Brookfield Insurance Dedicated Fund III: Fund Rating and Research File

In brief

Brookfield Insurance Dedicated Fund III 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 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 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; Brookfield Asset Management PIC BMG, 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. NESF Fund Services Corp. is the administrator. The figure does not show how prices were set or checked, which is a question for the insurer.

Brookfield Asset Management PIC BMG, LLC reports 1 regulatory action in Item 11 of its Form ADV in 2021, none concerning the adviser itself but other companies in its group, with reported sanctions of about USD 114,865. The full record is set out below.

The rating

Why Brookfield Insurance Dedicated Fund III has two stars

Deloitte audits the fund every year and the accounts go to investors. It loses ground on independence. NESF Fund Services, which administers the series, is part of the SALI group, and none of the assets were valued by an outside party last year, as SALI reports. The manager is young and small for this market: USD 912 million under management, registered since 2021.

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 nameBrookfield Insurance Dedicated Fund III

OrganisedDelaware limited partnership, 2024

SEC CIK0002046057 EDGAR

Private fund ID805-4578912478 ADV

Investment managerBrookfield Asset Management Pic Bmg, LLC IAPD

Platforma SALI platform fund IAPD

Offering, as filed on Form D

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

First sale22 February 2024

Minimum investmentUSD 10,000,000

Amount soldUSD 217.4 million to date

Investors in the offering1

Sales commissionsUSD 87,501

Latest filingForm D/A, 8 September 2026 Source

Size and ownership, as filed on Form ADV

Gross asset valueUSD 214,704,371 (ADV filed 25 August 2026)

Beneficial ownersAbout 1

Owned by non-US persons0%

Service providers

AuditorDeloitte & Touche

CustodianState Street Bank & Trust Co.

AdministratorNESF Fund Services Corp.

Prime brokerThe Northern Trust International Banking Corp.

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

Rental and infrastructure income is taxed every year when held directly. Inside a policy that meets the tax rules it compounds untaxed, though the pass-through deductions a direct holder would use do not apply inside the wrapper, so the comparison depends on each family's position.

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 Brookfield Asset Management PIC BMG, LLC

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.

202119 March 2021

Regulatory action by Securities and Exchange Board of India (SEBI): civil penalty

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 Securities and Exchange Board of India ("SEBI") alleged that: (1) Penbrook Capital Advisors private Limited ("Penbrook"), the Investment manager of peninsula Brookfield India real estate Fund (the "Fund") and a joint venture between (I) Brookfield Capital Partners Ltd (Bermuda), a wholly owned subsidiary of Brookfield Asset Management Inc., and (II) peninsula land Ltd, a third-party real estate developer); (2) the current and former directors of Penbrook, including anuj ranjan (former director) and sridhar rengan (current director); and (3) peninsula Brookfield trustee private Limited, (the trustee of the Fund, having the same shareholders as Penbrook) ((1), (2) and (3) collectively, ...

Securities and Exchange Board of India (SEBI) · Settled 28 January 2022 · USD 114,865 · Concerns another company in the group · Form ADV, Item 11 disclosure

These are the matters Brookfield Asset Management PIC BMG, LLC reports in Item 11 of its Form ADV, filed 10 July 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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Brookfield Insurance Dedicated Fund III