PartnerFacts
Data last updated: Oct 23, 2026, 5:45 PM ETLatest filing: Oct 22, 2026Now: Oct 24, 2026, 6:51 AM ET

Sponsor Check › Sponsor group

A

Arc

One sponsor team, 5 deal companies · Los Angeles, CA

Grouped because: 2 shared people, 2 shared management entities, similar issuer names (4) (automatic match from the filings) · not the same sponsor?

5deal companies
$203.8Mreported sold
17investors
5Form D filings
2020–2025active
2new, last 12 mo
Follow this sponsor groupLook further ↓

Data last updated Oct 23, 2026, 5:45 PM ET · Latest filing in this group Dec 22, 2025 · Courts (RECAP) last checked: Oct 24, 2026, 2:14 AM ET · SEC enforcement last checked: covered by the index scan as of Oct 24, 2026, 2:50 AM ET

The short version

Arc is a sponsor group of 5 issuers that PartnerFacts links to one sponsor (shared people, similar issuer names, shared management entity; automatic match from the filings), filing 5 Form D filings between Nov 2020 and Dec 2025.

What this means One team, 5 deal companies, about 5 years of track record in SEC filings. We link the companies because the same people or address appear on their forms — tap "Request a correction" if that is wrong.

Combined reported sold: $203.8M to 17 investors (latest filing per issuer). Industries as reported: Pooled Investment Fund (4), REITS and Finance (1). Issuers are based in CA (5).

What this means $203.8M raised across the group, about $12M per investor. Amounts come from each company's latest Form D; they are what the sponsor reported, not audited figures.

Principal people: Neville Rhone, Jr. (5 issuers, executive officer), Quincy Allen (5 issuers, executive officer), Arc Capital Partners LLC (3 issuers, executive officer and director, entity), Arc Capital Partners I GP LLC (2 issuers, director, entity), Arc Fund II GP LLC (1 issuer, director, entity) and 2 more.

What this means The person on the most companies is usually the one running the show; their page lists every deal.

Activity: 2 new offerings in the last 12 months; latest filing Dec 22, 2025.

What this means still raising money this year.

Adviser registration (Form ADV) on record: ARC CAPITAL PARTNERS; PAG.

Public records searched: federal courts (CourtListener / RECAP), SEC enforcement releases, state securities regulators (AR, AZ, CA, CT, DE, FINRA, GA, HI, ID, LA, ME, MO, MS, MT, NASAA, NC, NH, NM, OR, RI, TX, WA), property records (NYC, FL, IL and TX counties) — none found.

What this means Nothing turned up where we looked (4 sources). That does not prove there is nothing — it means none was found in those sources on that date.

We compared 5 public filings for Arc and found 10 differences, 1 worth asking the sponsor about: Form D filed 70 days after the first sale; and more below.

What this means These are differences between the sponsor's own SEC filings — both values, dates and sources are listed in Key records, section 4. Most have ordinary explanations; ask the sponsor.

What the community is saying

Community search for Arc has not run yet — it is joining a line of 20,818 names; searches run around the clock at the hosts' allowed rate. Searched so far: 314 names.

Community comments are quoted as written by their authors. Sources searched: BiggerPockets forums (via DuckDuckGo, Brave, Bing and BiggerPockets search) and Reddit (search feed + public archive).

Key records

Five things investors ask first. Items still in human review are counted, not shown.

1. Lawsuits

None found so far — 5 of 5 issuers searched (federal courts (CourtListener / RECAP), last checked Oct 24, 2026)

What was searched

Sources searched: CourtListener bulk data (RECAP dockets as of 2026-09-30; recall-first rule 10-24) — federal district + bankruptcy courts State courts: not covered (one-tap state court links under Look further). PACER: not searched.. Searched so far: 5 of 5 issuers in this group; 0 still to be searched. Results are added automatically.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

2. Regulatory actions

None found in sources searched — SEC enforcement releases (index scan as of Oct 24, 2026, 2:50 AM ET) · state securities regulators: NV (crawled Oct 23, 2026)

What was searched

SEC enforcement searched: SEC litigation releases and administrative proceedings — respondent names in the sec.gov index titles (30,205 releases, 1995-09-19 to 2026-10-23); release text is read only to confirm a candidate. Names that appear only in the body of a release are not found. — Searched SEC litigation releases and administrative proceedings (1995→ / 2007→) (30,205 records as of Oct 24, 2026, 2:50 AM ET) — nothing matched Arc..

State securities regulators: Securities regulators searched (3,318 actions): AZ Corporation Commission Securities Division (411 actions, 2017–2026), CA DFPI (25 actions, 2007–2024; listing starts 2002), DE DOJ Investor Protection Unit (257 actions, 1987–2026), TX State Securities Board (586 actions, 2006–2026), WA DFI (2,039 actions, 2001–2026) — 16 of 12,159 DFPI respondent pages read so far; sponsor-name matches are read first — last crawled Oct 23, 2026, 9:57 PM ET. No machine-readable public listing today for IA, IN, KS, MI, NE, NV (see docs/state-regulators.md).

3. Bankruptcies

None found so far — 5 of 5 issuers searched (federal bankruptcy courts (CourtListener / RECAP), last checked Oct 24, 2026)

What was searched

Sources searched: Federal bankruptcy courts via CourtListener / RECAP archive (federal district courts, federal bankruptcy courts). State courts: not covered (one-tap state court links under Look further). PACER: not searched (RECAP only).. Searched so far: 5 of 5 issuers in this group; 0 still to be searched. Results are added automatically.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

4. Differences between public sources

No comparisons published

What is compared

No public statement by this sponsor group has been collected yet, so there is nothing to compare. Sources compared: the sponsor's own website (known from the issuer's own filings — Form C issuer website, EDGAR company profile — an approved profile claim or Form ADV Item 1.I of its matched adviser) · SEC Form D · SEC Form ADV (IAPD) · Internet Archive · No website is on file for this sponsor group yet.

10 differences found between the filings for Arc — 1 worth asking about (compared 5 filings on Oct 24, 2026)

Note · Nov 12, 2020

12% of the money raised went to insiders — ARC GP PARTNERS LLC

The Nov 12, 2020 Form D reports $20,000,000 sold and $2,375,000 of the proceeds used for payments to officers, directors or promoters (marked as an estimate). Issuer's note: "Investment Management 1.75% of each Member?s Initial Capital Commitment per annum Transaction-Related Fees 1% of purchase price, sale price, loan amount respectively Property related fees cannot be es".

What this means The filing reports how much of the money raised was paid to insiders. Over 10% is high for most deals. Ask what it paid for.

Form D · Nov 12, 2020 ↗ARC GP PARTNERS LLC — PartnerFacts page ↗
Sources
Note · Nov 12, 2020 – May 26, 2023

Arc includes 2 deals that stopped filing before reaching their target

Arc Capital Partners Fund I LP (last filing May 26, 2023; $114,837,400 sold of $300,000,000); ARC GP PARTNERS LLC (last filing Nov 12, 2020; $20,000,000 sold of $50,000,000). Each has no filing in more than two years and reported under half its target sold.

What this means An issuer whose last filing is more than two years old and reported under half its target sold. The raise may have closed early or quietly stopped. Ask what happened to each.

Arc Capital Partners Fund I LP — PartnerFacts page ↗ARC GP PARTNERS LLC — PartnerFacts page ↗
Sources
Note · Nov 24, 2025 – Dec 22, 2025

11 other issuers file from the same address — 2 member issuers (Arc Capital Partners Fund II LP; Arc GP Partners II LLC)

The address on file, 445 S Figueroa Street, Suite 2160, Los Angeles, CA, is used by 13 issuers in our index across 4 sponsor groups; 11 are outside this group. It is on our registered-agent / shared-office list (13 issuers in 8 unrelated clusters).

What this means Many unrelated companies file from this address. Often a registered agent or a fund administrator; sometimes a shared office. Ask where the team actually works.

Arc Capital Partners Fund II LP — PartnerFacts page ↗Arc GP Partners II LLC — PartnerFacts page ↗EDGAR filer page · Arc Capital Partners Fund II LP ↗
Sources
Worth asking · Sep 15, 2025 – Nov 24, 2025

Form D filed 70 days after the first sale — Arc Capital Partners Fund II LP

The filing says the first sale was Sep 15, 2025. The Form D was filed Nov 24, 2025 — 70 days later. The rule: a Form D is generally due within 15 days after the first sale, so this one is 55 days past that.

What this means A late notice is common and carries no penalty by itself. It is worth asking the sponsor why the paperwork lagged.

Form D · Nov 24, 2025 ↗Arc Capital Partners Fund II LP — PartnerFacts page ↗
Sources
Note · Nov 20, 2025 – Dec 22, 2025

Form D filed 32 days after the first sale — Arc GP Partners II LLC

The filing says the first sale was Nov 20, 2025. The Form D was filed Dec 22, 2025 — 32 days later. The rule: a Form D is generally due within 15 days after the first sale, so this one is 17 days past that.

What this means A late notice is common and carries no penalty by itself. It is worth asking the sponsor why the paperwork lagged.

Form D · Dec 22, 2025 ↗Arc GP Partners II LLC — PartnerFacts page ↗
Sources
Note · Dec 5, 2023 – Dec 20, 2023

No amendment in the last 12 months on an offering that may still be open — Arc Capital Partners Fund I Sidecar LP (latest filing Dec 20, 2023)

The latest filing for this offering is dated Dec 20, 2023 (first sale Dec 5, 2023). It reports $20,000,000 sold of an indefinite amount offered. No later amendment is in our index as of Oct 24, 2026.

What this means SEC rules expect a yearly amendment while an offering is still going. The raise may simply have ended — a Form D does not say when it closed. Ask the sponsor whether the offering closed, when, and at what amount.

Form D · Dec 20, 2023 ↗Arc Capital Partners Fund I Sidecar LP — PartnerFacts page ↗
Sources
Note · May 17, 2023 – May 26, 2023

No amendment in the last 12 months on an offering that may still be open — Arc Capital Partners Fund I LP (latest filing May 26, 2023)

The latest filing for this offering is dated May 26, 2023 (first sale May 17, 2023). It reports $114,837,400 sold of $300,000,000 offered. No later amendment is in our index as of Oct 24, 2026.

What this means SEC rules expect a yearly amendment while an offering is still going. The raise may simply have ended — a Form D does not say when it closed. Ask the sponsor whether the offering closed, when, and at what amount.

Form D · May 26, 2023 ↗Arc Capital Partners Fund I LP — PartnerFacts page ↗
Sources
Note · Oct 30, 2020 – Nov 12, 2020

No amendment in the last 12 months on an offering that may still be open — ARC GP PARTNERS LLC (latest filing Nov 12, 2020)

The latest filing for this offering is dated Nov 12, 2020 (first sale Oct 30, 2020). It reports $20,000,000 sold of $50,000,000 offered. No later amendment is in our index as of Oct 24, 2026.

What this means SEC rules expect a yearly amendment while an offering is still going. The raise may simply have ended — a Form D does not say when it closed. Ask the sponsor whether the offering closed, when, and at what amount.

Form D · Nov 12, 2020 ↗ARC GP PARTNERS LLC — PartnerFacts page ↗
Sources
Note · Nov 12, 2020 – Dec 22, 2025

5 issuers use a registered-agent or shared-office address

Address on file is a registered agent / shared office — Arc GP Partners II LLC · Address on file is a registered agent / shared office — Arc Capital Partners Fund II LP · Address on file is a registered agent / shared office — Arc Capital Partners Fund I Sidecar LP · Address on file is a registered agent / shared office — Arc Capital Partners Fund I LP · Address on file is a registered agent / shared office — ARC GP PARTNERS LLC

What this means A registered agent's address is a mailbox, not where the team works. Ask where the business operates.

Form D · Dec 22, 2025 ↗Arc GP Partners II LLC — PartnerFacts page ↗Form D · Nov 24, 2025 ↗Arc Capital Partners Fund II LP — PartnerFacts page ↗
Sources
Note · May 26, 2023

Issuer used a different name before — Arc Capital Partners Fund I LP

SEC records list prior names for this filer: Arc Urban Investors LP. The current name on file is "Arc Capital Partners Fund I LP".

What this means A name change is normal, but your documents may show the old name. Match the CIK, not just the name.

EDGAR filer page ↗Arc Capital Partners Fund I LP — PartnerFacts page ↗
Sources
What is compared

What is compared: every Form D and D/A we hold for this subject, side by side — filing dates vs. first-sale dates (the 15-day rule), amendment timing on open offerings (the yearly-amendment expectation), amounts sold, investor counts, offering amounts and minimums across amendments, industry and size bands, addresses, how each person's name and role is written, paid sellers' CRD numbers, and (for groups) where the member companies were formed and sit. Everything is as filed by the issuer; the SEC does not check it. Differences are common and usually have ordinary explanations — we show both values, the dates, and the source so you can ask. As of Oct 24, 2026.

5. Money to insiders

0 of 5 offerings report sales commissions; 0 report finder's fees; 1 reports proceeds to related persons totalling $2,375,000. (includes amounts the issuer reported as estimates)

Offering (latest filing)Sales commissionsFinder's feesTo insidersPaid to sell itSource
Dec 22, 2025 D
Arc GP Partners II LLC
File 021-567787
$0$0$0None listed on this filingEDGAR ↗
Nov 24, 2025 D
Arc Capital Partners Fund II LP
File 021-564894
$0$0$0None listed on this filingEDGAR ↗
Dec 20, 2023 D
Arc Capital Partners Fund I Sidecar LP
File 021-500340
$0$0$0None listed on this filingEDGAR ↗
May 26, 2023 D
Arc Capital Partners Fund I LP
File 021-482797
$0$0$0None listed on this filingEDGAR ↗
Nov 12, 2020 D
ARC GP PARTNERS LLC
File 021-380406
$0$0$2,375,000 (est.)
Investment Management 1.75% of each Member?s Initial Capital Commitment per annum Transaction-Related Fees 1% of purchase price, sale price, loan amount respectively Property related fees cannot be estimated yet
None listed on this filingEDGAR ↗
How this is counted

Counts come from Form D Items 12–15 on the filings in our index (latest filing per offering; one offering = one SEC file number; an amendment updates its offering rather than adding one). "To insiders" = gross proceeds used for payments to executive officers, directors or promoters. "—" = not reported on that filing. Amounts marked (est.) were reported as estimates. "Paid to sell it" = sales compensation recipients named on that filing (Item 12), each linked to FINRA BrokerCheck when a CRD number is reported.

Counted across all 5 issuers in this group — every filing in our index, latest filing per offering (SEC file number).

Property records 0 documents · 0 ownership records · last checked Oct 24, 2026, 6:47 AM ET · NYC and Cook County lookup still to run

0 recorded documents and 0 ownership records matched to Arc in the sources searched.

Not found in sources searched as of Oct 24, 2026, 6:47 AM ET: Hillsborough County FL Clerk of Court Official Records daily index (publicrec.hillsclerk.com D/P/M files), 2 daily files (Oct 14, 2026 to Oct 15, 2026) — loaded Oct 23, 2026, 8:59 PM ET; Harris County TX (HCAD ownership rolls 2024–2026) — 410,909 records, loaded Oct 24, 2026, 6:47 AM ET; Dallas County TX (DCAD ownership roll 2026) — 173,688 records, loaded Oct 23, 2026, 8:58 PM ET; Hillsborough County FL (FL DOR 2026 ownership roll + Clerk recorded-document index Oct 14, 2026 to Oct 15, 2026), Miami-Dade County FL (FL DOR 2026 ownership roll) — 294,950 records, loaded Oct 23, 2026, 8:58 PM ET. Still to be looked up for this group: NYC ACRIS via NYC Open Data (Real Property Parties 636b-3b5g, Master bnx9-e6tj, Legals 8h5j-fqxa, Document Control Codes 7isb-wh4c) · NYC PLUTO ownership via NYC Open Data (64uk-42ks) · Cook County IL Assessor via Cook County Open Data (Parcel Sales wvhk-k5uv; Parcel Addresses 3723-97qp). Records in other counties, and recorder indexes we do not yet cover, were not searched.

Property records coverage: New York City (ACRIS recorded documents and PLUTO ownership, looked up per issuer when its page is viewed; re-checked when the page is viewed again more than 30 days after the last check); Harris County TX (ownership only, no deed, mortgage or sale records; HCAD ownership rolls 2024–2026); Dallas County TX (ownership only, no deed, mortgage or sale records; DCAD ownership roll 2026); Hillsborough County FL (FL DOR 2026 ownership roll + Clerk recorded-document index Oct 14, 2026 to Oct 15, 2026), Miami-Dade County FL (FL DOR 2026 ownership roll); Cook County IL (assessor ownership and deed/sale records, looked up per issuer when its page is viewed). Recorder indexes (party names on deeds, mortgages and liens) in TX, AZ, NV, CA and WA counties and outside the Clerk index in FL, mortgages and liens outside NYC and Hillsborough County, lis pendens and foreclosure notices everywhere, Los Angeles County CA, Clark County NV, King County WA (loader ready; first load not finished), Cook County IL bulk pass (not finished; per-issuer lookups only so far), New York City bulk pass (not finished; per-issuer lookups only so far), Maricopa County AZ (loader ready; commercial-purpose statement not yet filed), Salt Lake County UT, and all other counties are not covered — not searched. Last refresh by source: Harris County Appraisal District real_acct.txt Oct 24, 2026, 6:47 AM ET; Hillsborough County FL Clerk daily index Oct 23, 2026, 8:59 PM ET; Dallas Central Appraisal District ACCOUNT_INFO.CSV Oct 23, 2026, 8:58 PM ET; Florida DOR NAL roll (Dade 23) Oct 23, 2026, 8:58 PM ET; Florida DOR NAL roll (Hillsborough 39) Oct 23, 2026, 8:54 PM ET. NYC and Cook County are also looked up per issuer when its page is viewed; the most recent such lookup on this site finished Oct 24, 2026, 3:30 AM ET. Parties are named as the recorder's index names them (role suffixes as recorded); no address, account number or trust date is shown for an individual, and individual owners of record (home ownership) are not matched or shown. Items still in human review are not shown.

Issuers in this group

Why each issuer is here is stated in the "Linked by" column. Low-confidence links are never shown — they wait for human review.

SourceIssuerLinked byLocationIndustryFilingsSold (max)InvestorsMin. investment (latest filing)Active
EDGAR ↗AG ARC GP PARTNERS LLCshared people, similar issuer namesLOS ANGELES, CAREITS and Finance1$20,000,000
offering $50,000,000 · similar: $125,000–$125,000
2
similar: 124–125
$1,000,000
similar: $1,000–$1,000
2020–2020
EDGAR ↗AC Arc Capital Partners Fund I LPshared people, shared management entity, similar issuer namesLOS ANGELES, CAPooled Investment Fund1$114,837,400
offering $300,000,000 · similar: $155,000–$5,250,000
10
similar: 4–27
$10,000,000
similar: $1,000–$100,000
2023–2023
EDGAR ↗AC Arc Capital Partners Fund I Sidecar LPshared people, shared management entityLOS ANGELES, CAPooled Investment Fund1$20,000,000
offering Indefinite · similar: $155,000–$5,250,000
1
similar: 4–27
$10,000,000
similar: $1,000–$100,000
2023–2023
EDGAR ↗AC Arc Capital Partners Fund II LPshared people, shared management entity, similar issuer namesLOS ANGELES, CAPooled Investment Fund1$40,000,000
offering $40,000,000 · similar: $155,000–$5,250,000
2
similar: 4–27
$10,000,000
similar: $1,000–$100,000
2025–2025
EDGAR ↗AG Arc GP Partners II LLCshared people, similar issuer namesLOS ANGELES, CAPooled Investment Fund1$9,000,000
offering $9,000,000 · similar: $155,000–$5,250,000
2
similar: 4–27
$4,500,000
similar: $1,000–$100,000
2025–2025

"Similar" = offerings in the same industry claiming the same exemption, filed in the last 5 years: REITS and Finance / 506(b) (3,490 filings); Pooled Investment Fund / 506(b) (83,801 filings); ranges are the middle half (25th–75th percentile). Computed by PartnerFacts from SEC EDGAR Form D data as of Oct 23, 2026, 5:45 PM ET. Rows without a range: fewer than 30 comparable filings, or not a Rule 506 offering. No ranking or score.

Timeline of offerings

SourceFiledIssuerFormIndustryOfferedSold
EDGAR ↗Dec 22, 2025Arc GP Partners II LLCDPooled Investment Fund$9,000,000$9,000,000
EDGAR ↗Nov 24, 2025Arc Capital Partners Fund II LPDPooled Investment Fund$40,000,000$40,000,000
EDGAR ↗Dec 20, 2023Arc Capital Partners Fund I Sidecar LPDPooled Investment FundIndefinite$20,000,000
EDGAR ↗May 26, 2023Arc Capital Partners Fund I LPDPooled Investment Fund$300,000,000$114,837,400
EDGAR ↗Nov 12, 2020ARC GP PARTNERS LLCDREITS and Finance$50,000,000$20,000,000

Activity: 2 new offerings in the last 12 months across all issuers in this group (new offering = a Form D that is not an amendment, D/A) · most recent filing Dec 22, 2025. Industry history, as reported on each offering's latest filing: Previous offerings: REITS and Finance (2020). Latest offering: Pooled Investment Fund (2023–2025; most recent Dec 22, 2025).

People across the group

NameRolesIssuers hereFirst → last listed
QA Quincy AllenExecutive Officer5Nov 12, 2020 → Dec 22, 2025
NR Neville Rhone, Jr.Executive Officer5Nov 12, 2020 → Dec 22, 2025
AC Arc Capital Partners LLC entityDirector, Executive Officer3May 26, 2023 → Nov 24, 2025
AC Arc Capital Partners I GP LLC entityDirector2May 26, 2023 → Dec 20, 2023
AG Arc GP Manager II LLC entityDirector1Dec 22, 2025 → Dec 22, 2025
AF Arc Fund II GP LLC entityDirector1Nov 24, 2025 → Nov 24, 2025
AG Arc GP Manager LLC entityDirector1Nov 12, 2020 → Nov 12, 2020

Adviser registration (Form ADV)

ARC CAPITAL PARTNERS — SEC-registered investment adviser · SEC registration status as reported: “Approved” since Sep 2, 2026 · SEC file 801-137212 · Main office: LOS ANGELES, CA · IAPD record ↗ · Form ADV filing (PDF) ↗

Regulatory assets under management: $862,491,641 as reported on Form ADV filed Sep 1, 2026 (Item 5.F(2)(c)) · 11 accounts (Item 5.F(2)(f))

Websites listed on Form ADV (Item 1.I): arccapitalpartners.com ↗

Item 11 disclosure questions as answered on Form ADV filed Sep 1, 2026: 0 of 24 answered “Yes”
  • No — Form ADV Item 11 asks: “Do any of the events below involve you or any of your supervised persons?”
  • No — Form ADV Item 11A(1) asks: “A. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?”
  • No — Form ADV Item 11A(2) asks: “A. (2) been charged with any felony?”
  • No — Form ADV Item 11B(1) asks: “B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?”
  • No — Form ADV Item 11B(2) asks: “B. (2) been charged with a misdemeanor listed in Item 11.B(1)?”
  • No — Form ADV Item 11C(1) asks: “C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11C(2) asks: “C. (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?”
  • No — Form ADV Item 11C(3) asks: “C. (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11C(4) asks: “C. (4) entered an order against you or any advisory affiliate in connection with investment-related activity?”
  • No — Form ADV Item 11C(5) asks: “C. (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?”
  • No — Form ADV Item 11D(1) asks: “D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?”
  • No — Form ADV Item 11D(2) asks: “D. (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?”
  • No — Form ADV Item 11D(3) asks: “D. (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11D(4) asks: “D. (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?”
  • No — Form ADV Item 11D(5) asks: “D. (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?”
  • No — Form ADV Item 11E(1) asks: “E. Has any self-regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11E(2) asks: “E. (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?”
  • No — Form ADV Item 11E(3) asks: “E. (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11E(4) asks: “E. (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?”
  • No — Form ADV Item 11F asks: “F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?”
  • No — Form ADV Item 11G asks: “G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?”
  • No — Form ADV Item 11H(1)(a) asks: “H. (1) Has any domestic or foreign court: (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?”
  • No — Form ADV Item 11H(1)(b) asks: “H. (1)(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?”
  • No — Form ADV Item 11H(1)(c) asks: “H. (1)(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?”
  • No — Form ADV Item 11H(2) asks: “H. (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1)?”

Answers as filed by the adviser on Form ADV Part 1A, Item 11; question text quoted from the form. Details of each “Yes” are in the Disclosure Reporting Pages of the Form ADV (PDF) ↗.

Matched on management entity listed on Form D = adviser name, business address on Form ADV = address on Form D · Form ADV data: SEC Investment Adviser Information Report (SEC-registered advisers), file dated 2026-10-02, loaded Oct 23, 2026, 8:39 PM ET · IAPD record last checked Oct 23, 2026, 8:36 PM ET

PAG — Exempt reporting adviser · SEC registration status as reported: “ERA - Active” since Mar 29, 2012 · SEC file 802-75212 · Main office: GRAND CAYMAN · IAPD record ↗ · Form ADV filing (PDF) ↗

Regulatory assets under management: Not reported — exempt reporting advisers do not complete Form ADV Item 5.

Websites listed on Form ADV (Item 1.I): WWW.PAG.COM ↗

Item 11 disclosure questions as answered on Form ADV filed Mar 31, 2026: 4 of 24 answered “Yes”
  • Yes — Form ADV Item 11 asks: “Do any of the events below involve you or any of your supervised persons?”
  • Yes — Form ADV Item 11D(2) asks: “D. (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?”
  • Yes — Form ADV Item 11D(4) asks: “D. (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?”
  • Yes (1 disclosure reported) — Form ADV Item 11D(5) asks: “D. (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?”
  • Yes (1 disclosure reported) — Form ADV Item 11E(4) asks: “E. (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?”
  • No — Form ADV Item 11A(1) asks: “A. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?”
  • No — Form ADV Item 11A(2) asks: “A. (2) been charged with any felony?”
  • No — Form ADV Item 11B(1) asks: “B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?”
  • No — Form ADV Item 11B(2) asks: “B. (2) been charged with a misdemeanor listed in Item 11.B(1)?”
  • No — Form ADV Item 11C(1) asks: “C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11C(2) asks: “C. (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?”
  • No — Form ADV Item 11C(3) asks: “C. (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11C(4) asks: “C. (4) entered an order against you or any advisory affiliate in connection with investment-related activity?”
  • No — Form ADV Item 11C(5) asks: “C. (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?”
  • No — Form ADV Item 11D(1) asks: “D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?”
  • No — Form ADV Item 11D(3) asks: “D. (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11E(1) asks: “E. Has any self-regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11E(2) asks: “E. (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?”
  • No — Form ADV Item 11E(3) asks: “E. (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11F asks: “F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?”
  • No — Form ADV Item 11G asks: “G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?”
  • No — Form ADV Item 11H(1)(a) asks: “H. (1) Has any domestic or foreign court: (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?”
  • No — Form ADV Item 11H(1)(b) asks: “H. (1)(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?”
  • No — Form ADV Item 11H(1)(c) asks: “H. (1)(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?”
  • No — Form ADV Item 11H(2) asks: “H. (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1)?”

Answers as filed by the adviser on Form ADV Part 1A, Item 11; question text quoted from the form. Details of each “Yes” are in the Disclosure Reporting Pages of the Form ADV (PDF) ↗.

Matched on management entity listed on Form D = adviser other name, no state to compare · Form ADV data: SEC Investment Adviser Information Report (exempt reporting advisers), file dated 2026-10-02, loaded Oct 23, 2026, 8:39 PM ET · IAPD record last checked Oct 23, 2026, 10:52 PM ET

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