A series of a SALI platform fund, an insurance-dedicated platform, managed by Altes Capital, LLC. This file sets out what the fund and its adviser have filed with the SEC.
The fund relies on Section 3(c)(7) of the Investment Company Act and Rule 506(b), so its interests go only to qualified purchasers in a private offering. The adviser reports about 4 beneficial owners, 100% of them outside the United States. As an insurance-dedicated fund it is held through insurance company separate accounts, alongside the few other holders the Treasury rules allow, and a family reaches it through a policy whose insurer offers it.
It is a series of a SALI platform fund, a platform run by SALI Fund Management, LLC (SALI Fund Services), whose Form ADV of 25 August 2026 reports the series' controls; Altes Capital, LLC manages the investments.
One point to raise with the insurer: the filing reports that 0% of the fund's assets were valued in the last fiscal year by a person that is not related to the adviser. Essential Fund Services is the administrator. The figure does not show how prices were set or checked, which is a question for the insurer.
Altes Capital, LLC reports no disciplinary matters in Item 11 of its Form ADV: no regulatory actions, criminal matters or civil proceedings against the adviser, its advisory affiliates or its management persons.
Altes reports no regulatory or legal matters in its Form ADV. The accounts are audited every year by BDO and sent to investors. As SALI reports it, administration and valuation stay inside its group: Essential Fund Services, a related company, administers the series, and none of the assets were valued by an outside party last year. Altes is a small manager, with USD 3.2 billion of regulatory assets and an SEC registration only since 2024.
The rating looks only at the areas below, which matter to a family holding the fund through a private placement policy. Past returns play no part: these funds do not report them in their SEC filings, and they say little about what a policy will earn.
What regulators and courts have recorded against the manager, and for platform series against the platform, as the advisers report it to the SEC. Several proceedings on one set of facts count as one matter. Recent and serious matters count most, matters of other companies in the group count for less, matters of individuals are weighed by the person's role and their bearing on the business, and the size of the firm is taken into account.
What the adviser reports to the SEC for the fund: whether the accounts are audited every year by an accountant registered with the PCAOB and subject to its regular inspection, whether audited statements go to investors and what the audit opinion says, whether the administrator and custodian are outside the adviser's group, and what share of the assets was valued last year by a person not related to the adviser.
The assets the manager runs, its investment staff and how long it has been registered with the SEC.
The fund's gross assets, the number of its owners and how long it has been offered.
Whether the fund and its adviser keep their SEC filings current and consistent with each other.
Whether the fund is insurance-dedicated, so that a policy can hold it, and the minimum it asks. Liquidity terms join this element as they are documented.
Investor experience. What policyholders, insurers and advisers tell us is shown separately and never changes the stars. A factual point they raise is checked against the filings, and if it holds, the data is corrected. We never publish names. Tell us about yours
The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the fund or its manager, not a credit rating, not a forecast of returns and not investment advice. Read about the rating.
Figures are shown as filed, with their dates. Form D counts investors in the offering and Form ADV counts beneficial owners, so the two numbers need not match. Gross asset value counts total assets without deducting borrowings or other liabilities, so it is not a net asset value. The minimum on Form D can be nominal; the amount a family actually needs is set by the insurer and the policy.
Income and gains that a direct holder pays tax on every year are not taxed as they arrive inside a policy that meets the tax rules. The size of the benefit depends on how much of the fund's return would otherwise be taxed each year.
The fund's redemption terms are not in its public filings. Read them in the offering documents and set them against the way the policy will need cash: loans, withdrawals and the insurer's own rules for moving between funds.
The policyholder can choose this fund from the insurer's menu but cannot direct what the fund buys. That line comes from the investor control rules, and it is the reason the fund exists in a separate insurance-only form.
A policy's separate account must meet the diversification test of section 817(h). Because the fund is reached only through insurance policies, the test can look through to its assets if the fund meets the conditions of the Treasury rules; whether a given account passes is a question for the insurer, not something these filings show.
SALI reports that none of the fund's assets were valued last year by a person outside its group. Ask the insurer how it checks the price at which the account buys, sells and reports this fund.
Management and performance fees are set in the offering documents and are not shown in these filings. They come on top of the policy's own charges.
This is research, not an offer of the fund or advice to buy it. Interests in the fund are available only through an insurance company, and only to investors who qualify.
The full list for the firm is in the manager file.
Altes Capital, LLC reports no disciplinary matters in Item 11 of its Form ADV filed 5 March 2026: no regulatory actions, criminal matters or civil proceedings against the adviser, its advisory affiliates or its management persons.
The series runs on the SALI platform. SALI Fund Management's own Form ADV reports no disciplinary matters in Item 11, and the platform's record carries a 30% share of the conduct element for every series it runs.
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Prepared by PPLI.com Fund Intelligence from the public filings listed, checked on 4 November 2026. The rating makes no judgment of the fund's returns. Facts and ratings are updated every quarter, or sooner when a new filing appears.
If a fact here is wrong or out of date, write to [email protected] with the filing that shows it. We correct what we can verify and record the date of the change.
Important. Educational research only. Nothing here is an offer, a solicitation or a recommendation to invest in any fund or to buy any policy. Interests in insurance-dedicated funds are available to the public only through insurance policies. Tax results depend on a policy meeting the tax rules and on each family's circumstances; take advice in the countries concerned.
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