A Delaware limited partnership that Pennington Partners & Co., LLC runs for insurance company separate accounts, following a private 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 Regulation D, 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.
Pennington Partners & Co., LLC reports the fund in its own Form ADV of 6 April 2026, which gives the controls and service providers below.
The filing reports an annual audit by Warren Averett and that 100% of the assets were valued last year by a person not related to the adviser.
Pennington Partners & Co., LLC reports no disciplinary matters in Item 11 of its Form ADV: no regulatory actions, criminal matters or civil proceedings against the adviser, its advisory affiliates or its management persons.
Every control we look for is reported: an annual audit by Warren Averett, an outside administrator in Jtc Group, and valuation of nearly all assets by a firm outside the group. No regulator or court action appears in Pennington's filings.
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.
Pennington Partners & Co., LLC 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.
Pennington Partners & Co., LLC reports no disciplinary matters in Item 11 of its Form ADV filed 6 April 2026: no regulatory actions, criminal matters or civil proceedings against the adviser, its advisory affiliates or its management persons.
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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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