Overview
Assets Under Management: $1.4 billion
Headquarters: NEW YORK, NY
High-Net-Worth Clients: 420
Average Client Assets: $4 million
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Fee Structure
Primary Fee Schedule (CARRICK LANE ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 0.85% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,500 | 0.85% |
| $5 million | $42,500 | 0.85% |
| $10 million | $85,000 | 0.85% |
| $50 million | $425,000 | 0.85% |
| $100 million | $850,000 | 0.85% |
Clients
Number of High-Net-Worth Clients: 420
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 71.06
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 330
Discretionary Accounts: 330
Regulatory Filings
CRD Number: 309148
Last Filing Date: 2024-12-13 00:00:00
Website: https://carricklane.com
Form ADV Documents
Primary Brochure: CARRICK LANE ADV PART 2A (2025-03-25)
View Document Text
Item 1. Cover Page
Carrick Lane LLC
Part 2A of Form ADV
(the “Brochure”)
450 7th Avenue
New York, NY 10123
https://www.carricklane.com/
Tel: (212) 433-8450
March 25, 2025
This Brochure provides information about the qualifications and business practices of Carrick Lane LLC
(“we,” the “Adviser,” or “Carrick Lane”). If you have any questions about the contents of this Brochure,
please contact the Advisers Chief Compliance Officer Peter Montgomery at 415-548-5099 or
peter@carricklane.com. This information has not been approved or verified by the SEC or by any state
securities authority.
information about
the Adviser also
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
1
Item 2. Material Changes
Since the Adviser’s previously filed Brochure dated March 26, 2024, the Adviser changed its principal
place of business address.
Our current and future investors are encouraged to read this Brochure and all of the applicable governing
documents to their current or prospective investment, in their entirety.
2
Item 3. Table of Contents
Item 1. Cover Page ........................................................................................................................................ 1
Item 2. Material Changes .................................................................................................................................... 2
Item 3. Table of Contents ............................................................................................................................. 3
Item 4. Advisory Business ............................................................................................................................ 4
Item 5. Fees and Compensation ................................................................................................................... 4
Item 6. Performance-Based Fees and Side-by-Side Management ................................................................ 5
Item 7. Types of Clients ............................................................................................................................... 5
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 5
Item 9. Disciplinary Information ................................................................................................................. 6
Item 10. Other Financial Industry Activities and Affiliations ....................................................................... 6
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 6
Item 12. Brokerage Practices......................................................................................................................... 8
Item 13. Review of Accounts ........................................................................................................................ 9
Item 14. Client Referrals and Other Compensation ...................................................................................... 9
Item 15. Custody ........................................................................................................................................... 9
Item 16. Investment Discretion ..................................................................................................................... 9
Item 17. Voting Client Securities .................................................................................................................. 9
Item 18. Financial Information ................................................................................................................... 10
3
Item 4. Advisory Business
Carrick Lane LLC (“Carrick Lane” or the “Adviser”) is an investment advisory firm that commenced
operations in 2021. Carrick Lane has a principal place of business in New York, New York and is organized
as a limited liability company under the laws of the State of Delaware. The Adviser is wholly owned by
Carrick Lane Holdings LLC, a limited liability company organized under the laws of the State of Delaware
(“CL Holdings”) whose members are Allan Kennedy, Kenneth Kwalik, Peter Montgomery, and Timonthy
Knowles.
The Adviser provides discretionary investment advisory services to “accredited investors,” “qualified clients,”
and “qualified purchasers” as they are defined respectively under Rule 501 of Regulation D of the Securities
Act of 1933, Rule 205-3 under the Investment Advisers Act of 1940 and Rule 2(a)(51)-1 under the
Investment Company Act of 1940, in addition to investment consulting and other services. The Adviser
furnishes guidance to separately managed account arrangements (“Accounts” or “Clients”) based on the
specific investment objectives and strategies that are set forth in the investment management agreement
(“IMA”) and sub-advisory agreement (collectively “Governing Documents”).
The Adviser offers customized option-based solutions to clients with a focus on absolute return, yield
enhancement and risk reduction. Its primary offering is a suite of Put Writing strategies, with an objective to
generate option premium over time by selling and actively managing a portfolio of index put options. The
Put Writing suite provides clients with the ability to opt-in to features that can buy and actively manage index
put options in addition to selling and actively managing put options. Carrick Lane provides exposure to the
strategy targeting the client specified mandate size.
To the extent Accounts are managed under wrap fee programs, the Adviser manages such Accounts the
same as its non-wrap fee Accounts. The Adviser receives fees for the wrap fee accounts based on the
Client’s mandate size.
As of March 25, 2025, the Adviser manages approximately $2,384,425,000 in regulatory assets under
management, all on a discretionary basis.
Item 5. Fees and Compensation
The Adviser charges its Client’s an asset-based investment management fee (the “Management Fee”) on the
mandate size as determined by the Governing Documents. Typically, the mandate size may be expressed
in dollar or number of contract based terms. The value for contract based mandates is derived from the
portfolio’s option strike price and is updated quarterly. If a dollar based mandate size is chosen, the
Management Fee is calculated based on that value. The Management Fee is charged either monthly or
quarterly in advance or in arrears depending on the particular strategy and the arrangement between the
Adviser and the individual Client as set forth in the Governing Documents. When the Management Fee is
charged in advance, a Client will receive a refund of the unused portion of any pre-paid Management Fee.
Management Fees are pro-rated based on the number of days in the applicable strategy for any given quarter
based on the commencement date, termination date or any date in which the mandate was increased or
decreased over the course of the quarter as agreed to in the Governing Documents. Generally, the Adviser
charges its Clients a Management Fee ranging from 0.25% to 0.85% annually.
In addition to paying the Management Fee, Accounts are subject to other investment expenses, including
but not limited to custodial charges, brokerage fees, commissions and related costs; interest margin
expenses; taxes, duties and other governmental charges; transfer and registration fees or similar expenses;
costs associated with foreign exchange transactions; and costs, expenses and fees associated with products
or services that may be necessary or incidental to such investments or accounts. For each Client who is
considering investing with the Adviser it is important that they review the Governing Documents in their
entirety to understand the risks, fees and expenses associated with such investment.
4
The Adviser may change, reduce, or waive the Management Fee for principals, employees or affiliates of
the Adviser, relatives of such persons, and for certain large or strategic investors.
Item 6. Performance-Based Fees and Side-by-Side Management
The Adviser does not charge performance-based fees.
Item 7. Types of Clients
As described in Item 4, the Adviser provides discretionary investment advisory services to including and not
limited to high-net-worth individuals and other sophisticated or institutional investors. In addition, the
Adviser serves as a sub-adviser to one or more investment advisers. Generally, the minimum mandate size
for the Adviser’s Clients is $1,000,000. However, the Adviser has the discretion to accept lesser amounts.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Investment Objective and Strategy
The Adviser utilizes modern portfolio theory, and fundamental, technical and volatility-based research to
guide recommendations to clients and investment decisions.
For information regarding the Adviser’s investment strategies, please refer to the applicable Governing
Documents, which must be reviewed carefully in connection herewith.
Risk Factors
The investment strategies the Adviser uses entail substantial risks, including the complete risk of loss that
clients should be prepared to bear. Other applicable risk factors are included below as well as in the
Governing Documents of the Clients for which the Adviser performs investment advisory services, or in
the applicable documentation furnished to the Clients. Investors are advised to carefully review all risk
factors described in such documents. The following is not intended to supersede the material contained in
such documents nor identify all possible risks of an investment with the Adviser.
Derivatives. Swaps, and certain options and other custom derivative or synthetic instruments are subject to
the risk of nonperformance by the counterparty to such instrument, including risks relating to the financial
soundness and creditworthiness of the counterparty. In addition, investments in derivative instruments may
require a high degree of leverage, meaning the overall contract value (and, accordingly, the potential for
profits or losses in that value) is much greater than the modest deposit used to buy the position in the
derivative contract. Derivative securities can also be highly volatile. The prices of derivative instruments
and the investments underlying the derivative instruments may fluctuate rapidly and over wide ranges and
may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Client
or the Adviser. Further, transactions in derivative instruments may not be undertaken on recognized
exchanges, and may expose the Client’s account to greater risks than regulated exchange transactions that
may provide greater liquidity and more accurate valuation of securities.
Fixed-Income and Debt-Related Securities. Investment in fixed-income and debt-related securities, such as
options on fixed-income indices, subject a Client’s portfolio to the risk that the value of these securities
overall will decline because of rising interest rates. Similarly, portfolios that hold such securities are subject
to the risk that the portfolio’s income will decline because of falling interest rates. Investments in these
types of securities will also be subject to the credit risk created when a debt issuer fails to pay interest and
principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will
cause the price of that debt to decline. Lastly, investments in debt-related securities will also subject the
investments to the risk that the securities may fluctuate more in price, and are less liquid than higher-rated
5
securities because issuers of such lower-rated debt securities are not as strong financially, and are more
likely to encounter financial difficulties and be more vulnerable to adverse changes in the economy.
Illiquid Instruments. Certain instruments may have no readily available market or third-party pricing.
Reduced liquidity may have an adverse impact on market price and the Adviser’s ability to sell particular
securities when necessary to meet liquidity needs or in response to a specific economic event, such as the
deterioration of creditworthiness of an issuer. Reduced liquidity in the secondary market for certain securities
may also make it more difficult for the Adviser to obtain market quotations based on actual trades for the
purpose of valuing a Client’s portfolio.
Security Futures and Options. In connection with the use of futures contracts and options, there may be an
imperfect correlation between the change in market value of a security and the prices of the futures contracts
and options in the Client’s account. In addition, the Adviser’s investments in security futures and options
may encounter a lack of a liquid secondary market for a futures contract and the resulting inability to close
a futures position prior to its maturity date.
Risk of Default or Bankruptcy of Third Parties. Clients may engage in transactions in securities or other
financial instruments and other assets that involve counterparties. Under certain conditions, Clients could
suffer losses if a counterparty to a transaction were to default or if the market for certain securities or other
financial instruments and/or other assets were to become illiquid. In addition, the Client could suffer losses
if there were a default or bankruptcy by certain other third parties, including brokerage firms and banks
with which the Client does business.
Item 9. Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to a client’s evaluation of Carrick Lane or the integrity of Carrick Lane’s
management. Carrick Lane has no disciplinary events to report.
Item 10. Other Financial Industry Activities and Affiliations
The Adviser does not have any financial industry affiliations with a broker-dealer, Futures Commission
Merchant (FCM), Commodity Pool Operator (CPO), or Commodity Trading Advisor (CTA).
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
The Adviser has adopted a Code of Ethics (the “Code”) that obligated the Adviser and its personnel to put
the interests of the Client before their own interests and to act honestly and fairly in all respect in their
dealings with the Client. The purpose of the Code is to identify the ethical and legal framework in which
the Adviser and its personnel are required to operate and to highlight some of the guiding principles and
mechanisms for upholding the Adviser’s standard of business conduct. The description below is a
summary only. For additional information about the Code or to request a copy, please contact Peter
Montgomery at (415) 548-5099 or peter@carricklane.com.
Standard of Business Conduct. The Adviser and its personnel have a fiduciary duty to our Clients, and in
this fiduciary capacity, we must place the interests of our Clients before our own interests.
Basic Principles. The Code is based on a few basic principles: (i) the Adviser and its personnel must place
the interests of Clients above their own; (ii) the professional activities and personal investment activities
of the Adviser’s personnel must be consistent with the Code and avoid any actual or potential undisclosed
material conflict between the interests of Clients and those of the Adviser or its personnel; (iii) the
6
activities of the Adviser’s personnel must be conducted in a way that avoids any abuse of any such person’s
position of trust with and responsibility to the Adviser and Clients; (iv) employees of the Adviser must
not take any inappropriate advantage of their positions at the Adviser; and (v) the Adviser’s personnel
may not engage in any act, practice or course of conduct that would violate the provisions of Rule 204A-
1 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and other applicable securities
laws.
Conflicts of Interest. As a fiduciary, the Adviser has an affirmative duty of care, loyalty, honesty and good
faith to act in the best interests of its Clients. The Adviser makes every effort to avoid conflicts of
interest and fully disclose all material facts concerning any conflict of interest that may arise with respect
to any of its Clients. The Adviser stresses that individuals subject to the Code must try to avoid situations
that have even the appearance of conflict or impropriety.
Insider Trading. The Adviser’s personnel may not trade, either personally or on behalf of another, on
material non-public information or communicate material non-public information to another person in
violation of the law. This policy applies to all of the Adviser’s personnel and extends to their activities
both within and outside their duties for the Adviser. The Adviser has also implemented policies and
procedures designed to detect and prevent insider trading.
Personal Securities Transactions. All personnel must comply with the Adviser’s policy on personal
trading. Except with respect to certain securities (including certain indices, mutual funds, exchange-
traded funds and fixed income securities) and with respect to certain accounts for which a person does
not exercise investment discretion and in regards to certain automatic or non-volitional transactions, such
as dividend reinvestment plans, personal securities transactions by the Adviser’s personnel must be pre-
approved by the Adviser’s Chief Compliance Officer (“Pre-Clearance Procedures”).
Holdings and Transactions Reports. Every employee and access person must submit both initial and annual
holdings report to the Adviser’s Chief Compliance Officer that discloses all covered securities held in any
personal account. Every employee and access person must also submit a quarterly transaction report to the
Chief Compliance Officer for each covered securities transaction in any personal account.
Reporting of Violations. The Adviser has implemented policies and procedures whereby the Adviser’s
personnel are required to report any violation, apparent violation, or potential violation of the Code to the
Adviser’s Chief Compliance Officer.
Review and Enforcement. The Adviser’s Chief Compliance Officer is responsible for ensuring adequate
supervision over the activities of all persons who act on our behalf in order to prevent and detect violations
of our Code of Ethics by such persons.
Participation or Interest in Client Transactions. To the extent that the Adviser’s related persons invest in
the same securities that the Adviser or a related person recommends to a Client, such practices present a
conflict where the Adviser or its related person is in a position to trade in a manner that could adversely
affect the Clients. In addition to affecting the Adviser’s or its related person’s objectivity, these practices by
the Adviser or its related persons may also harm the Clients by adversely affecting the price at which the
Client’s trades are executed. The Adviser has adopted the foregoing Pre-Clearance Procedures in an effort
to minimize such conflicts, which procedures may result in the denial of permission to execute a transaction
if such transaction will have any adverse economic impact on a Client. In addition, the Code prohibits the
Adviser or its personnel from executing personal securities transactions of any kind in any securities on a
restricted securities list maintained by the Chief Compliance Officer. All of the Adviser’s employees are
required to disclose their securities transactions on a quarterly basis and holdings on an annual basis. Trading
in employee accounts will be reviewed by the Chief Compliance Officer, compared with transactions for the
Client accounts and reviewed against the restricted securities list.
To the extent a supervised person of the Adviser buys or sells securities for a Client at or about the same
7
time that such supervised person buys or sells the same securities for its own account, the supervised
person must do so in accordance with the procedures described above in order to minimize the conflicts
stemming from situations where the contemporaneous trading would result in an economic benefit for the
Adviser or its supervised person to the detriment of the Client.
From time to time, subject to Client or investment guidelines and restrictions and to the extent we
determine it to be in our Clients’ best interests to do so, the Adviser is authorized to direct one of our
Clients to sell investments to another of our Clients through an internal cross transaction in which the
Adviser will receive no compensation. Any such transactions will be conducted using a pricing mechanism
the Adviser considers to be fair to both such Clients.
To the extent that any of the transactions described above may be viewed as a principal transaction due to
the interest of the Adviser or its affiliates in a purchaser or seller, the Adviser will comply with the
requirements of Section 206(3) of the Advisers Act, and provide written notification to the relevant Client
and obtain Client consent either prior to the principal transaction or prior to its settlement.
In addition, the Adviser may give advice or take action with respect to investments of one or more of our
Clients that may not be given or taken with respect to our other Clients with similar investment programs,
objectives and strategies. Accordingly, the Adviser’s Clients with similar investment strategies may not
hold the same investments or achieve the same performance. The Adviser may also advise Clients with
conflicting programs, objectives or strategies. These activities may also adversely affect the prices and
availability of other investments held or potentially considered for one or more Clients.
Item 12. Brokerage Practices
Clients of the Adviser, pursuant to applicable Governing Documents, direct the Adviser to execute
transactions with certain designated broker-dealers at their discretion. Not all adviser require clients to
designate a broker-dealer to execute their transactions. Through executing Client’s trades through a
specified broker-dealer, the Adviser will not attempt to negotiate commissions on behalf of the Client.
However, in certain circumstances, the Adviser does have the ability to negotiate commissions and, in such
cases, will consider a number of factors in selecting a broker-dealer to execute transactions (or a series of
transactions) and determining the reasonableness of the broker-dealer’s compensation. Such factors include,
but are not limited to, reputation, efficiency of execution, financial strength and stability. In selecting a
broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the
broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an obligation
to seek the lowest available commission cost.
At this time the Adviser is not a party to, and does not anticipate entering into, a formal “soft dollar”
arrangement. However, in the event that the Adviser utilizes allocations of commission dollars, it will do so
solely to pay for products or services that qualify as “research and brokerage services” within the “safe
harbor” of Section 28(e) of the Securities Exchange Act of 1934, as amended.
At times, the Adviser will aggregate purchase and sale orders of investments held by a Client’s account with
similar orders being made simultaneously for other accounts if, in the Adviser’s reasonable judgment, such
aggregation is reasonably likely to result in an overall economic benefit to such Client based on an evaluation
that the Client will be benefited by relatively better purchase or sale prices, beneficial timing of transactions,
or a combination of these and other factors. In all most all instances, the purchase or sale of investments for
a Client’s account will be effected simultaneously with the purchase or sale of like investments for other
accounts. Such transactions may be made at different prices, due to the volume of investments purchased or
sold. In such event, the average price of all investments purchased or sold in such transactions may be
determined, at the Adviser’s sole discretion, and the Client’s account may be charged or credited, as the case
may be, with the average transaction price.
8
Certain clients may participate in a “wrap fee” program that may not be charged brokerage commissions or
other transaction costs. Carrick Lane is not a sponsor of any wrap fee program. Clients that are a part of a
“wrap fee” program should consult with their program sponsor for details on the fees and expenses
applicable to such client.
Item 13. Review of Accounts
A member of the Adviser’s investment team regularly reviews and monitors Client portfolios. Such review
includes but is not limited to monitoring the securities positions and adherence to investment guidelines for
the applicable Client. Investors receive written reports as further described in the applicable Governing
Documents. Such reports may be delivered electronically to the Client in accordance with the Client’s
agreement with the Adviser.
Certain significant market events affecting the prices of one or more securities in Client accounts may trigger
a prompt review of Client accounts.
Item 14. Client Referrals and Other Compensation
The Adviser compensates third-party solicitors for Client referrals. The Adviser maintains a well-
established relationship with its financial advisers wherein they provide continual Client referrals to the
Adviser. Where applicable, compensation for Client solicitations will be structured to comply fully with
the requirements of the SEC.
Item 15. Custody
The Adviser does not have custody over its Clients’ assets. The assets of the Clients are held by a custodian
as disclosed in the Governing Document or as chosen by the Client. The Adviser is not authorized to open
accounts in the name of a Client. At times, the Adviser will debit certain fees from the Clients’ accounts.
Each Client is urged to carefully review the statements it receives from the broker-dealer, bank or other
qualified custodian and compare such statements to any statements received from the Adviser.
Item 16. Investment Discretion
The Adviser is provided with discretionary authority to manage the investment accounts of Clients as set
forth in the Clients corresponding Governing Documents.
Prior to assuming full discretion in managing a Client’s assets, the Adviser enters into an IMA or other
agreement that sets forth the scope of the Adviser’s discretion.
Unless otherwise instructed or directed by a discretionary Client, the Adviser has the authority to determine:
(1) which securities or instruments to buy or sell and (2) total amount of securities or instruments to buy or
sell. Due to the differences in Client investment objectives and strategies, risk tolerances, tax status and other
criteria, there may be differences among Clients investments.
Item 17. Voting Client Securities
The Adviser does not have, nor will it accept, authority to vote Client securities.
9
Item 18. Financial Information
The Adviser does not require, nor does the Adviser solicit, prepayment of more than $1,200 in fees per
Client, six months or more in advance.
The Adviser has no financial condition that is reasonably likely to impair its ability to meet contractual and
fiduciary commitments to its clients.
The Adviser has never been the subject of a bankruptcy petition.
10