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About the rating

How PPLI.com rates insurance-dedicated funds

PPLI.com rates the reported controls, disclosures and standing of insurance-dedicated funds and their managers from public filings, under the method set out below. Each fund gets one rating, from one to five stars. The rating does not measure returns and does not guarantee that capital is preserved or that a fund suits a particular policy. Each fund page shows its sources, the dates of the data and what has not been checked.

What is considered

The bases of the rating

We consider only what matters to a family putting a fund inside a policy. PPLI.com decides how much each area weighs.

Conduct and regulatory record

Regulatory actions, criminal matters and civil cases that the manager reports in Item 11 of its Form ADV, and for platform series those of the platform, considered by their seriousness, how recent they are and the size of the firm. Several proceedings that arise from one set of facts, for example three regulators acting on the same transactions, count as one matter. Item 11 also covers advisory affiliates: matters of other companies in the group count for less, and a matter that concerns an individual is weighed by the person's role, whether they are still with the firm, how serious it is and whether it bears on the advisory business. Cases dismissed without payment count for little. Sources: Form ADV and its disclosure pages on the SEC's adviser database.

Reported controls

The controls an adviser reports for each private fund in Schedule D of Form ADV: an annual audit by an accountant registered with the PCAOB and subject to its regular inspection, audited statements sent to investors, the audit opinion, an administrator outside the group that sends statements to investors, a custodian outside the group, and the share of assets valued in the last fiscal year by a person not related to the adviser. These are the answers the adviser files; they are not a guarantee that the assets are safe or correctly priced.

Depth and experience of the manager

Regulatory assets under management, investment staff and the years the manager has been registered with the SEC, from Form ADV and the SEC's monthly adviser files. Exempt reporting advisers do not report these figures, so their funds wait until the information is documented.

Fund scale and investor base

Gross asset value and number of owners as reported in Form ADV, and how long the fund has been offered according to its Form D.

Reporting and filings

Whether the adviser's annual Form ADV and the fund's Form D are current, and whether the two filings point to each other.

Fit for a life insurance policy

Whether the fund is an insurance-dedicated fund: one the public can reach only through an insurance policy, held by insurance company separate accounts and the few other holders the Treasury diversification rules allow, such as the insurer's general account or the manager in connection with setting up the fund, so that a policy can hold it, and the minimum it asks. A fund named as insurance-dedicated is rated only once its offering documents or filings confirm it. Redemption terms are added as they are documented from offering documents and from managers.

The stars

What each rating means

The strongest files in our database. A clean or nearly clean record, every control we look for in place and run by firms outside the manager's group, and an established manager of real size.

Strong on most counts, with one point a family should raise with the insurer, often how the assets are valued or who administers the fund.

Sound, with several points to check: valuation or administration inside the group, a manager with a longer regulatory record, or a fund that is still small.

A material gap, such as administration and pricing kept in-house, a heavy regulatory record or a very small and new fund.

A basic safeguard is missing, for example an annual audit of the accounts.

Principles

Rules that apply to every fund

Nature of the ratingThe rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about any fund or manager, not a credit rating, not a forecast of returns and not investment advice.
ReturnsPast returns play no part. Insurance-dedicated funds do not report them in their SEC filings, managers report them on different bases, and the return a family earns depends on the policy as much as on the fund.
One rating per fundEach fund gets one rating, from one to five stars. A manager file carries its own Manager Rating, built from the manager's record and depth and from the controls of its rated funds.
Fixed standardsStars are set against fixed standards, not against other funds, and a fund that falls short of a standard by any margin stays below it: the standards are applied to exact figures, and nothing is rounded before the stars are set. A fund keeps its stars when others improve, and five stars require both a clean or nearly clean record and a full set of independent controls.
Platform seriesFor a series run on an insurance-dedicated platform, the controls of the series and the record of the platform are read from the platform's Form ADV, and the record and depth of the investment manager from the manager's own.
Rating in preparationA fund is not rated while any element lacks a documented basis: for example when the fund does not yet appear in an adviser's Form ADV, the adviser reports that the auditor's report for the last fiscal year has not yet been received, its manager cannot be matched to an SEC registration, the manager's registration has changed since the last filing, or the fund's insurance-dedicated status is still to be confirmed.
Changes of managerWhen a manager is sold or merged, its funds are shown as in preparation until the successor adviser is confirmed in the filings.
Investor experienceWhat policyholders, insurers and advisers tell us is shown separately from the rating and never changes the stars. A factual point raised in a response is checked against the filings, and if it holds, the data behind the rating is corrected.
CorrectionsA manager can ask for the facts behind its rating and respond to them, and a reader can point out an error. Every claim is checked against the filings. A verified correction reaches the fund's page, the manager file and the rankings at the same time, with the date of the change.
AudienceDesigned for ultra-high-net-worth families, family offices and their advisers who use or consider a private placement policy. It is not a guide to funds sold to the public.
Quarterly updatesRatings are updated every quarter. This is the Q4 2026 edition, and a rating can change between editions if something material happens.
SignatureEvery rating is signed by Noam Cohen, Editor of PPLI.com Fund Intelligence.
Disclaimer

Important information

The PPLI.com Fund Rating and all content of PPLI Fund Intelligence express the editorial opinion of PPLI.com, operated by Talniri Ltd, on the date shown. They are based on public filings with the US Securities and Exchange Commission, on information shared with PPLI.com by investors and their advisers, and on editorial judgment. They are not statements of fact about any fund or manager, not a credit rating, not a forecast of returns, and not investment, legal, tax or financial advice, nor an offer 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. The information is provided as is; it may be incomplete or out of date. Readers should verify it with the manager, the insurer and their own professional advisers before making any decision. Fund and manager names are used for identification only and imply no affiliation with, or endorsement by, PPLI.com.

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