Mystic Total Alpha Growth Insurance Fund: Fund Rating and Research File

In brief

Mystic Total Alpha Growth 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; MS Capital Partners Adviser Inc. manages the investments.

The filing reports an annual audit by BDO USA, P.C. and that 100% of the assets were valued last year by a person not related to the adviser.

MS Capital Partners Adviser Inc. reports 4 regulatory actions in Item 11 of its Form ADV between 2016 and 2017, none concerning the adviser itself but other companies in its group, with reported sanctions of about USD 173 million. The full record is set out below.

The rating

Why Mystic Total Alpha Growth Insurance Fund has four stars

Every control we look for is reported: an annual audit by BDO, an outside administrator in Apex, and valuation of nearly all assets by a firm outside the group. It is also first sold only in 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.

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 nameMystic Total Alpha Growth Insurance Fund Series of the SALI Multi-Series Fund, L.P.

OrganisedDelaware limited partnership, 2024

SEC CIK0002044484 EDGAR

Private fund ID805-5127983879 ADV

Investment managerMs Capital Partners Adviser 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 sale11 October 2024

Minimum investmentUSD 2,500,000

Amount soldUSD 85.0 million to date

Investors in the offering2

Sales commissionsNone reported

Latest filingForm D/A, 10 September 2026 Source

Size and ownership, as filed on Form ADV

Gross asset valueUSD 82,606,736 (ADV filed 25 August 2026)

Beneficial ownersAbout 2

Owned by non-US persons0%

Service providers

AuditorBDO USA, P.C.

CustodianPrincipal Bank; Wells Fargo Bank N.a

AdministratorApex Fund and Corporate Services

Prime brokerNone reported

Valued by a person not related to the adviser100% 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 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.

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 MS Capital Partners Adviser 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.

20176 March 2017

Regulatory action by Hellenic Capital Market Commission: 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 Hellenic Capital Market Commission (HCMC) alleged that Morgan Stanley committed Market manipulation pursuant to Article 7, par. 2(C) of Law 3340/2005 by disclosing that the firm, through various subsidiaries, had acquired more than 5% of alpha Bank, however 4.16% of the Holding was held by a subsidiary as custodian on behalf of a customer.

Hellenic Capital Market Commission · Decision 24 April 2019 · USD 52,960 · Concerns another company in the group · Form ADV, Item 11 disclosure

201622 March 2016

Regulatory action by Portuguese Securities Market Commission: other sanction

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 Portuguese Securities Market Commission (CMVM) alleged that the firm did not notify the CMVM or the issuing Company of changes to certain qualifying Holdings within the required time period, in violation of Article 16 of the Portuguese Securities Code

Portuguese Securities Market Commission · Decision 5 March 2018 · No monetary sanction reported · Concerns another company in the group · Form ADV, Item 11 disclosure

201611 February 2016

Regulatory action by Office of the Attorney General of the State of Illinois: 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 Illinois Attorney General's Office ("ILAG") alleged that Morgan Stanley violated Illinois Law in connection with the marketing, sale, and issuance of certain residential mortgage-backed Securities between 2002 and 2008.

Office of the Attorney General of the State of Illinois · Settled 11 February 2016 · USD 22.5 million · Concerns another company in the group · Form ADV, Item 11 disclosure

201611 February 2016

Regulatory action by Attorney General of the State of new York: 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 new York Attorney General's Office ("NYAG") alleged that Morgan Stanley violated new York Law in connection with the marketing, sale, and issuance of certain residential mortgage-backed Securities between 2006 and 2007.

Attorney General of the State of new York · Settled 11 February 2016 · USD 150.0 million · Concerns another company in the group · Form ADV, Item 11 disclosure

These are the matters MS Capital Partners Adviser Inc. reports in Item 11 of its Form ADV, filed 17 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

How would you rate Mystic Total Alpha Growth Insurance Fund?

Tap a star to give your own rating, from one to five, then add your name and email and, if you wish, a comment. Reader ratings are shown separately and never change the PPLI.com Fund Rating, which rests only on what the filings report.

Loading reader ratings.

Your name

Your email

Your comment, if you have one

Your name and email are used only if the research desk needs to reply, and are never published. Comments go to the desk, which checks any factual point against the filings.

Mystic Total Alpha Growth Insurance Fund

Mystic Total Alpha Growth Insurance Fund at a glance

Why Mystic Total Alpha Growth Insurance Fund has four stars

Conduct and regulatory record

Reported controls

Depth and experience of the manager

Fund scale and investor base

Reporting and filings

Fit for a life insurance policy

Identity, offering and service providers

Identity

Offering, as filed on Form D

Size and ownership, as filed on Form ADV

Service providers

What to check before this fund goes into a policy

Why the wrapper matters here

Liquidity

Who chooses the investments

Diversification

Valuation

Fees

Regulatory and legal record of MS Capital Partners Adviser Inc.

Regulatory action by Hellenic Capital Market Commission: civil penalty

Regulatory action by Portuguese Securities Market Commission: other sanction

Regulatory action by Office of the Attorney General of the State of Illinois: civil penalty

Regulatory action by Attorney General of the State of new York: civil penalty

How would you rate Mystic Total Alpha Growth Insurance Fund?

Sources

About this file

For the manager

Tell us about yourself

How can we help?

Thank you