Blueberry Hill Insurance Fund: Fund Rating and Research File

In brief

Blueberry Hill Insurance Fund at a glance

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 2 beneficial owners and none 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 SALI Multi-Series Fund, L.P., a platform run by SALI Fund Management, LLC (SALI Fund Services), whose Form ADV of 25 August 2026 reports the series' controls; M Holdings Securities, Inc. 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 LLC is the administrator. The figure does not show how prices were set or checked, which is a question for the insurer.

M Holdings Securities, Inc. reports 2 regulatory actions in Item 11 of its Form ADV between 2018 and 2025, all concerning the adviser itself, with reported sanctions of about USD 325,000. The filing also reports 1 matter concerning an individual, which is weighed in the rating but not published. The full record is set out below.

The rating

Why Blueberry Hill Insurance Fund has two stars

The accounts are audited every year by Grant Thornton and sent to investors. What holds it back is that Essential Fund Services, the administrator, belongs to the same group as the SALI platform, and SALI reports that none of the assets were valued by a person outside that group last year. M Holdings Securities reports 2 regulatory matters of its own since 2018, the most recent brought by the SEC in 2025. Its Form ADV also lists one matter of another company in its group or of an individual, which counts for less.

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.

Conduct and regulatory record

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.

Reported controls

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.

Depth and experience of the manager

The assets the manager runs, its investment staff and how long it has been registered with the SEC.

Fund scale and investor base

The fund's gross assets, the number of its owners and how long it has been offered.

Reporting and filings

Whether the fund and its adviser keep their SEC filings current and consistent with each other.

Fit for a life insurance policy

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.

PPLI.comFund Rating

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.

The fund at a glance

Identity, offering and service providers

Identity

Legal nameBlueberry Hill Insurance Fund Series Interests of the SALI Multi-Series Fund, L.P.

OrganisedDelaware limited partnership, 2023

SEC CIK0002047919 EDGAR

Private fund ID805-8935359821 ADV

Investment managerM Holdings Securities, Inc. IAPD

PlatformSALI Multi-Series Fund, L.P. IAPD

Offering, as filed on Form D

ExemptionsRule 506(b); Investment Company Act s. 3(c)(7)

First sale1 February 2023

Minimum investmentUSD 500,000

Amount soldUSD 45.0 million to date

Investors in the offering2

Sales commissionsNone reported

Latest filingForm D/A, 8 September 2026 Source

Size and ownership, as filed on Form ADV

Gross asset valueUSD 41,414,872 (ADV filed 25 August 2026)

Beneficial ownersAbout 2

Owned by non-US persons0%

Service providers

AuditorGrant Thornton LLP

CustodianCharles Schwab; Frost Bank

AdministratorEssential Fund Services LLC

Prime brokerNone reported

Valued by a person not related to the adviser0% of assets, last fiscal year

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.

Inside a policy

What to check before this fund goes into a policy

Why the wrapper matters here

A diversified portfolio mixes income and gains, and a direct holder pays tax on both every year. Inside a policy that meets the tax rules neither is taxed as it arrives, and the insurer can move the account between funds on its menu without a taxable event for the policyholder.

Liquidity

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.

Who chooses the investments

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.

Diversification

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.

Valuation

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.

Fees

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 adviser's record

Regulatory and legal record of M Holdings Securities, Inc.

The full list for the firm is in the manager file.

What the adviser itself discloses in Item 11 of its Form ADV, summarised from the disclosure pages, with a link to the filing. Item 11 is filed for the adviser as a whole, so under each matter the fund it concerns is read from the disclosure itself.

202525 November 2025

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

The Securities and Exchange Commission ("SEC") found that m Holdings Securities, Inc. ("M Holdings") failed to (1) adopt written policies and procedures reasonably designed to protect customer records and information, in violation of Rule 30(a) of Regulation sp (17 c.f.r. § 248.30(a)); and (2) develop and implement a written identity theft prevention program that is designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or any existing covered account, in violation of Rule 201 of Regulation sid (17 c.f.r. § 248.201).

US Securities and Exchange Commission · Order 25 November 2025 · USD 325,000 · Concerns the adviser itself · Form ADV, Item 11 disclosure

201811 June 2018

Regulatory action by US Securities and Exchange Commission: cease and desist

Fund concerned: a public mutual fund. None of the insurance-dedicated funds in this file is named.

On March 11, 2019, the Securities and Exchange Commission (SEC) published ia release no. 5193, an order instituting administrative and cease and desist proceedings, pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940 (Advisers Act), against m Holdings Securities, Inc. (respondent). Respondent self-reported the violations to the SEC. The proceedings arise out of breaches of fiduciary duty and inadequate disclosures by respondent in connection with its mutual Fund share class selection practices and the 12b- 1 fees it AND/OR its associated persons received. At times during the relevant period, respondent purchased for, recommended to, or held for advisory clients ...

US Securities and Exchange Commission · Order 11 March 2019 · No monetary sanction reported · Concerns the adviser itself · Form ADV, Item 11 disclosure

The filing also reports 1 matter that concerns an individual; such matters are weighed in the rating by the person's role and are not published here. These are the matters M Holdings Securities, Inc. reports in Item 11 of its Form ADV, filed 27 October 2026. A reported matter is a fact disclosed by the adviser, not a finding by PPLI.com about this fund. None of them concerns the fund's investments.

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.

Reader rating

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Blueberry Hill Insurance Fund