Overview
Assets Under Management: $689 million
High-Net-Worth Clients: 69
Average Client Assets: $11 million
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles
Fee Structure
Primary Fee Schedule (SCOTT CAPITAL PARTNERS LLP FORM ADV PART 2A 18 JUNE 2025)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 0.80% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,000 | 0.80% |
| $5 million | $40,000 | 0.80% |
| $10 million | $80,000 | 0.80% |
| $50 million | $400,000 | 0.80% |
| $100 million | $800,000 | 0.80% |
Clients
Number of High-Net-Worth Clients: 69
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 99.82
Average High-Net-Worth Client Assets: $11 million
Total Client Accounts: 202
Discretionary Accounts: 201
Non-Discretionary Accounts: 1
Regulatory Filings
CRD Number: 332026
Last Filing Date: 2024-09-25 00:00:00
Website: https://scottcp.com
Form ADV Documents
Primary Brochure: SCOTT CAPITAL PARTNERS LLP FORM ADV PART 2A 18 JUNE 2025 (2025-06-18)
View Document Text
BROCHURE/Form ADV Part 2A
18 June 2025
CRD No: 332026
SEC File No: 801-131114
This Brochure provides information about the qualifications and business practices of Scott Capital Partners LLP. If you have questions
about the contents of this Brochure, please call us at the number above or e-mail us at info@scottcp.com. The information in this Brochure
has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or any U.S. state or foreign securities authority.
Registration does not imply that we have attained a certain level of skill or training.
Additional information about us is available on the SEC’s website at www.adviserinfo.sec.gov.
This Brochure is intended only for our U.S. resident prospects or clients.
Form ADV Part 2A
18 June 2025, page 1 of 9
Scott Capital Partners LLP 24 St James’s Square London SW1Y 4JHTel. +44 (0)204 574 2828 Web. scottcp.comSCOTTCAPITAL PARTNERS
Item 2. Material Changes
This Brochure is being filed with the SEC as our first annual amendment since we became registered with the SEC and for the fiscal year
ending 31 March 2025.
On 17 September 2024, we became registered as an investment adviser with the SEC.
We will continue to amend our Brochure to report material changes and annually.
Form ADV Part 2A
18 June 2025, page 2 of 9
SCOTTCAPITAL PARTNERS
Item 3. Table of Contents
Item 2. Material Changes
2
Item 3. Table of Contents
3
Item 4. Advisory Business
4
Item 5. Fees and Compensation
5
Item 6. Performance-Based Fees and Side-by-Side Management
5
Item 7. Types of Clients
5
Item 8. Method of Analysis, Investment Strategies and Risk of Loss
6
Item 9. Disciplinary Information
7
Item 10. Other Financial Industry Activities and Affiliations
7
Item 11. Code of Ethics, Participation/Interest in Client Transactions and Personal Trading
7
Item 12. Brokerage and Trading Practices
8
Item 13. Review of Accounts
8
Item 14. Client Referrals and Other Compensation
8
Item 15. Custody
9
Item 16. Investment Discretion
9
Item 17. Voting Client Securities
9
Item 18. Financial Information
9
Form ADV Part 2A
18 June 2025, page 3 of 9
SCOTTCAPITAL PARTNERS
Item 4. Advisory Business
Scott Capital Partners LLP (“SCP” “we”, “us” or the “firm”) is a United Kingdom (“UK”) based independent multi-family office providing highly
personalised investment management, family office, family governance and private market services to ultra high net worth clients.
SCP is a limited liability partnership incorporated in England and Wales and is authorised (May 2022) and regulated by the UK Financial
Conduct Authority (“FCA”) (Firm reference number 957221).
We are based in London, UK with our registered office at 24 St James’s Square, London, SW1Y 4JH.
We have 18 staff, 14 of whom are members of the LLP. Our executive team are all members of the firm and contribute capital.
We have a Management Board comprised of the executive team and one member who does not work for us day-to-day.
David Scott is our Managing Partner and Chief Executive Officer, and holds the majority ownership interest in the firm. Anna O’Shaughnessy is
our Chief Compliance and Risk Officer. Our executive team is named in our Form ADV Part 1 Schedule A.
We are owned by our members. We are proud of our independence and the ability it gives us to serve our clients in a way that best suits
them. Our independent multi-family office acts alongside our clients to manage their family’s wealth, achieving the optimal balance of
preservation, enhancement and a sense of purpose for their wealth.
For purposes of our investment management offering for “U.S. clients” (based on residence), we offer: discretionary investment management
services; non-discretionary investment management services; and occasional and non-continuous non-discretionary investment advice.
This Brochure covers specifically these three services in relation to our U.S. clients. We also offer non-investment advisory family governance
and family office services, including consolidated reporting, wealth analytics and financial strategic advisory services.
There is no minimum account size for our investment management services, as we consider all the services we provide to a client.
We offer clients the option to agree a performance fee in relation to occasional and non-continuous non-discretionary investment advice,
which is in addition to the one-off fee they pay. Such a performance fee would be based on the performance of the client’s investments as
agreed with the client. Any investment advice so involved would be based upon a portfolio of assets that is different from a portfolio on which
we provide discretionary or non-discretionary investment management services. We may only enter a performance fee agreement if the client
meets the definition of a qualified client under Rule 205-3(d)(1) of the Advisers Act. Before we start providing services to our client, we ensure
that they understand and agree with the methodology we will use to calculate the performance fee and include this in the written agreement
between us.
We do not provide custody and execution services. Clients choose the third-party custodian(s) for their investments and enter into a direct
agreement with them. The custodian(s) charge the client fees for their services.
For our discretionary or non-discretionary investment management services, each client has their own dedicated investment manager. We
gather and assesses a range of information from our clients so we can understand their investment objectives, financial situation, personal
circumstances, restrictions and willingness and ability to take risk. Based on this assessment, we develop a bespoke investment strategy for
each client.
As of the date of this Brochure, we have client assets under management (“AUM”) of $739,286,682 across our 70 clients, of which
$656,036,515 are discretionary and $83,250,167 are non-discretionary. We disclose our regulatory assets under management, which is the
same amount and is calculated in the same manner as AUM, in our Form ADV Part 1. These amounts exclude client assets where we provide
occasional and non-continuous non-discretionary investment advice.
Form ADV Part 2A
18 June 2025, page 4 of 9
SCOTTCAPITAL PARTNERS
Item 5. Fees and Compensation
We charge an annual management fee for our discretionary and non-discretionary investment management services. This is based on a
percentage of AUM. Our current fee guidelines range from 0.40% to 0.80% (based upon a percentage of AUM) and generally decrease as a
percentage of AUM as the value of AUM increases but will also depend on the specific mandate given to us by our client, including whether it
includes other multi-family office services, and the client’s circumstances. Our fees are negotiable depending on these factors.
If a client requests it, they may pay an annual flat fee for our discretionary and non-discretionary investment management services.
We agree our fees in advance with our client and set these out in the written agreement between us.
Our fees are payable quarterly in arrears on presentation of an invoice to our client. The client’s third-party custodian will, as agent for the
client, pay the fees due to us from the client’s account with them.
The third-party system that we use provides us with asset values for each client’s portfolio using the custodian’s data sources. Where the
custodian is not able to source a price for a security, the system uses data from an independent third party to determine the price. For
assets that are not priced daily, for example some funds and private market securities, the system uses the last available price provided to
us by the fund administrator (where applicable) or custodian. The third-party system also automatically calculates the fees due to us. The fee
calculation methodology is open for inspection and verification by any client and it – together with sample calculations - are audited every
year by our external auditor. It is the responsibility of our clients to review fee calculations and bring discrepancies to our attention.
Our clients may terminate their agreement with us at any time with pro rata annual management fees calculated for the relevant period based
upon the termination date.
Where we provide occasional and non-continuous non-discretionary investment advice, the client pays us a one-off fee.
Separately from our fees, clients bear costs charged by third parties, for example custody and execution fees, underlying financial instrument
costs associated with investments in funds or other investments, taxes, interest expenses, duties and other governmental charges, transfer
and registration fees, or costs associated with foreign exchange transactions. We do not receive any part of these third-party charges.
Neither we nor any of our Supervised Persons accept compensation for the sale of securities or any other investments.
Item 6. Performance-Based Fees and Side-by-Side Management
Currently we do not advise/manage assets on a performance fee basis.
Item 7. Types of Clients
We provide our three types of investment management services to high net worth clients who are individuals, trusts, family investment
vehicles and retirement accounts.
Form ADV Part 2A
18 June 2025, page 5 of 9
SCOTTCAPITAL PARTNERS
Item 8. Method of Analysis, Investment Strategies and Risk of Loss
Investment Philosophy and Approach
We develop and agree with each client a suitable strategic asset allocation and investment strategy based on their financial situation, investment
objectives, liquidity needs, restrictions, and willingness and ability to bear risk, and our view of future medium to long-term global trends.
We develop our own research. We also buy research and analyse it to come to our own views. Our Investment Committee, chaired by our
Chief Investment Officer, is responsible for the development of our strategic asset allocation plan based on fundamental and technical
analysis, using a range of third-party economic research and market data, including views on interest rates, equity earnings outlook, and
market volatility, as well as third-party research.
Our investment philosophy is simple: we follow a value-based approach to investing. We invest our clients in securities that we believe will
benefit from our view of future medium to long-term global trends. We diversify by selecting several themes to follow rather than just one and
invest for the long-term.
In the case of equities, we seek to invest in high quality companies that are attractively priced relative to their future business prospects. We
believe that the market’s short-term focus creates opportunities for those willing to concentrate on underlying business performance.
We invest in corporate bonds where we believe there is a commensurate level of credit spread for the credit risk. We monitor debt levels and
interest cover of the underlying companies to assess whether the debt can be financed. We restrict direct bond exposure to investment grade
senior unsecured bonds.
We will invest in collective investments schemes where we believe the fund manager has the skills to outperform market indices over the
medium to long term, and where there is a compelling case for active returns. We meet with and monitor the fund managers regularly,
reviewing performance, financials including costs, and team changes.
We maintain an approved list of investments. When implementing a client’s bespoke investment strategy, we use the full range of securities
available to optimise the balance of risk, return and liquidity consistent with the client’s aims.
Risk
We explain below some of the main risks of investing. It is not an exhaustive list.
Investing risk - investing in securities involves the risk of loss that investors must be willing and able to bear and the level of risk of loss can
vary significantly. Most investments do not guarantee that investors will get back the amount they initially invest.
Market risk - the value of investments, and the income from them, can go down as well as up, and investors may lose all the money they
invest. Changes in interest rates also may cause the market value of investments to fall.
Asset allocation risk - is the risk that the strategic asset allocation that we implement for our clients underperforms other asset classes.
Currency risk – where investments are denominated in foreign currencies, movements in exchange rates of the currency in which the
investment is denominated relative to the base currency of investors’ portfolios may cause the value of the investment to fluctuate unfavourably.
Foreign securities risk - investing in emerging markets can carry significantly greater risk than those typically associated with investing
in more developed markets. The nature and extent of these risks will vary from country to country. Emerging markets often face political
instability and unpredictable growth patterns. Also, they often lack the levels of transparency, liquidity, infrastructure, efficiency, and
regulatory supervision of more developed markets.
Liquidity risk - this is the risk that, due to insufficient trading volumes, a security cannot be traded at the required size (or quickly enough) to
prevent a loss or make the expected profit. In terms of market volatility there is always the possibility that investments may not be easy to
liquidate at a good price, particularly if the position is large. Liquidity risk increases where portfolios are invested in alternative investments
such as private market securities and hedge funds as they are not traded on an exchange and may have long periods of liquidity restrictions.
Counterparty credit risk – this is the risk that the issuer of an investment fails to meet its obligations and does not or cannot pay amounts
due to investors. If this is the case, investors may lose all their initial investment. Also, cash held with deposit taking financial institutions gives
rise to counterparty risk if these entities cannot pay amounts due.
Form ADV Part 2A
18 June 2025, page 6 of 9
SCOTTCAPITAL PARTNERS
Item 9. Disciplinary Information
We have nothing to report.
Item 10. Other Financial Industry Activities and Affiliations
We are not registered as a broker dealer with the SEC. We are not a Commodity Trading Adviser or a Commodity Pool Operator, or an exempt
Commodity Trading Adviser or Commodity Pool Operator. We do not have an application pending for these.
David Scott, our Managing Partner and Chief Executive Officer, is a member of the Board of Tribe Impact Capital LLP, an FCA authorised and
regulated investment firm. We have no business dealings with this firm. Holding these positions at the same time is a conflict of interest. To
address this and protect our Confidential Client Information, as defined in our Code of Ethics (“Code”), we require him to certify, quarterly,
compliance with information barrier requirements. If a situation arises, we will require him to recuse himself from discussions or voting at this
firm’s board meetings.
Some of the members on our Management Board also are our clients. This is a conflict of interest. To address the conflict, they do not manage
their portfolios and will recuse themselves when and where necessary. Also, the management of their investment portfolio is monitored on a
regular basis.
Other members of our LLP hold outside activities, such as positions as trustee, investors in non-investment management private companies,
and positions at charities. We require these persons, and all associated with SCP, to declare outside activities. We evaluate them to confirm
whether a conflict of interest is present and, if so, we implement requirements to mitigate these.
One of the members of our Management Board is a member of the Advisory Board to the Investment Committee of Pembroke College, a
college of the University of Cambridge, UK. This is a conflict of interest. To address the conflict, we require that they do not provide investment
advice about an investment security to the Advisory Board, and we require them to recuse themselves when and where necessary to ensure
that they do not have sight of any of the investment securities that may be included within Pembroke College’s portfolio of investments. We
require them to certify, quarterly, compliance with these requirements.
Item 11. Code of Ethics, Participation/Interest in Client Transactions and
Personal Trading
Our Code, required by Advisers Act Rule 204A-1, sets out standards of conduct and other requirements for Supervised Persons and regulates
the personal account dealing activity for Access Persons and their Connected Persons – these terms are defined in our Code.
These are reasonably designed to address conflicts of interest and prevent the misuse of Confidential Client Information (as defined in our
Code). Each Access Person must comply with initial and annual holding reporting requirements regarding their accounts and securities
positions, pre-clearance and quarterly transaction reporting.
The giving and receiving of gifts and entertainment are addressed by our Gifts and Entertainment Procedure.
We track the outside activities of our Supervised Persons and require them to address (mitigate) the conflicts of interest, if any, that arise
from these.
We will provide a copy of our Code to any client or prospective client upon request.
Form ADV Part 2A
18 June 2025, page 7 of 9
SCOTTCAPITAL PARTNERS
Item 12. Brokerage and Trading Practices
As a fiduciary, we always seek to act in the best interests of our clients.
Our clients choose and appoint their own third-party custodian(s) who hold client money and assets and whose trading desks execute and
settle transactions. We are not affiliated with any custodians.
We do not solicit or take orders to buy or sell securities from U.S. clients. We do not permit directed brokerage. We do not extend credit
to clients.
We do not trade commodities, futures or OTC derivatives for U.S. clients. We use spot FX when we buy or sell a security denominated in a
foreign currency.
We are required to seek best execution for our clients. We do not select brokers or counterparties with whom to trade or route orders to
markets or executing venues. All orders are routed to the trading desk of the custodian chosen by our client, and it selects the broker or
counterparty with whom trades are executed. As such, we require that each trading desk provides us with its best execution policies and
procedures and executes at a standard consistent with - and to discharge – its and our duty of best execution. We perform our own analysis
to ascertain best execution against a daily average of VWAP on the date of the trade.
We do not have any “soft dollar” arrangements within the safe harbour of Section 28(e) of the U.S. Securities Exchange Act of 1934.
We do not effect cross trades. We do not trade for our own account or with clients.
When we deal at one time for more than one account or client, we pre-trade allocate the amount of securities for each client participating
in that transaction. We do this if we reasonably believe that our clients will obtain a no less favourable outcome than if the order had been
executed separately. Post execution, securities are promptly allocated to or removed from the account of the client and they are allocated
without unfair preference. Partial order fills are allocated on a pro rata basis.
A trade error is a mistake in the dealing process. If we identify a trade error, we seek to resolve it straightaway while ensuring that the client
is not disadvantaged. Clients keep gains. Where the trade error is our mistake, we bear losses. We do not net gains or losses. Where the
trade error is the custodian’s mistake, they bear losses. We do not compensate clients for lost investment opportunities (e.g., failure to take
advantage of investment or market opportunity).
Item 13. Review of Accounts
We meet and speak with our clients regularly throughout the year to discuss the performance of their portfolio of investments. The client’s
dedicated investment manager will perform a comprehensive review of each client’s portfolio of investments annually and present the
outcome of this review to the client at their review meeting. In addition to this annual review process, if there is a material change in our
client’s investment objectives, financial situation, personal circumstances, or willingness and ability to take risk, the client’s dedicated
investment manager will also carry out a review of the suitability of the client’s investment strategy.
Item 14. Client Referrals and Other Compensation
We do not pay cash or non-cash compensation to any third party for providing discretionary investment management services, non-
discretionary investment management services or occasional and non-continuous non-discretionary investment advice for or to our U.S.
clients, or to solicit or refer clients to us. We do not accept monetary or non-monetary benefits from third-parties in relation to these services.
We do not have any solicitation or referral arrangements in place with respect to U.S. clients.
Form ADV Part 2A
18 June 2025, page 8 of 9
SCOTTCAPITAL PARTNERS
Item 15. Custody
We do not have custody of any client assets. Our clients choose and appoint their own third-party custodian(s). Clients receive quarterly
valuations and statements from their custodian(s), as well as the quarterly valuations and statements we provide them. The valuations and
statements received from their custodian(s) are the official record of the clients’ assets and clients are responsible for reviewing these and
raising any discrepancies with their custodian(s).
Item 16. Investment Discretion
Where we provide discretionary investment management services to U.S. clients, within the asset allocation parameters of the investment
strategy agreed with the client, and with reference to any restrictions and preferences the client has given, we have discretion to determine
whether a particular investment is bought or sold, without consultation with our client.
Where we provide non-discretionary investment management services to U.S. clients, we do not have authority to decide whether a particular
investment is bought or sold; this decision is made by the client, and they maintain responsibility for implementing their investment decisions.
Item 17. Voting Client Securities
We do not vote proxies for U.S. clients.
Item 18. Financial Information
We do not have any information to disclose.
Form ADV Part 2A
18 June 2025, page 9 of 9
SCOTTCAPITAL PARTNERS