Governance

Order is a form of care

Strong structure protects people, relationships and the mission.

Principles

How we are governed

Private family control

The family sets purpose, risk appetite and priorities. Advisers and service providers advise and serve. They do not govern.

Responsible delegation

Authority is given deliberately, in proportion, and with oversight retained.

Safekeeping discipline

Safekeeping is treated as a first-order concern, with controls designed to avoid single points of failure.

Confidentiality

Information is shared on a need-to-know basis and protected by policy, technology and discretion.

Investment oversight

Decisions follow a defined process of review, challenge and record-keeping.

Ethical stewardship

Counsel, compliance and conscience stand behind every commitment.

Reference

Legal Classification

United States — Federal

  • 17 CFR § 275.202(a)(11)(G)-1(SEC Family Office Rule exclusion from the investment-adviser definition)
  • 17 CFR § 230.501(a)(12) and (a)(13)(accredited-investor qualification for eligible family offices and family clients)
  • 17 CFR § 240.10b-5(securities anti-fraud)
  • 18 U.S.C. § 1343(wire fraud)

Tennessee

  • Tenn. Code Ann. § 48-1-102(1)(accredited-investor definition incorporating SEC Regulation D)
  • Tenn. Code Ann. § 48-1-102(13)(investment-adviser definition and exclusions)
  • Tennessee Securities Rule 0780-04-03-.05(investment-adviser registration exemptions)
  • Tenn. Code Ann. § 48-1-121(securities-related fraudulent acts and deceptive practices)

Florida

  • Fla. Stat. § 517.021(1)(accredited-investor definition)
  • Fla. Stat. § 517.061(9)(i)(securities transaction exemption for qualifying family offices)
  • Fla. Stat. § 517.301(securities fraud, material misrepresentation, and concealment)

Singapore

  • Securities and Futures Act 2001, § 4A(1)(a)(accredited-investor definition)
  • Securities and Futures (Licensing and Conduct of Business) Regulations, Second Schedule, paragraph 5(1)(ba)(single-family-office licensing exemption)
  • Penal Code 1871, § 420(cheating and dishonest inducement of property)
  • Penal Code 1871, § 477A(falsification of accounts)

Switzerland

  • Financial Institutions Act (FinIA), Art. 2(2)(a)(exclusion for management of assets exclusively for persons with qualifying family or business ties)
  • Financial Institutions Ordinance (FinIO), Art. 4(family-ties requirements)
  • Financial Services Act (FinSA), Art. 4(3)(g) and (i)(professional-client categories)
  • Swiss Criminal Code, Art. 146(fraud)

British Virgin Islands

  • Securities and Investment Business Act, 2010 (SIBA), §§ 3–4 and Schedule 2(investment-business scope and exclusions applicable to proprietary family capital and intra-family activity)
  • SIBA § 40(1) and Mutual Funds Regulations, Regulation 5(professional-investor qualification, where applicable)
  • BVI Criminal Code, § 231(obtaining property by deception)
  • BVI Criminal Code, § 236(false accounting)
  • Proceeds of Criminal Conduct Act, 1997
Not publishedGoverning documents, authorization structures, signatory arrangements and control details are confidential and are intentionally not described here.
Put GOD in charge of your work, then what you’ve planned will take place.Proverbs 16:3 · MSG