A series of SALI SVW Multi-Series Fund, L.P., an insurance-dedicated platform, managed by BlackRock Financial Management, Inc., following a fixed income and structured credit strategy. 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 one beneficial owner 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 SVW 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; BlackRock Financial Management, Inc. manages the investments.
The filing reports an annual audit by KPMG, LLP and that 100% of the assets were valued last year by a person not related to the adviser.
BlackRock Financial Management, Inc. reports 12 regulatory actions and 3 civil proceedings in Item 11 of its Form ADV between 2017 and 2026, none concerning the adviser itself but other companies in its group, with reported sanctions of about USD 10 million. The full record is set out below.
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.
Interest from loans and bonds is ordinary income for a US taxpayer, taxed at up to 37% plus the 3.8% net investment income tax, every year. Held through a policy that meets the tax rules, the same income compounds without a yearly tax bill. How the numbers work
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 all of the fund's assets were valued last year by a person not related to it, the strongest answer the form allows. Still ask who values the positions and how often.
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.
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.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
On January 9, 2025, the comisión Nacional Bancaria y de Valores ("CNBV") imposed a fine of approximately $123,000 USD (MXN $2,501,720) regarding the anti-money laundering and counter-terrorist financing program at BlackRock's Mexico City Office. Specifically, the CNBV found that BlackRock Mexico did not have sufficient procedures to assess whether potential transactions involving politically exposed persons were appropriate and to collect certain information about higher risk clients. Further, the CNBV identified instances where BlackRock Mexico did not maintain complete client files.
Fund concerned: public ESG and non-ESG funds. None of the insurance-dedicated funds in this file is named.
On November 27, 2024, the Texas Attorney General and the attorneys general from 10 other States (Alabama, Arkansas, Indiana, Iowa, Kansas, Missouri, Montana, Nebraska, West Virginia, and Wyoming) filed a complaint against BlackRock, Vanguard, and State Street (the "managers") alleging that the managers used their ownership stakes in coal companies to artificially reduce coal output in violation of various State and Federal antitrust laws. Texas also claims BlackRock made false and deceptive statements in connection with the marketing of its non-ESG ETFS.
Fund concerned: public ESG and non-ESG funds. None of the insurance-dedicated funds in this file is named.
On August 22, 2024, the Indiana Securities Commissioner (the "Commissioner") issued a cease and desist order (the "order") against BlackRock, Inc. and several of its advisory affiliates, (collectively, "BlackRock"). The order alleges that BlackRock has made misleading statements about how we manage our non-ESG and ESG Funds. With respect to non-ESG Funds, the order cites to our participation in climate organizations and our statements regarding ESG integration and stewardship activities, among other things, as evidence that our non-ESG Funds actually pursue an ESG strategy. With respect to ESG Funds, the order asserts that BlackRock falsely claims that sustainable investing will generate ...
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
On March 27, 2024, BlackRock, Inc., BlackRock investments, LLC, BlackRock Advisors, LLC, BlackRock Fund Advisors, and iShares Trust (collectively, "BlackRock") were served with a summary cease and desist order and notice of intent to impose administrative penalty from the Mississippi Secretary of State. The summary order alleges that BlackRock has made misleading statements in Fund prospectuses, marketing material, public statements, and on its website regarding BlackRock's ESG practices and approach to proxy voting. The summary order, which was issued to BlackRock without any prior notice or opportunity to be heard, finds that BlackRock violated the Mississippi Securities laws, and orders ...
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
On December 18, 2023, the Tennessee Attorney General ("AG") sued BlackRock, Inc. in Tennessee State Court for alleged violations of Tennessee's consumer Protection statute in connection with our ESG practices. The complaint generally alleges that BlackRock has made misleading statements in Fund prospectuses, fact sheets, various public statements, and on its website regarding its ESG practices and its approach to proxy voting.
Fund concerned: a public mutual fund. None of the insurance-dedicated funds in this file is named.
Failure to comply with certain regulations applicable to the Management of mutual Funds and the provision of Investment advisory Services in BlackRock's Mexico City Office.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
According to the SEC order, GIM (I) did not offset from applicable Management fees eligible fees paid to it by a Fund portfolio Company, (II) did not offset from applicable Management fees the full amount it owed a Fund's Limited Partners in connection with eligible fees it collected from a Fund portfolio Company and (III) included inconsistent provisions concerning the Management fee calculation methodology in the offering and governing documents for two Funds. In addition, the SEC order found that GIM did not adopt and implement written policies and procedures reasonably designed to prevent the above violations of the Advisers Act.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
On dates in 2017 and in 2018, BlackRock, Inc. was late in making certain threshold filings with the Swiss regulator. These late filings were caused by two separate issues: (1) incorrect share issue information provided to BlackRock by its third party vendor; and, (2) BlackRock's outgoing email quarantine System incorrectly quarantining threshold information emails from BlackRock to the Swiss regulator.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
The CME concluded that BlackRock violated Chicago Board of Trade (CBOT) Rule 562, which prohibits firms from Holding positions on the CME larger than the limits proscribed by CME rules.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
BaFin (the German Financial regulator) reached a decision against BIM UK for approximately 180 incorrect thresholds filings between August 2018 and October 2018 following Brexit restructuring.
Fund concerned: a public mutual fund. None of the insurance-dedicated funds in this file is named.
On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC ("BAL") to settle findings relating to misstatements in annual and semi-annual reports of a mutual Fund for which BAL serves as the registered Investment adviser. The SEC found that the reports inaccurately described the interest rate and Industry classification of a lending facility with a privately held entity in which the mutual Fund invested. Without admitting or denying the SEC'S findings, BAL agreed to the entry of an administrative order containing findings that BAL violated Section 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder and Section 34(b) of the Investment Company Act ...
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
BlackRock Investment Management (UK) Limited ("BIM UK") is required to report to the Swedish Financial Services Authority ("SFSA"), within a specified time period, its Holdings in listed issuers where those Holdings cross a certain threshold ("notifications"). On May 5, 2017, an external vendor was unable to provide accurate data resulting in approximately a 5 minute delay in BIM UK's submission of certain short selling notifications to the SFSA. The SFSA was informed in advance of the filing deadline of the likelihood of a delay to the submission of certain short selling notifications. In September 2017, BIM UK responded to an inquiry from the SFSA regarding the late submission on May 5, ...
Fund concerned: iShares MSCI Russia Capped ETF, a public ETF. None of the insurance-dedicated funds in this file is named.
The order specifically concerns the iShares MSCI Russia capped ETF ("Russia Fund ETF"), managed by BlackRock Fund Advisors ("BFA") and whether it was covered by existing exemptive relief granted by Securities and Exchange Commission ("SEC"). In 2010, the Russia Fund ETF began selling its shares as the only series of shares of iShares MSCI Russia capped ETF, Inc. ("Russia Fund Company"). The Russia Fund Company did not have the required exemptive relief until January 2015. Accordingly, by operating the Russia Fund ETF from December 2010 to January 2015, BFA caused the Russia Fund Company to violate the Investment Company Act.
Fund concerned: none named in the filing. The matter concerns another company in the group, not a specific fund, and none of the insurance-dedicated funds in this file is named.
The U.S. Securities and Exchange Commission ("SEC") found that a historic version of BlackRock Inc.'s ("BlackRock") form employee separation and release agreement ("agreement") violated Dodd Frank's whistleblower provisions, (Rule 21f-17 under the Securities and Exchange Act of 1934). The agreement, which was in use between October 2011 and March 2016, did not prohibit former employees from reporting alleged wrongdoing to the SEC. However, employees who accepted a voluntary separation payment from BlackRock waived their right to recover a Monetary reward from the SEC in connection with its whistleblowing program. BlackRock stopped using the agreement at issue before being contacted by the ...
These are the matters BlackRock Financial Management, Inc. reports in Item 11 of its Form ADV, filed 27 August 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.
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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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