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LinePoint Partners & Co., LLC
2121 Avenue of the Stars, Suite 2900
Los Angeles, CA 90067
Phone: (323) 886-3635
Fax: (323) 538-8740
www.linepointpartners.com
FORM ADV PART 2A – DISCLOSURE BROCHURE
January 16, 2026
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of LinePoint Partners & Co., LLC (“LinePoint” or the “Advisor”), and its relying investment
adviser, LinePoint Investments GP, LLC (“LinePoint GP”). The Advisor and LinePoint GP conduct a single
advisory business, which is described in this Disclosure Brochure. If you have any questions regarding the
contents of this brochure, please do not hesitate to contact the Advisor’s Chief Compliance Officer, Santino
G. Coury, by telephone at (323) 886-3635 or by email at compliance@linepointpartners.com. The
information in this Disclosure Brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
LinePoint is a registered investment adviser. Registration with the SEC or any state securities authority does
not imply a certain level of skill or training. Additional information about LinePoint is available on the SEC’s
website at www.adviserinfo.sec.gov by searching the Advisor’s name or CRD# 332598.
This Disclosure Brochure is for informational purposes only. It does not convey an offer of any type and is
not an offer to sell, or the solicitation of an offer to buy, any interest in any entity, investment, or investment
vehicle.
Item 2 – Material Changes
Material Changes
This Disclosure Brochure provides information about a variety of topics relating to the Advisor’s business
practices and investment activities, as well as a description of potential risks and conflicts of interest. The
Advisor routinely updates its Disclosure Brochure to improve and clarify the description of such information
or in response to evolving industry or firm practices.
LinePoint previously updated its Disclosure Brochure on November 20, 2025. This amendment reflects the
following changes:
• Effective December 17, 2025, James M. Chirdo transitioned from his roles as Chief Operating Officer
and Chief Compliance Officer of LinePoint Partners & Co., LLC, and its relying investment adviser,
LinePoint Investments GP, LLC. Mr. Chirdo continues his relationship with LinePoint in the capacity
of Strategic Advisor, providing strategic perspective and institutional insight in support of the firm’s
long-term objectives.
Future Changes
From time to time, LinePoint may amend this Disclosure Brochure to reflect changes in business practices,
changes to regulatory requirements, or routine annual updates as required by securities regulators. This
complete Disclosure Brochure or a summary of any material changes will be provided to you annually and
upon any material amendment.
At any time, you may view the current Disclosure Brochure by visiting the SEC’s Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov and searching for the Advisor’s name or CRD#
332598. You may also request a copy by contacting LinePoint by telephone at (323) 886-3635 or by email
at compliance@linepointpartners.com.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 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 ........................................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................. 14
Item 7 – Types of Clients ................................................................................................................................. 15
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 16
Item 9 – Disciplinary Information .................................................................................................................... 20
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................ 21
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................... 22
Item 12 – Brokerage Practices .......................................................................................................................... 23
Item 13 – Review of Accounts ......................................................................................................................... 26
Item 14 – Client Referrals and Other Compensation ....................................................................................... 27
Item 15 – Custody ............................................................................................................................................ 29
Item 16 – Investment Discretion ...................................................................................................................... 30
Item 17 – Voting Client Securities ................................................................................................................... 31
Item 18 – Financial Information ....................................................................................................................... 32
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 3
Item 4 – Advisory Business
LinePoint is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The
Advisor is organized as a limited liability company under the laws of the State of Delaware. LinePoint was
founded in July 2024, with its principal business location in Los Angeles, CA. LinePoint is owned by
Robertino S. Coury (Founder & CEO), Santino G. Coury (CITO & CCO, Co-Founder), Juliano C. Coury
(Managing Director, Co-Founder), and Andreo V. Coury (Managing Director, Co-Founder).
LinePoint offers investment advisory services to individuals, high net worth individuals, families, family
offices, trusts, estates, businesses, charitable organizations, and private pooled investment vehicles (each
referred to as a “Client” or collectively as “Clients”). LinePoint’s advisory services may be provided on a
discretionary or a non-discretionary basis.
Each advisory relationship at LinePoint is managed by one or more financial advisors, acting in the capacity
of an investment adviser representative registered with LinePoint (hereinafter referred to as “Financial
Advisor(s)” or “IAR(s)”). The Financial Advisor serves as the primary point of contact between LinePoint
and the Client.
Financial Advisors may create their own business entities, and/or create their own trade names (“DBAs”) and
logos that are used to conduct and market their advisory services, and the names of such business entities or
DBAs may appear on marketing materials or Client statements, as approved by LinePoint. LinePoint’s Form
ADV Part 2B Brochure Supplement (“Financial Advisor Brochure Supplement”) identifies any business or
DBA name utilized. Financial Advisors who provide investment advisory services are independent contractors
or employees of LinePoint, and all investment advisory services are subject to the supervision of, and are
conducted through, LinePoint.
Financial Advisors may have other material business interests, unrelated to their advisory services provided
through LinePoint, as described in the Financial Advisor Brochure Supplement.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest, by putting the best interests of Clients ahead of its own interest.
LinePoint’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 - Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Statements in this brochure, including those made in the present tense, may describe the prospective business
of LinePoint. If you have any questions regarding the contents of this Disclosure Brochure, please do not
hesitate to contact the Advisor’s Chief Compliance Officer, Santino G. Coury, by telephone at (323) 886-3635
or by email at compliance@linepointpartners.com.
Investment Advisory Services
LinePoint IARs provide investment advisory services to its Clients that may consider and utilize a variety of
asset classes and investment vehicles that typically include mutual funds, exchange traded funds (“ETFs”),
equity securities, fixed income securities, structured products, traded and non-traded REITs, hedge funds,
private credit, private equity, venture capital, private real estate, direct investments, and other related
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 4
securities. LinePoint IARs offer advice on these and other types of investments based on the individual
circumstances of each Client. IARs may manage Client accounts in accordance with customized investment
guidelines developed for a specific Client, with security selection varying from one Client to another.
LinePoint IARs work with each Client to understand the Client’s risk tolerance, investment objectives, and
investment attribute preferences, and to determine an appropriate asset portfolio construction. Each LinePoint
IAR, based on his or her own analysis, management style and preferences, in conjunction with each Client’s
specific profile and financial circumstances, determines an appropriate portfolio for each of their Clients.
Depending on how the Client’s assets are allocated, they are managed in different ways. When assuming the
management of an existing Client portfolio, LinePoint IARs may retain certain legacy investments based on
portfolio fit and/or tax considerations, among other factors.
IARs, subject to LinePoint’s supervision, can develop their own investment philosophies and strategies.
Investment philosophies and strategies can differ considerably between and among IARs. There is no
guarantee, stated or implied, that a strategy or a Client’s investment goals or objectives will be achieved.
LinePoint, through its Financial Advisors, is available to Clients on an ongoing basis to discuss Client
financial circumstances, to review the selected portfolio and the securities therein, or to process instructions
from Clients concerning advisory assets.
Prior to engaging LinePoint to provide advisory services, each Client is required to enter into a written
advisory agreement with the Advisor that defines the terms, conditions, authority, and responsibilities of the
Advisor and the Client.
Sub-Advisors
LinePoint IARs may recommend or allocate a portion of a Client’s assets to certain unaffiliated independent
investment managers, who serve as sub-advisers (each, a “Sub-Advisor”) to actively manage a portion of the
assets in accordance with the Client’s designated investment objectives. In such situations, the Sub-Advisor
shall have day-to-day responsibility for the active discretionary management of the allocated assets. LinePoint
and its IARs have no ability to affect the trading decisions of the Sub-Advisor once they are chosen but can
advise on the decision to engage or terminate a particular Sub-Advisor. LinePoint IARs shall continue to
render continuous and regular investment supervisory services to the Client relative to the ongoing monitoring
and review of account performance, including any sub-advised account, asset allocation and Client investment
objectives. Please note: Investment management fees charged by a Sub-Advisor are separate from, and in
addition to, LinePoint’s investment advisory fee and Platform Fee (as hereinafter defined).
The specific terms and conditions under which a Client engages a Sub-Advisor will be set forth in a separate
written agreement with the Sub-Advisor. Depending on the Sub-Advisor, a Client may enter into a written
agreement directly with the Sub-Advisor, or, alternatively, LinePoint can contract directly with the Sub-
Advisor on the Client’s behalf. Clients will receive the written disclosure documents of the respective Sub-
Advisor engaged to manage their assets.
LinePoint has also hired third-party unaffiliated advisers to provide research to assist Financial Advisors with
the investment management of Client assets. These unaffiliated advisers do not have any authority to exercise
discretion over the management of LinePoint’s Client’s assets.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Mutual Funds and ETFs
Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective
client can obtain many of the funds that may be utilized by LinePoint and its IARs independent of engaging
LinePoint as an investment advisor. However, if a prospective client determines to do so, they will not receive
LinePoint’s initial and ongoing investment advisory services.
In addition to LinePoint’s investment advisory fee, the Platform Fee, direct account expenses and
administrative costs, and transaction and/or custodial or brokerage fees described below, Clients will also
incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g.,
management fees and other fund expenses).
Structured Notes
LinePoint and its IARs may purchase structured notes for Client accounts. A structured note is a financial
instrument that combines two elements: (i) a debt security, and (2) exposure to an underlying asset or assets.
It is essentially a note, carrying counterparty risk of the issuer. However, the return on the note is linked to
the return of an underlying asset or assets, such as the S&P 500 Index or commodities. It is this latter feature
that makes structured products unique, as the payout can be used to provide some degree of principal
protection and/or leveraged returns (usually with some cap on the maximum return), and can be tailored to a
specific market or economic view. In addition, investors may receive long-term capital gains tax treatment if
certain underlying conditions are met and the note is held for more than one year. Finally, structured notes
also have liquidity constraints, such that a sale before maturity may be limited.
Unaffiliated Private Funds and Direct Investments
LinePoint provides investment advice regarding private funds, including direct investment in individual
enterprises, either directly or through special purpose vehicles. LinePoint and its IARs may recommend or
allocate an investment by certain qualified Clients in a private fund and/or direct investment in an individual
enterprise. The applicable offering and/or governing documents for such investments as described above will
outline the terms, conditions, risks, conflicts, and fees, including incentive compensation. Clients should
carefully review such offering and/or governing documents prior to investing in such private fund and/or
direct investments.
Affiliated Private Funds
LinePoint also serves as the investment advisor to an affiliated private fund, LinePoint Investments, L.P., and
its respective series and wholly owned subsidiary investment entities (collectively, referred to herein as the
“Affiliated Fund(s)”). These services are detailed in the offering documents for the Affiliated Funds, which
include, as applicable, organizational and governing documents, limited partnership agreement and series
designations, offering memorandum, series supplements, subscription agreement and all amendments thereto
(“Offering Documents”).
Advisory services provided to the Affiliated Funds by LinePoint are based on the investment objectives,
policies and guidelines as set forth in the respective Offering Documents and not in accordance with the
individual needs or objectives of any particular investor therein. Each prospective investor interested in
investing in the Affiliated Funds is required to complete a subscription agreement, attesting to their
qualifications to invest in the Affiliated Fund and acknowledging and accepting the various risk factors
LinePoint Partners & Co., LLC – Form ADV Part 2A
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associated with such an investment.
LinePoint IARs may recommend that certain Clients who meet certain qualifications invest in LinePoint’s
Affiliated Funds. To the extent that a Client of the Advisor invests in an Affiliated Fund, the Client will
ordinarily bear both the investment management fee charged directly by the Affiliated Fund as well as the
investment advisory fee charged by LinePoint for its investment advisory services. This creates a conflict of
interest as the Advisor has an incentive to recommend an Affiliated Fund to a Client based on its interest in
receiving additional advisory fees. The Advisor and its IARs have a fiduciary duty to make or recommend
investments that are in the best interests of Clients’ accounts and without consideration of the Advisor’s
economic or other financial interests. The Advisor and its IARs expect to take into account the unique aspects
of the Affiliated Fund’s underlying investment strategies, its terms, the Advisor’s transparency into the
operations of an Affiliated Fund relative to the operations of third-party funds, and the best interest of each
Client to whom the Advisor makes a recommendation regarding an Affiliated Fund.
For the avoidance of doubt, an Affiliated Fund is considered a Client of the Advisor. Qualified individuals or
entities that invest directly in an Affiliated Fund are sometimes referred to in this document as “investors.”
Assets Under Management
As of January 31, 2025, LinePoint had regulatory assets under management of approximately $567,302,305,
all on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 7
Item 5 – Fees and Compensation
Fees for Advisory Services
When a Client engages LinePoint to provide investment advisory services, LinePoint charges an advisory fee.
Fees for advisory services are generally calculated as a percentage of the total market value of the managed
assets.
Financial Advisors set their own advisory fees for their services, as long as the maximum advisory fees do not
exceed 2.00% of the total portfolio assets committed to the IAR. Fees are negotiated on an individual basis at
the time of the engagement for such services. Financial Advisors consider various factors in determining what
advisory fee to charge, which may include, without limitation, complexity of the portfolio, amount of assets
to be placed under management, related accounts, the nature and size of the overall Client relationship with
the Financial Advisor, the type of advisory services likely to be provided through the Financial Advisor, or
other special circumstances. The specific fee schedule will be identified in the advisory agreement between
the Client and LinePoint.
Advisory fees for investment advisory services are paid quarterly, in advance of each calendar quarter,
pursuant to the terms of the advisory agreement. Investment advisory fees are based on the market value of
assets under management at the end of the prior quarter. The advisory service fee for the initial calendar
quarter in which an account is opened will be due and payable in the quarter immediately following account
funding, and is prorated from the inception date of the account(s) to the end of the initial quarter. For the
calendar quarter in which an advisory agreement is terminated, any paid but unearned fees will be promptly
refunded to the Client based on the number of days that the account was managed, and any fees due to
LinePoint from the Client will be invoiced or deducted from the Client’s account prior to termination. Upon
termination of a Client’s advisory agreement, the Client will be charged all usual fees for transactions and
services provided with respect to the Client’s account.
Generally, LinePoint requires Clients to authorize the direct debit of advisory service fees from their accounts.
However, certain exceptions may be granted, subject to LinePoint’s written consent, to permit Clients to be
billed directly for advisory service fees. The Client may withdraw this authorization for direct debit of the
advisory service fee at any time by notifying LinePoint or its custodian in writing. If the cash portion of an
account is insufficient to pay the advisory service fee, LinePoint may direct the custodian to liquidate assets
selected by LinePoint to pay such fees.
LinePoint typically compensates its Financial Advisors based upon the revenues derived from accounts that
they service. The Financial Advisor generally maintains the authority to determine/negotiate the advisory fee
percentage. In addition, experienced Financial Advisors moving their practices to LinePoint may have
received loans or other financial incentives based on reaching certain asset levels or revenues generated. Thus,
conflicts of interest exist because the higher the advisory fee, the greater the Financial Advisor’s
compensation. The Advisor seeks to mitigate these potential conflicts of interest by imposing suitability
requirements and maintaining a supervisory system that includes conducting periodic compliance inspections
and audits of each Financial Advisor and their book of business. This conflict of interest is further mitigated
by fiduciary obligations and regulatory and compliance rules and procedures to which the Advisor and the
IARs are subject.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Family Office Platform Fee
Separate and distinct from the advisory fee described above, LinePoint imposes a fee for accessing and
utilizing its family office platform (the “Platform Fee”). The Platform Fee compensates for distinct services,
tools, and infrastructure not covered by the advisory fee and is designed to support IARs of LinePoint for the
benefit of their respective Client accounts that they manage. These include, but are not limited to, technology
and software, administration, custody, investment support and research, access to a network of service
providers, billing and reporting, operational and back-office support, compliance, professional liability
insurance, ongoing platform development, and advanced planning support, among other related items. For the
avoidance of any doubt, LinePoint’s Platform Fee, unless otherwise disclosed, will be charged to the Client
account, separate from and in addition to such Client’s advisory fee, as described above.
LinePoint’s Platform Fee is equal to forty percent (40%) of the Client’s advisory fee. For example, if a Client’s
advisory fee is 1.00%, LinePoint’s Platform Fee shall be 0.40% (i.e., 40 basis points). If a Client’s advisory
fee is 0.50%, LinePoint’s Platform Fee shall be 0.20% (i.e., 20 basis points). The Platform Fee is billed
quarterly, in advance, based on the market value of assets under management at the end of the prior quarter.
For the initial quarter of service, the Platform Fee is prorated based on the number of days the account is
active during that quarter. The Platform Fee may be reduced or waived at LinePoint’s or the IAR’s discretion.
For IARs compensated based on a payout percentage of the Client’s advisory fees, the IAR has discretion to
reduce or waive the Client’s Platform Fee, in which case the IAR will receive a lower payout percentage from
the Client’s account(s). This creates a conflict of interest in that the IAR has an incentive not to reduce or
waive the Client’s Platform Fee.
Single family offices may engage LinePoint to provide non-investment advisory services, such as tailored
operational and back-office service support and access to LinePoint’s platform and network of service
providers, among others. LinePoint typically charges the family office management company a Platform Fee
ranging from 0.02% to 0.25% (i.e., 2 to 25 basis points) based on the aggregate value of their family office
client assets supported or monitored by LinePoint’s platform. Platform Fees for single family offices are
negotiable and determined on a case-by-case basis. Factors influencing the determination of the Platform Fee
for a single family office include, but are not limited to: (i) the size and nature of the family office, (ii) the
scope and complexity of the services rendered to their family office clients, (iii) the amount and types of the
assets placed under LinePoint’s direct management (if any), (iv) the amount and types of the assets placed
under LinePoint’s advisement (assets that are generally managed directly by the single family office or by
other investment professionals engaged by the family office, for which LinePoint provides review/monitoring
services, but does not have trading authority), and (v) the likelihood of additional assets being placed under
LinePoint’s management as a result of the relationship with the single family office.
Direct Account Expenses and Administrative Costs
LinePoint may charge the Client for direct account expenses and administrative costs paid by LinePoint on
behalf of the Client. Such expenses and costs may vary based upon the Client’s specific needs and account
size, as discussed with and determined by the IAR, and may include, but not be limited to, expenses related
to custody fees and services provided by a qualified custodian, financial data feeds, and family office
technology providing holistic wealth reporting. Such expenses and costs may be reduced or waived at
LinePoint’s or the IAR’s discretion. For IARs compensated based on a payout percentage of the Client’s
advisory fees, the IAR has discretion to reduce or waive all or a portion of direct account expenses and
administrative costs, in which case the IAR will receive a lower payout percentage from the Client’s
account(s). This creates a conflict of interest in that the IAR has an incentive not to reduce or waive the
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Client’s direct account expenses and administrative costs.
Other Fees and Expenses
Clients may incur certain fees, commissions, or charges imposed by third parties, other than LinePoint, in
connection with investments made on behalf of the Client’s account(s). The Client is responsible for all
custody and securities execution fees charged by the custodian, as applicable.
LinePoint and its IARs recommend that certain Clients invest account assets in open-end mutual funds
including money market funds, closed-end funds, exchange traded funds, and other registered collective
investment vehicles that have various internal fees and expenses, which are borne by the Client as an investor.
LinePoint’s advisory fee and Platform Fee do not include the internal management, operating or distribution
fees or expenses imposed or incurred by a mutual fund, ETF or other pooled investment vehicle held in a
Client's account. If a Client’s assets are invested in any mutual funds, ETFs, or other pooled investment
vehicles, in addition to LinePoint’s investment advisory fee and Platform Fee, the Client will incur the internal
management and operating fees and expenses, investment management and/or performance-based fees,
redemption/early termination fees, which include fees on whole or partial liquidations of the Client’s assets
in the investment vehicles, and other fees and expenses that are assessed by the investment vehicle’s sponsor,
custodian, transfer agent, adviser, shareholder service provider or other service providers. These expenses
include administration, distribution, transfer agent, custodial, legal, audit and other fees and expenses. Further
information regarding charges and fees assessed is found in the appropriate prospectus, offering
memorandum, annual report and/or custodial agreement applicable to the corresponding investment vehicle.
LinePoint and its IARs generally use institutional or advisory share classes that typically have a higher initial
minimum investment and lower expense ratios as compared with other retail share classes. However, in some
instances, LinePoint may not be able to purchase institutional or advisory share classes though third-party
custodians. In other instances, LinePoint will purchase other share classes, such as load waived A shares,
which do not have a sales load but typically have a higher expense ratio than institutional share classes. Clients
should not assume that they will only be invested in mutual funds with the lowest expense ratio, as LinePoint
considers other factors beyond expense ratios when making recommendations to its advisory clients.
LinePoint and its IARs can allocate a portion of the Client’s investment assets among unaffiliated independent
investment managers (i.e., Sub-Advisors, as defined in Item 4 of this Disclosure Brochure) in accordance with
the Client’s designated investment objectives. In such situations, the Sub-Advisors shall have day-to-day
responsibility for the active discretionary management of the allocated assets. LinePoint will continue to
render continuous and regular investment supervisory services to the Client relative to the ongoing monitoring
and review of account performance, asset allocation and Client investment objectives. Such fees charged by
the Sub-Advisor are separate from, and in addition to, LinePoint’s advisory fee and Platform Fee.
In addition to fees paid to LinePoint (which include its advisory fee(s) and Platform Fee(s)) and any Sub-
Advisors, Clients will also incur certain charges imposed by other third parties, such as broker-dealers,
custodians, trust companies, banks, and other financial institutions (collectively “Financial Institutions”).
These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees
attributable to alternative assets, reporting charges, margin costs, automated customer account transfer
(ACAT) fees, charges imposed directly by pooled investment vehicles, including mutual funds, ETFs, REITs,
alternative investment funds (e.g., hedge funds, etc.), private market funds (e.g., private equity funds, private
credit funds, venture capital, etc.), as disclosed in the respective fund’s prospectus (e.g., fund management
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fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions, among other
charges.
Affiliated Private Fund
The Advisor’s fees for its Affiliated Funds are set forth and outlined in each Affiliated Fund’s Offering
Documents. The Advisor does not have a single standardized management fee or performance fee schedule
for such Affiliated Funds. Generally, investors are assessed (i) a management fee equal to a percentage of the
net asset value of the investor’s interest in the Affiliated Fund and, if applicable, (ii) performance-based
compensation, which is calculated as a percentage of the investor’s net profits or net capital appreciation
(unrealized and/or realized) allocated to the investor’s account. Management fees, if applicable, are payable
regardless of profitability and are charged during periods of loss. All performance-based allocations, if
applicable, are charged in accordance with Rule 205-3 under the Investment Advisers Act of 1940, as amended
(the “Advisers Act”). Also, the Advisor in its sole discretion, may elect to reduce, waive or calculate
differently the management fees and/or performance-based fees with respect to any employee or affiliate of
LinePoint, any family member thereof or trusts, estate planning and other investment accounts and/or vehicles
established by or for the benefit of such persons.
In addition to paying investment management fees and performance-based compensation to the Advisor (as
described above), Affiliated Funds will typically pay for their own operating and investment expenses, which
may include, but are not necessarily limited to, the following: fees, costs and out-of-pocket expenses incurred
in connection with the formation of an Affiliated Fund; fees and expenses of any advisers and consultants to
the Affiliated Fund; external legal, auditing, accounting, administration, tax return preparation and other
professional fees and expenses; fees and expenses of an Affiliated Fund’s directors, if applicable, including
the costs associated with meetings; fees and expenses of the Affiliated Fund’s administrator; governmental
charges or filing fees; fees and expenses of prime brokers, custodians, futures commission merchants,
brokerage commissions and dealer collateral and other fees, charges, payments and expenses and other costs
of trading, acquiring, monitoring or disposing of any investments of an Affiliated Fund; fees and expenses of
any third-party research, market data, software services, tools and systems to assist with data analytics and
modeling, trade processing and compliance, recommendations and/or services used by the Advisor in its
investment decision-making process; interest expenses; expenses of preparing and distributing reports,
financial statements and notices to investors in the Affiliated Fund; litigation and other extraordinary
expenses; certain insurance expenses (including fees for directors’ and officers’ liability insurance); and other
expenses as may be detailed in the Affiliated Fund’s Offering Documents, investment management agreement,
prospectus and supplemental disclosure document or other governing document, as applicable.
Certain expenses (as described above) relating to the Advisor’s Affiliated Funds may be subject to an expense
cap and other expenses may not be, as set forth in the applicable Offering Documents. Generally, operating
expenses of an Affiliated Fund that are not subject to an expense cap include, but are not limited to: (i)
investment management fees, (ii) indemnification expenses, (iii) regulatory expenses arising from or relating
to new, or changes to existing laws, (iv) organizational expenses, (v) extraordinary expenses (including,
without limitation, extraordinary legal expenses), (vi) taxes, as well as any tax preparation and compliance
expenses, financial statement preparation expenses, and audit expenses, (vii) interest expense on any amounts
borrowed by an Affiliated Fund and/or its underlying investment vehicles, whether directly or indirectly, and
any other fees and/or expenses associated with such borrowing and use of any credit facilities, and (viii)
transactional expenses (including, without limitation, brokerage commissions, clearing and settlement
charges, execution platform fees, custodial fees, bank service fees and interest expenses). As set forth in the
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Affiliated Funds’ Offering Documents, the Affiliated Funds will reimburse the Advisor for all or a portion of
expenses (subject to an expense cap, if applicable) that the Advisor bears on behalf of the Affiliated Funds. It
is important that investors refer to the relevant Offering Documents for a complete understanding of fees and
expenses they will indirectly bear through an investment in an Affiliated Fund. The information contained
herein in this Item 5 is a summary only and is qualified in its entirety by such Offering Documents of an
Affiliated Fund.
The Advisor and its IARs expect to recommend the inclusion of the Advisor’s Affiliated Funds to certain
qualified Clients for a portion of their overall asset allocations, even when there may be other third-party
solutions available to meet the Client’s investment objectives. To the extent a Client invests in any Affiliated
Fund managed by the Advisor, the Client will ordinarily bear both the investment management fee to which
the Affiliated Funds are subject in addition to the Advisor’s investment advisory fee and Platform Fee (just as
the Client bears the management fee charged by managers of third-party funds in which the Client invests).
The inclusion of the Advisor’s Affiliated Funds in a Client’s portfolio will increase the overall fees payable
by the Client to the Advisor. This creates a conflict of interest as the Advisor has an incentive to recommend
an Affiliated Fund to a Client based on its interest in receiving additional advisory fees.
Cash Positions
The Advisor treats cash as an asset class. As such, unless determined to the contrary by LinePoint, all cash
positions (e.g., money markets, etc.) shall be included as part of assets under management for purposes of
calculating LinePoint’s advisory fee and Platform Fee. In addition, while assets are maintained in cash, such
amounts could miss market advances. Depending upon current yields, at any point in time, LinePoint’s
advisory fee and Platform Fee could exceed the interest paid by the Client’s cash positions.
Valuation
LinePoint generally relies on the prices provided directly to it by account custodians. Custodians, in turn,
generally rely on prices provided by reputable, independent third parties.
If LinePoint references private investments and/or private funds owned by the Client on any supplemental
account reports prepared by LinePoint, the values for all such private investments and/or private funds shall
generally reflect the initial purchase, the most recent valuation provided by the fund sponsor or the fund
administrator and for reported purposes, or contributions and distributions occurring since the most recent
valuation from the administrator (adjusted value). In some cases, the most recent valuations may not be
provided until several months after quarter end and they will typically be unaudited. If the valuation reflects
the initial purchase price and/or a value as of a previous date, the current values to the extent ascertainable
could differ significantly from the original purchase price. LinePoint’s role relative to unaffiliated private
funds and/or private direct investments is limited to its initial and ongoing due diligence and investment
monitoring services. If a Client is invested in a private fund and/or private direct investment, the amount of
assets held in the private fund and/or private direct investment shall be included in the Client’s investment
advisory fee and the calculation of LinePoint’s Platform Fee. LinePoint’s advisory fee and Platform Fee are
in addition to the private investment fund fees and any expenses charged with respect to a private direct
investment. For certain private investments and/or private funds that are being held in a Client custody or
brokerage account, LinePoint shall calculate its fee based upon the latest value provided by such custodian at
the time of billing. If such private investments and/or private funds are not being held in a Client custody or
brokerage account, LinePoint shall calculate its fee based upon the latest value provided by the fund sponsor
or administrator, as applicable.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 12
Custodians may be unable to price certain securities or may assign prices that do not reflect current market
conditions. In the normal course of providing investment advisory services to Clients, LinePoint will assess
the prices assigned by custodians and other sources.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 13
Item 6 – Performance-Based Fees and Side-By-Side Management
LinePoint Investments GP, LLC (“LinePoint GP”), the relying investment adviser of LinePoint, charges
Affiliated Funds of the Advisor performance-based fees (as discussed in Item 5 of this brochure and disclosed
in the Offering Documents relating to the Affiliated Funds) in addition to management fees received for
managing such Affiliated Funds. The Advisor structures any performance-based fee arrangement to comply
with the Advisers Act, including Rule 205-3 thereunder.
As of the date of this Disclosure Brochure, the Advisor currently has no other performance-based fee
arrangements (i.e., a fee based on a share of capital gains or capital appreciation of a Client’s assets) with
Clients besides its performance-based fees charged to its Affiliated Funds.
Clients and investors should understand that the receipt of performance-based fees creates a conflict of interest
as the Advisor has the potential to receive higher compensation. Performance-based fees create an incentive
for the Advisor to make investments that are riskier or more speculative than might otherwise be the case in
the absence of such arrangement. Additionally, the Advisor has an incentive to favor and devote more time
and effort to managing investments when there is a potential for receipt of performance-based fees. In
allocating investments, the Advisor has an incentive to favor Affiliated Funds with higher potential for
performance-based fees / carried interest distributions over Affiliated Funds with lower potential for
performance-based fees / carried interest.
As explained in Item 11 below, the Advisor seeks to mitigate these conflicts through disclosures in this
Disclosure Brochure, additional disclosures in the applicable Offering Documents, and the Advisor’s Code of
Ethics and policies and procedures contained in its SEC compliance manual.
In the future, the Advisor may establish additional related private investment funds, or may, in its discretion,
enter into performance-based fee arrangements with other Clients subject to compliance requirements under
the Advisers Act applicable to these types of compensation structures. In these arrangements, Clients may pay
a performance-based fee in addition to, or in lieu of, an asset-based fee.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 14
Item 7 – Types of Clients
LinePoint offers investment advisory services to individuals, high net worth individuals, families, family
offices, trusts, estates, businesses, charitable organizations, and pooled investment vehicles (each referred to
as a “Client” or collectively as “Clients”). A description of the assets under management of LinePoint
attributable to each type of Client is available on LinePoint’s Form ADV Part 1A. These amounts may change
over time and are updated at least annually by the Advisor. LinePoint generally does not impose a minimum
relationship size.
Affiliated Private Fund
The Advisor provides investment advisory services to its Affiliated Funds through an investment management
agreement entered into by and between the Advisor and the Affiliated Funds. For the avoidance of any doubt,
such Affiliated Funds are considered Clients of the Advisor. Any investment in an Affiliated Fund made on
the basis of information inconsistent with or not contained in the Offering Documents provided to the
prospective investors will be at the sole risk of the investor. Prospective Affiliated Fund investors are required
to complete a subscription agreement, which will require disclosure of certain private information required to
substantiate the investor’s identity and investment qualifications.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 15
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
The Financial Advisor responsible for the Client relationship determines and directs the investment approach
and investment strategies, which are based on the client’s financial objectives and subject to LinePoint’s
supervision and compliance requirements. The Financial Advisor may allocate the assets of a Client’s
portfolio among various asset classes, including, but not limited to, cash/cash equivalents, equities (e.g., large-
cap, small/mid-cap, domestic and international), fixed income (e.g., investment grade, high yield, municipal,
domestic and international), and private fund investments (e.g., hedge funds, private credit, private equity and
venture capital funds), among others. Financial Advisors may also recommend specific types of investments
for a Client’s portfolio, including common stocks, bonds, various types of pooled investment vehicles
including, but not limited to, ETFs, mutual funds and limited partnerships. Certain risks associated with these
types of investments are described below. Efforts by the Financial Advisor to invest in a diversified asset
allocation do not ensure a profit or protect against a loss. Investing involves risk, including loss of principal.
The investment styles, philosophies, strategies, techniques and methods of analysis that LinePoint and its
Financial Advisors use in formulating investment advice for Clients vary widely. Investment strategies and
advice will vary depending on each Client’s financial situation, objectives, risk tolerance, time horizon,
financial information, liquidity needs and other factors. Brief descriptions of commonly used strategies and
certain of the risks associated with such strategies are provided below.
With respect to the Advisor’s Affiliated Funds, the Advisor utilizes a variety of methods and strategies to
make investment decisions and recommendations on behalf of its Affiliated Funds that are set out in the
relevant Offering Documents. On behalf of the Affiliated Funds, the Advisor implements a diversified range
of alternative investment strategies that typically invest into external unaffiliated private fund vehicles and/or
entities that are managed by third-party asset managers or sponsors. The different series (or classes) of
interests administered in the Advisor’s Affiliated Fund will have different participation in these alternative
investment strategies. The investment objective and strategies with respect to each series (or class) of interests
administered in the Advisor’s Affiliated Fund are set out in the relevant Offering Documents.
Material Risks Involved
Investing in securities involves risk of loss that Clients should be prepared to bear. All investments in securities
and other financial investments involve substantial risk of volatility arising from numerous factors that are
beyond the control of the Advisor and investment managers utilized by the Advisor and its IARs, including
market conditions, changing domestic or international economic or political conditions, changes in tax laws
and government regulation, and other factors.
The following is a summary of the material risks associated with the Advisor’s investment activities. The
summary below does not purport to be a comprehensive discussion of all the risks associated with the
Advisor’s activities or underlying investments held by a Client. Investors in any of the Advisor’s Affiliated
Funds should review the Affiliated Fund’s Offering Documents for a description of the risks associated with
the specific Affiliated Fund and its underlying investment strategy(ies).
Market Risks: The value of a Client’s holdings may fluctuate in response to events specific to companies or
markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the
performance of the overall financial markets.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 16
Asset Allocation: Investment performance will depend largely on the Advisor’s decisions as to strategic asset
allocation and tactical adjustments made to the asset allocation. At times, the Advisor’s judgments as to the
asset classes in which Clients should invest may prove to be wrong, as some asset classes may perform worse
than others or the equity markets generally from time to time or for extended periods of time.
Multiple Managers: The Advisor generally uses a “manager-of-managers” approach in allocating Client
assets. The Advisor will invest Client assets with investment managers who make their trading decisions
independently. It is possible that one or more investment managers may take investment positions that are
opposite of positions taken by other investment managers. Some investment managers may have overlapping
strategies or portfolios and thus could accumulate large positions in the same or related instruments at the
same time. The Advisor may not have access to information regarding the underlying investments made by
the investment managers or investment funds and thus may not be able to mitigate the associated risks of
concentration or exposure to specific markets or strategies. Because each investment manager will trade
independently of the others, the trading losses of some investment managers could offset trading profits
achieved by other investment managers. In addition, investment managers may compete with each other for
similar positions at the same time.
Activities of Unaffiliated Investment Managers and Investment Funds: The Advisor will have no control
over the day-to-day operations of any unaffiliated investment fund or investment manager. As a result, there
can be no assurance that every investment fund or investment manager will invest on the basis expected by
the Advisor. Furthermore, because the Advisor will have no control over any investment fund or investment
manager day-to-day operations, Clients may experience losses due to the fraud, poor risk management, or
recklessness of the investment funds or the investment managers.
Equity Securities: Common stocks and other equity securities generally increase or decrease in value based
on the earnings of a company and on general industry and market conditions. The value of a company’s share
price may decline as a result of poor decisions made by management, lower demand for the company’s
services or products or if the company’s revenues fall short of expectations. There are also risks associated
with the stock market overall; in particular, the stock market may experience periods of turbulence and
instability.
Fixed Income Securities: A bond’s market value is affected significantly by changes in interest rates –
generally, when interest rates rise, the bond’s market value declines and when interest rates decline, its market
value rises. Generally, a bond with a longer maturity will entail greater interest rate risk but have a higher
yield. Conversely, a bond with a shorter maturity will entail less interest rate risk but have a lower yield. A
bond’s value may also be affected by changes in its credit quality rating or the issuer’s financial condition.
Emerging Markets: Investment in the securities of issuers based in emerging markets involves a greater
degree of risk than an investment in securities of issuers based in more developed countries. When compared
to investments in securities in more developed countries, emerging market securities investments may carry
the risks of less publicly available information, more volatile markets, less strict securities market regulation,
less favorable tax provisions, and a greater likelihood of severe inflation, unstable or not freely convertible
currency, and war, corruption and expropriation of personal property, among other considerations. In addition,
investment opportunities in certain emerging markets may be restricted by legal limits on foreign investment
in local securities.
ETF and Mutual Fund Risk: When investing in an ETF or mutual fund, the Client will bear additional
expenses based on their pro rata share of the ETF or mutual fund’s operating expenses, including the potential
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 17
duplication of management fees. The risk of owning an ETF or mutual fund reflects the risks of owning the
underlying securities the ETF or mutual fund holds. The Client may also incur brokerage costs when
purchasing ETFs.
Structured Notes: Structured notes are securities issued by financial institutions whose returns are based on,
among other things, equity indexes, a single equity security, a basket of equity securities, interest rates,
commodities, and/or foreign currencies. Thus, returns are “linked” to the performance of a reference asset or
index. Structured notes have specific risks that include market risk, an issuance price that is likely higher than
the fair value of the note on the date of the issuance, liquidity risk, credit risk, call risk, and a complicated
payoff structure.
Risks Associated with Investing in Private Funds: Clients should be aware that an investment in a private
fund (whether an affiliated fund with LinePoint or an unaffiliated private fund) involves a high degree of risk
and illiquidity. There can be no assurance that a private fund’s investment objective will be achieved or that
an investor will receive a return of its capital. Investing in securities involves risk of loss that Clients should
be prepared to bear as well as limited access to their respective invested assets in the private funds due to
certain lock-up periods applied to such private funds. For further information, please refer to the private fund’s
respective offering and governing documents.
Illiquid Securities; Special Investments: LinePoint or a Financial Advisor may allocate to securities or other
assets that are not readily marketable, including private investment funds, securities of private companies,
certain other derivatives or customized structured products. LinePoint or the Financial Advisor may find it
difficult to readily dispose of illiquid investments in the ordinary course of business.
Options: Options can be highly volatile investments and involve special risks. Successful investment
strategies using options require the ability to predict future movements in securities prices, interest rates and
other economic factors. LinePoint or a Financial Advisor’s efforts to use options (even for hedging purposes)
may not be successful. Options utilized in a Client’s account may be based on any type of security, index or
currency, including options traded on foreign exchanges and options not traded on exchanges. If such
investment manager applies a hedge at an inappropriate time or judges market conditions incorrectly, options
strategies may reduce a Client’s return. A Client may also experience losses if the prices of option positions
were to be poorly correlated with its other investments, or if it could not close its positions because of an
illiquid secondary market.
Futures Contracts: Trading in futures contracts is a highly specialized activity which may involve substantial
risks. Futures contract prices are highly volatile. Price movements for contracts are influenced by, among
other things: changing supply and demand relationships; weather; agricultural, trade, fiscal, monetary and
exchange control programs and policies of governments; various economic indices; political and economic
events and policies; changes in interest rates and rates of inflation; currency devaluations and revaluations;
and emotions of the marketplace. The low margin or premiums normally required in such trading may provide
a large amount of leverage, and a relatively small change in the price of a security or contract can produce a
disproportionately larger profit or loss. There is no assurance that a liquid secondary market will exist for
commodity futures contracts or options purchased or sold. Futures positions may be illiquid because, for
example, most U.S. commodity exchanges limit fluctuations in certain futures contract prices during a single
day (or part thereof) by imposing what are known as “daily price fluctuation limits” or “daily limits.” The
price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock
index.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 18
Other Instruments: LinePoint or a Financial Advisor may take advantage of opportunities with other
derivative instrument such as swaps, options on various underlying instruments and other customized
“synthetic” or derivative instruments which will be subject to varying degrees of risk.
Economic Conditions: Changes in economic conditions, including, for example, interest rates, inflation rates,
currency and exchange rates, industry conditions, competition, technological developments, trade
relationships, political and diplomatic events and trends, tax laws and innumerable other factors, can affect
substantially and adversely the investment performance of a Client’s account. None of these conditions is or
will be within the control of LinePoint or a Financial Advisor, and no assurances can be given that LinePoint
or a Financial Advisor will anticipate these developments.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 19
Item 9 – Disciplinary Information
There are no legal or disciplinary events that would be material to a Client and investor, or prospective Client
and investor, evaluation of the advisory business of LinePoint or the integrity of its management.
The Advisor encourages Clients to perform the requisite due diligence on any Financial Advisor or service
provider that the Client engages. The backgrounds of the Advisor and its IARs are available on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or
CRD# 332598.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 20
Item 10 – Other Financial Industry Activities and Affiliations
Clients should review the Financial Advisor Brochure Supplement (as defined in Item 4 – Advisory Business
of this Disclosure Brochure) to determine whether the Client’s IAR is engaged in any activities that may create
a conflict of interest. If the Client did not receive the Financial Advisor Brochure Supplement, the Client
should contact the Advisor’s Chief Compliance Officer using the information in Item 2 of this Disclosure
Brochure. The Chief Compliance Officer is available to address any questions a Client or prospective Client
may have regarding any potential conflicts of interest or any other information outlined in this Disclosure
Brochure.
LinePoint GP (LinePoint Investments GP, LLC) is a relying investment adviser of the Advisor and serves as
the general partner to Affiliated Funds. The Advisor and LinePoint GP share the same office space and are
held under common ownership and control. Supervision and oversight for both the Advisor and LinePoint GP
are performed by executive officers of the Advisor. All employees of the Advisor and LinePoint GP are subject
to the same SEC policies and procedures and Code of Ethics. Additionally, all employees of the Advisor and
LinePoint GP are subject to the same requirements for pre-clearance to participate in any initial public offering
(“IPO”), limited offering or private offering.
Certain managers, officers and employees of the Advisor may serve as directors, officers, and employees of
for-profit and non-profit businesses subject to the Advisor’s approval.
Robertino S. Coury, Santino G. Coury, and Daniel T. Cole (LinePoint’s Chief Financial Officer) are executive
officers of E’O Management, LLC, a family office (as defined by Advisers Act) responsible for exclusively
managing the assets of the Coury Family (referred to herein as “Coury Family Office” or “EOM”). Robertino
S. Coury and Santino G. Coury are also managers (similar to a director) of EOM. Juliano C. Coury and Andreo
V. Coury are employees of the Coury Family Office. Robertino S. Coury also serves as an officer and director
of The Robert J. Coury Family-Mylan Foundation, as trustee on family-related trusts, and as a member of the
board of directors of BridgePort Financial Technology.
LinePoint and the Coury Family Office share certain administrative services, office, personnel, and
infrastructure and systems. LinePoint has an expense sharing agreement in place with EOM. EOM serves as
the pay master and administrative services entity for LinePoint. All employees are employed through EOM
and provide services to LinePoint through the expense sharing agreement. Other infrastructure such as the
office lease, supplies, insurance, furniture and equipment, etc. is owned by EOM. EOM operates as a “family
office” exempt from registration under Advisers Act, and does not engage in the business of providing
investment advisory services to anyone other than eligible family clients, as defined in the Advisers Act.
Certain principals, directors, officers, partners, managers, shareholders, and employees, as applicable, will not
be devoting their time exclusively to the management of the Advisor and/or Client accounts. Therefore, each
of these persons will have conflicts of interest in allocating management time, services, and functions among
the various entities and accounts for which they provide services.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 21
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
LinePoint has a Code of Ethics (the “Code of Ethics”) which requires LinePoint’s personnel (“Supervised
Persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Advisor’s Clients.
Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest,
outside business activities, gifts and entertainment, compliance with insider trading laws and policies and
procedures governing personal securities trading by Supervised Persons.
Personal securities transactions of Supervised Persons present conflicts of interest in that a Supervised Person
may be able to buy or sell a security in advance of executing the same transaction for a Client account, or may
be able to obtain a more favorable price for such a security. The Code of Ethics addresses these conflicts by
prohibiting securities trades that would breach a fiduciary duty to a Client and requiring, with certain
exceptions, Supervised Persons to report their personal securities holdings and transactions to LinePoint for
review by the Advisor’s Chief Compliance Officer. The Code of Ethics also requires Supervised Persons to
obtain pre-approval of certain investments, including initial public offerings and limited offerings.
LinePoint will provide a copy of the Code of Ethics to any Client, prospective client, or investor upon request.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 22
Item 12 – Brokerage Practices
LinePoint does not maintain discretionary authority to select a broker-dealer/custodian for custody and
execution services on a Client’s behalf. While LinePoint and its Financial Advisors may recommend a
custodian to Clients, Clients are not obligated to follow their recommendation. It is the Client’s decision as to
where they custody their assets. If a Client chooses to custody their assets at a custodian other than as
recommended by LinePoint and its Financial Advisors, the Advisor and its Financial Advisor could be limited
in the services it can provide if the recommended custodian is not engaged.
LinePoint is not affiliated with any company that it refers Clients to for custody and/or brokerage services.
Examples of companies that LinePoint may refer Clients to for custodian and brokerage services include, but
are not limited to, Northern Trust Company, and Folio Investments, Inc. d/b/a Goldman Sachs Custody
Solutions together with Goldman Sachs & Co. LLC.
Some factors that LinePoint considers in recommending a broker-dealer/custodian to Clients include historical
relationship with LinePoint, financial strength, reputation, execution capabilities, pricing, research, and
service. To the extent that a transaction fee is payable, LinePoint has a duty to obtain best execution for such
transaction. However, that does not mean that the Client will not pay a transaction fee that is higher than
another qualified broker-dealer might charge to affect the same transaction where LinePoint determines, in
good faith, that the transaction fee is reasonable. In seeking best execution, the determinative factor is not the
lowest possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a broker-dealer’s services, including the value of research provided, execution
capability, transaction rates, and responsiveness. Accordingly, although LinePoint will seek competitive rates,
it may not necessarily obtain the lowest possible rates for Client account transactions.
Soft Dollar Arrangements and Other Benefits
Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an
agreement to place security trades with a broker-dealer/custodian in exchange for research and other services.
LinePoint does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian.
Custodians that LinePoint recommends to its Clients may also provide certain services that may benefit the
Advisor and its business in general, rather than benefit specific Clients. Such benefits include, but are not
limited to, sharing in Advisor recruitment expenses and other business growth initiatives; and payment directly
to vendors supporting the Advisor’s business including research providers, trade administration, portfolio
accounting systems, supporting LinePoint’s management of Client assets.
LinePoint receives products and services from firms providing custodial services that benefit LinePoint but
may not benefit all Clients. These services are typically offered to all investment advisers working with the
custodian and do not have a specific cost tied to the benefit. Some of these products and services assist
LinePoint in managing and administering Client accounts. These products and services include software and
other technology that provide access to Client account data (such as trade confirmations and account
statements); services that facilitate trade execution (and allocation of aggregated trade orders for multiple
Client accounts, if applicable); research, pricing information and other market data; products and services that
facilitate payment of LinePoint’s fees from its Client accounts; assistance with back office functions,
recordkeeping and Client reporting; receipt of duplicate account statements and confirmations; research
related products and tools; consulting services; access to a trading desk serving LinePoint’s participants;
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 23
access to block trading (which provides the ability to aggregate securities transactions for execution and then
allocate the appropriate shares to Client accounts); the ability to have advisory fees and Platform Fees
deducted directly from Client accounts; access to an electronic communications network for Client order entry
and account information; access to mutual funds with no transaction fees and to certain institutional money
managers; and discounts on compliance, marketing, research, technology, and practice management products
or services provided to LinePoint by third party vendors. Generally, many of these services may be used to
service all or a substantial number of Client accounts.
While, as a fiduciary, LinePoint seeks to act in its Clients’ best interests, LinePoint’s recommendation that
Clients maintain their assets in accounts at a particular custodian may be based in part on the benefit to
LinePoint, including the availability of some of the foregoing products and services and not solely on the
nature, cost, or quality of custody and brokerage services provided. This may benefit LinePoint more than
individual Clients. LinePoint may have an incentive to select or recommend a broker-dealer/ custodian based
on its interest in receiving these benefits, rather than the Client’s interest in receiving the most favorable
execution. It is possible that Clients would pay lower commissions by using a broker-dealer that does not
provide any benefit to LinePoint. A conflict of interest exists when the services provided by the custodian are
based on the amount of Client assets that LinePoint maintains with the third-party service provider. To address
this conflict, LinePoint will not compromise its best execution and fiduciary responsibility to its Clients.
Brokerage for Client Referrals
LinePoint does not receive any compensation from any third party in connection with the recommendation
for establishing an account.
Client-Directed Brokerage
Generally, in the absence of specific instructions to the contrary, for brokerage accounts that Clients engage
LinePoint to manage on a discretionary basis, LinePoint has full discretion with respect to securities
transactions placed in the accounts. This discretion includes the authority, without prior notice to the Client,
to buy and sell securities for the Client’s account and establish and affect securities transactions through the
custodian of the Client’s account or other broker-dealers selected by LinePoint. In selecting a broker-dealer
to execute a Client’s securities transactions, LinePoint seeks prompt execution of orders at favorable prices.
The Advisor generally does not accept directed brokerage arrangements, but may consider exceptions on a
case-by-case basis. A directed brokerage arrangement arises when a Client requires that account transactions
be affected through a specific broker-dealer/custodian, other than one generally recommended by LinePoint.
In such Client directed arrangements, the Client will negotiate terms and arrangements for their account with
that broker-dealer, and the Advisor will not seek better execution services or prices from other broker-dealers.
As a result, a Client could pay higher commissions or other transaction costs or greater spreads, or receive
less favorable net prices, on transactions for the account than would otherwise be the case.
Trade Aggregation
Orders for the same security entered on behalf of more than one Client managed by the same IAR may be
aggregated (i.e., blocked or bunched) to reduce transaction costs, subject to the aggregation being: (i) in the
best interest of each Client participating in the order; (ii) consistent with LinePoint’s duty to obtain best
execution; and (iii) consistent with the terms of the advisory agreement of each participating Client. All Clients
participating in an aggregated order will receive the average price. The aggregation practices of any third-
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 24
party managers or sub-advisors that are recommended are disclosed in the respective third-party manager/sub-
advisors disclosure documents.
Best Execution
LinePoint and its Financial Advisors maintain a fiduciary duty to seek the best execution pricing available for
Client transactions. While best execution is difficult to define and challenging to measure, there is some
consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it is a
collective consideration of factors concerning the trade in question. Such factors include the security being
traded, the price of the trade, the speed of the execution, apparent conditions in the market and the specific
needs of the Client. LinePoint's primary objective when placing orders for the purchase and sale of securities
for Client accounts is to obtain the most favorable net results taking into account such factors as price, size of
order, difficulty of execution and broker skill. Based on these criteria, the firm may not necessarily pay the
lowest commission or commission equivalent, as specific transactions can involve specialized services on the
part of the broker.
Trade Errors
Occasionally, a trade error can occur where either LinePoint, or its IAR, are at fault for affecting one or more
erroneous securities transactions. If this occurs, the error will be corrected and the Client account will be made
whole, if such trading error resulted in a loss to the Client’s account. Neither losses nor gains realized will be
passed on to the Client.
Selection of Custodian / Brokers
Although Clients are not obligated to use the Advisor’s recommended custodian(s), the Advisor could be
limited in the services it can provide if the recommended custodian is not engaged. Clients typically provide
LinePoint with the discretion to select the broker-dealer for execution of securities transactions. LinePoint
determines the securities to be bought or sold, the price, the timing, and the selection of broker-dealer it
believes can provide best execution of Client transactions. The Financial Advisor will direct transactions to
designated broker-dealers based on their execution capabilities; however, the use of a designated broker may
or may not always allow LinePoint to obtain the best price and execution of portfolio transactions. While
LinePoint believes the broker-dealer it has selected will provide the best execution and services, it is possible
that better execution may be obtained through another broker-dealer. LinePoint may be incentivized to trade
with a certain broker-dealer regardless of execution quality to avoid incurring the charges that may accompany
trading with other broker-dealers.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
Page 25
Item 13 – Review of Accounts
LinePoint monitors investment advisory portfolios as part of a continuous and ongoing process. Financial
Advisors generally have at least one annual meeting with each Client to conduct a formal review of the Clients’
account(s). Factors that may trigger an additional review, other than a periodic review, include material
market, economic or political events, known significant changes in a Client’s financial situation and/or
objectives, and large deposits or withdrawals from the accounts. Clients are encouraged to notify LinePoint
and their respective Financial Advisor if changes occur in the Client’s personal financial situation that might
adversely affect the Client’s investment plan.
Other Reviews
LinePoint may perform compliance and/or supervisory reviews of a sampling of Client accounts. Examples
of reviews that LinePoint may perform include comparing an account’s strategy and/or allocation to the
account’s stated objectives, reviewing commission and transaction costs borne by the account, and reviewing
the billing rate and charges.
Review Reports
Each Client will receive written statements from their custodian that detail the Client’s positions and activity.
Financial Advisors may also provide their Clients with periodic performance reports, which may show
performance across multiple accounts within a household. Clients are advised to regularly compare any
performance reports provided by Financial Advisors with the statements issued by their qualified custodians,
which are the official records of the accounts, to ensure accuracy and consistency.
For LinePoint’s Affiliated Funds, reporting to underlying investors will be outlined in the Affiliated Fund
Offering Documents.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Item 14 – Client Referrals and Other Compensation
Generally, Financial Advisors are compensated through LinePoint as a percentage of the advisory fee charged
to the Clients’ accounts.
LinePoint and its Financial Advisors refer various unaffiliated, non-advisory professionals (e.g., attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients.
Likewise, LinePoint and its Financial Advisors may receive non-compensated referrals of new Clients from
various third parties.
Economic Benefits Provided by Third Parties for Advice Rendered to Clients
LinePoint may receive referral payments from banks and other financial institutions as applicable for referring
Clients to use their products and services. This includes bank loans, asset backed securities loans, financial
and other such type loans, etc. These payments may be in the form of a one-time payment or ongoing trials.
These referral payments create a conflict of interest because a Financial Advisor may direct a Client to one
firm over another in order to receive such payments. LinePoint mitigates this conflict on such
recommendations and referrals by disclosure in this Disclosure Brochure.
LinePoint may recommend or require that Clients establish brokerage accounts with certain qualified
custodians to maintain custody of Clients’ assets and to effect trades for their accounts. The final decision to
custody assets with a qualified custodian(s) is at the discretion of the Client, including those accounts under
ERISA or IRA rules and regulations, in which case the Client is acting as either the plan sponsor or IRA
accountholder. LinePoint is independently owned and operated and not affiliated with any qualified
custodians. Certain qualified custodians as applicable, provide LinePoint with access to its institutional trading
and custody services, which are typically not available to their retail investors. These services generally are
available to independent investment advisors on an unsolicited basis, at no charge to advisors. Services
provided to LinePoint from a qualified custodian may include, but are not limited to, brokerage services that
are related to the execution of securities transactions, custody, research, including that in the form of advice,
analyses and reports, and access to mutual funds and other investments that are otherwise generally available
only to institutional investors or would require a significantly higher minimum initial investment.
Compensation for Client and/or Financial Advisor Referrals
LinePoint may pay referral fees to independent persons or firms (i.e., solicitors / promotors) for introducing
clients or financial advisors to LinePoint. All such arrangements are consistent with the rules under the
Advisers Act as well as individual state requirements, including, without limitation, documenting such
arrangement in a written agreement and providing certain disclosures to referral prospects/clients. Recruiting
financial advisors from other firms creates a conflict of interest for LinePoint because compensation received
as a result of Clients following their financial advisor to LinePoint induces LinePoint to recruit financial
advisors without regard to the comparative benefits Clients receive at other financial firms.
Other Cash and Non-Cash Compensation
Financial Advisors of LinePoint may receive promotional items of nominal value, meals or entertainment or
other non-cash compensation from representatives of asset managers / third party money managers, mutual
fund companies, and other investment products, as permitted by regulatory rules.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Financial Advisor Transition Assistance Benefits
When an IAR associates with LinePoint after working with another financial services firm, the IAR can
receive recruitment or transition compensation from LinePoint in connection with the transition. This
transition assistance includes payments that are intended to assist an IAR with certain defined costs associated
with the transition; however, LinePoint does not verify that any payments made are used for transition costs.
LinePoint incentivizes Financial Advisors when a Financial Advisor joins as a recruit, through various
economic arrangements which can include an upfront signing bonus in the form of a forgivable or non-
forgivable loan. When and if a loan is paid, the amount is typically based on the expected revenue that the
new Financial Advisor will generate after joining LinePoint. The bonus paid is individually negotiated
between the new Financial Advisor and LinePoint.
Compensation considerations based on the percentage of Clients who transfer their business to LinePoint, or
the anticipated revenue that is expected to be generated from Clients who transfer, raises conflicts of interest,
including the concern that the Financial Advisor has an incentive to recommend that Clients transfer their
assets to LinePoint over another investment adviser.
Recruiting and Transition Expenses
As a part of LinePoint’s business, the Advisor may hire outside parties (recruiters) to help find investment
adviser representatives interested in joining LinePoint. The recruiters are typically paid a fee based on a
percentage of the total revenue of the investment adviser representatives book of business or business referred
to LinePoint. At times, others may contribute to the recruiting expense LinePoint might incur, including
custodians of Client assets. When a third-party custodian contributes to the recruiting expense, it presents a
conflict of interest, as LinePoint has an incentive to refer the Client to the third-party custodian sharing the
cost of the recruitment expense.
Referrals to Service Providers
LinePoint may refer Clients to third parties that offer services to support Client financial needs. In such
arrangements, LinePoint has a conflict of interest in that LinePoint will receive a fee payment for the referral
of the Client by LinePoint. Clients are under no obligation to engage the services of third party service
providers or vendors recommend by LinePoint.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Item 15 – Custody
LinePoint’s investment advisory agreement with Clients and/or the Clients’ separate agreement with the
custodian may authorize LinePoint through such custodian to debit the Client’s account for LinePoint’s fee(s)
and to directly remit that fee(s) to LinePoint in accordance with applicable custody rules. For this reason,
LinePoint is considered to have custody of Client assets through its ability to debit its fees (i.e., investment
advisory fees and Platform Fees) from Client accounts.
A custodian recommended by LinePoint will send a statement to the Client, at least quarterly, indicating all
amounts disbursed from the account including the amount of advisory fees and Platform Fees paid directly to
LinePoint. LinePoint encourages Clients to review the official statements provided by the custodian, and to
compare such statements with investment reports received from LinePoint. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor
may have custody of those assets. To avoid additional regulatory requirements, the applicable custodian and
the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with
the Client’s instructions.
LinePoint’s Affiliated Funds generally receive financial statements audited by an independent certified public
accountant as of the end of its fiscal year. The audited financial statements will be prepared in accordance
with generally accepted accounting principles (GAAP) and copies are furnished to each investor within 180
days of the Affiliated Funds’ fiscal year end.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Item 16 – Investment Discretion
Clients have the option of providing LinePoint with investment discretion on their behalf, pursuant to a grant
of a limited power of attorney contained in LinePoint’s investment advisory agreement with a Client. By
granting LinePoint investment discretion, a Client authorizes LinePoint to direct securities transactions and
determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which
the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints
on any of these areas of discretion with the consent and written acknowledgement of LinePoint.
LinePoint provides discretionary advisory services to its Affiliated Funds. Any limits to the Advisor’s
authority and other specifications related to managing its Affiliated Funds are included in the investment
management agreement between LinePoint and its Affiliated Fund(s).
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Item 17 – Voting Client Securities
LinePoint does not typically accept the authority to and does not vote proxies on behalf of Clients. Clients
retain the responsibility for receiving and voting proxies for all and any securities maintained in Client
portfolios. In the event that LinePoint is inadvertently assigned proxy voting authority on a Client’s custodial
account, it will take steps to have the instructions modified so that the Client is responsible for voting any
such proxies.
If applicable, LinePoint does have the authority to vote proxies on behalf of its Affiliated Funds. The Advisor
will vote each proxy in accordance with its fiduciary duty. The Advisor will seek to vote proxies in a way that
maximizes the value of the Affiliated Fund’s assets and in a manner that is consistent with management
recommendations except in certain specific situations where the Advisor determines that the management
recommendation is not consistent with the Affiliated Fund’s interests. The Advisor may abstain from voting
if it deems that abstaining is in the Affiliated Fund’s best interests.
Any questions regarding LinePoint’s proxy voting policy with respect to its Affiliated Funds or requests for a
description of the Advisor’s proxy voting policy should be directed to LinePoint’s Chief Compliance Officer.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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Item 18 – Financial Information
LinePoint does not require prepayment of more than $1,200 in fees per Client, six months or more in advance.
Therefore, LinePoint is not required to include a balance sheet in this Disclosure Brochure. Neither LinePoint
nor its management has any financial conditions that are reasonably likely to impair its ability to meet
contractual commitments to Clients. Additionally, LinePoint has not been the subject of a bankruptcy petition
during the past ten years.
End of section.
LinePoint Partners & Co., LLC – Form ADV Part 2A
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