client’s individual needs and investment
objectives and other criteria, as set forth in each Client’s limited partnership agreement,
performance agreement, private placement memorandum and/or investment management
agreements and, if applicable, in accordance with a Client’s statutory mandates or regulatory
restrictions for a particular program. Enhanced seeks out economically viable investments with
dedicated and competent management and a high degree of market potential. Enhanced also
applies a thematic framework in its investing, on behalf of its Client and other accounts, to generate
positive, measurable economic, environmental, and social (“EES”) impact alongside financial
return. Enhanced may accept clearly defined Client directives for responsible investing that do
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not conflict with the Enhanced’s EES policy of acting as a responsible investor by aligning private
sector resources with public policy goals to transform local economies for the benefit of investors
and community stakeholders. Enhanced manages all Clients in compliance with applicable
mandates and directives. For more detail, see in Item 8 – Methods of Analysis, Investment
Strategies and Risk of Loss.
As of December 31, 2023, Enhanced, including its Relying Advisers, had $331,250,503 of
discretionary regulatory assets under management and $637,820,836 of non-discretionary
regulatory assets under management.
State Investment Funds
Enhanced manages funds raised through state focused investment programs (“State Investment
Funds”) which have been created by state legislatures, state pension funds and the federal
government. These programs are intended to channel investment capital into targeted businesses
and thereby create jobs, increase tax revenues and establish a local investment community
infrastructure by attracting qualified managers to invest in businesses in such state. Each
legislatively enacted State Investment Fund has strict statutory investment mandates/regulatory
restrictions with respect to the types of businesses in which a State Investment Fund may invest.
All of the State Investment Funds are classified as proprietary accounts, with the exception of the
Enhanced Jobs for Texas Fund, LLC (the “Texas Fund”) and Council & Enhanced Tennessee Fund
LLC (the “Tennessee Fund”), which are the only State Investment Funds that are non-proprietary
clients.
The Texas Fund received an allocation of capital to invest pursuant to the Texas Small Business
Venture Capital Program administered by the Texas Department of Agriculture (the
“Department”) pursuant to a Performance Agreement between the Texas Fund and the Department
(the “Performance Agreement”). The Texas Small Business Venture Capital Program, which is
no longer active, was administered by the Department pursuant to the State Small Business Credit
Initiative Act of 2010 (the “SSBCI Act”) implemented by the United States Department of
Treasury. While the Texas Fund is no longer making investments, the Texas Fund primarily made
debt investments and a limited number of direct equity investments into companies located in or
with a substantial nexus to Texas. The investments made by the Texas Fund followed investment
parameters and restrictions of the SSBCI Act and the Performance Agreement.
The Tennessee Fund received an allocation of capital to invest pursuant to Tennessee’s Small
Business Investment Company Credit Act (“TNInvestco Act”) administered by Tennessee’s
Department of Economic & Community Development. While the Tennessee Fund is no longer
making investments, the Tennessee Fund primarily made equity investments in businesses (with
an emphasis on early-stage businesses) located in Tennessee. The investments made by the
Tennessee Fund followed investment parameters and restrictions of the TNInvestco Act. The
Tennessee Fund is co-managed by Council Capital, a non-related company that invests in growth
and early-stage growth companies and is based in Tennessee. All investment decisions were made
jointly by the Tennessee Manager and Council Capital. The Tennessee Manager is co-owned by
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Enhanced and Council Capital.
The Tennessee Manager has discretion over, but not custody of,
the assets of the Tennessee Fund.
SBIC Fund
Enhanced Small Business Investment Company, LP (the “SBIC Fund”) is a participant in the SBIC
program, as administered by the U.S. Small Business Administration (the “SBA”). The SBIC
Fund primarily makes debt investments in businesses that meet the investment parameters and
restrictions as set forth in Title 13, Chapter I, Part 107 of the Code of Federal Regulations and Title
13, Chapter I, Part 121 of the Code of Federal Regulations (the “SBIC Regulations”). It is noted
that, while the SBIC Fund may still make follow on investments in existing portfolio companies,
it is no longer making investments in new portfolio companies.
PR Account
The PR Manager provides investment advisory services to a separate account for a bank located
in Puerto Rico (the “PR Account”) that provides debt investments to privately held businesses
located in Puerto Rico that meet the requirements of the Community Reinvestment Act.
Investments made by the PR Account must be made in a business that satisfies the requirements
of Section 208.22(b) (1) of Regulation H of the Federal Reserve Act. The PR Manager co-manages
the PR Account with Popular Securities, LLC, a third-party entity that is not affiliated with the PR
Manager or Enhanced. The PR Manager does not have custody of or discretion over the assets of
the PR Account.
CRSS Account
In keeping with the Client’s impact objectives, ECG provides investment advisory and related
services to a separately managed account (the “CRSS Account”) owned by Crossroads Systems,
Inc., a public company focused on investing in businesses that promote economic vitality and
community development (“Crossroads”). ECG has custody of but not discretion over the assets
of the CRSS Account. For more information about Crossroads, the owner of the CRSS Account,
see Item 10 – Other Financial Industry Activities and Affiliations.
Sub-Advised Funds
Enhanced provides investment sub-advisory services to two private funds that are advised by third-
party investment managers (the “Sub-Advised Funds”). Enhanced does not have custody of or
discretion over the assets of the Sub-Advised Funds.
• The Impact Manager provides sub-advisory services to a third-party private fund that is the
“master fund” in a master-feeder arrangement (the “TriLinc Fund”), as detailed in Item
7.B.2 of Part 1A of Enhanced’s Form ADV. Enhanced identifies, structures, and negotiates
potential investment opportunities for the TriLinc Fund and makes investment
recommendations to its investment manager.
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• Climate Finance provides sub-advisory services to a third-party private limited partnership
(the “BR Fund”), as detailed at Item 7.B.2 of Part 1A of Enhanced’s Form ADV. Enhanced
identifies, structures, and negotiates potential investment opportunities for the BR Fund
and makes investment recommendations to its investment manager. The CRSS Account
has invested alongside the BR Fund. For more information about Crossroads, see Item 10
– Other Financial Industry Activities and Affiliations.
Ownership/Management
Enhanced Capital Holdings, Inc., a Delaware corporation that is owned 100% by Enhanced Capital
Employee Stock Ownership Trust, owns 51% of the voting securities of Enhanced Capital. Trident
ECP Holdings LLC, a limited liability company that is owned 100% by P10 Intermediate Holdings
LLC, a Delaware limited liability company (“P10 LLC”), owns 49% of the voting securities of
Enhanced Capital. P10 LLC owns 100% of ECG, 82% of which it holds directly and 18% of
which it holds through Trident ECG Holdings LLC. P10 LLC is owned by P10 Holdings, Inc., a
Delaware corporation (“P10 Holdings”), which is owned by P10, Inc., a public
company(“P10Co.”). Mr. Michael A.G. Korengold, President and Chief Executive Officer of
Enhanced and ECG, and certain other officers and employees of Enhanced are shareholders of
P10Co.
The members of the Board of Managers of Enhanced Capital are: F. Barrett Davis, an independent
director; Chris Florczak, an independent director; and William F. Souder, a Member of the Board
and Chief Operations Officer of P10Co. and a Managing Partner and co-founder of RCP Advisors,
LLC, RCP Advisors 2, LLC and RCP 3 Advisors, LLC, each an SEC-registered investment adviser
and indirect wholly-owned subsidiary of P10Co.
The members of the Board of Managers of ECG are: Mr. Korengold; Mr. Souder; and C. Clark
Webb, Co-Chief Executive Officer of P10Co. and a director of Crossroads. For more details on
the subsidiaries of P10Co. and Messrs. Souder and Webb, see Item 10 – Other Financial Industry
Activities and Affiliations.
In addition to serving on the Board of Managers of Enhanced and ECG and as the President and
Chief Executive Officer of Enhanced and ECG, Mr. Korengold serves as a member of the
investment committee of each State Investment Fund and the SBIC Fund. He also serves as a
managing member of the general partner of the SBIC Fund, Enhanced Small Business Investment
Company GP, LLC (the “SBIC GP”), and as a managing member of the SBIC Manager. Mr.
Korengold has over 20 years’ experience investing in portfolio companies and has been with
Enhanced since 2001.
The SBIC GP delegates responsibility for the management of the SBIC Fund to the SBIC Manager.
ECG owns approximately 50% of the SBIC Manager. The remaining ownership is as follows
(approximate and rounded): Mr. Korengold, 12.5%; Mr. Andrew Paul, 12.5%; and Mr. Barry
Osherow, 25%.
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As discussed in Item 10 – Other Financial Industry Activities and Affiliations, as an independent
contractor, Mr. Paul Kasper, Chief Executive Officer of Enhanced PK Services, LLC, an SEC-
registered investment adviser (“EPKS”), provides investment advisory and consulting services to
and is a supervised person of Enhanced. Mr. Kasper serves as a member of the investment
committee for the SBIC Fund, many of the State Investment Funds and the PR Account. He also
serves as a managing member of the SBIC GP and as a managing member of the SBIC Manager.
With respect to all of Enhanced’s business operations, Enhanced’s firm-wide team consists of
approximately 36 full- and part-time investment and corporate support professionals.
Enhanced’s headquarters are in New Orleans, Louisiana, with additional investment advisory
offices in New York and St. Louis. All of Enhanced’s books and records, together with its
accounting, compliance and fund administration are located in New Orleans, Louisiana.