Manager Selection LLC (“Empirically”, “Company”, “we”, “us”, or “our”) is a professional services organization serving sophisticated institutional investors. Please refer to the following disclosures:

  • Are you registered with the SEC or a state securities regulator as an investment adviser? If so, have you provided all the disclosures required under those laws (including Part II of Form ADV)? Empirically is not an SEC-registered investment adviser. Empirically generally provides analytics and information services, and does not provide investment advice. However, certain client engagements may entail our providing investment advice. Empirically is a prohibited Small Adviser under Section 203A of the Advisers Act because it has less than $25 million of assets under management. We have no assets under management.
  • Do you or a related company have relationships with money managers that you recommend, consider for recommendation, or otherwise mention to the plan? If so, describe those relationships. Empirically does not maintain any relationships with investment managers beyond arms-length due diligence activities on behalf of clients.
  • Do you or a related company receive any payments from money managers you recommend, consider for recommendation, or otherwise mention to the plan for our consideration? If so, what is the extent of these payments in relation to you other income (revenue)? No.
  • Do you have any policies or procedures to address conflicts of interest or to prevent these Payments or relationships from being a factor when you provide advice to your clients? Yes, we have policies and procedures designed to eliminate actual and apparent conflicts of interest, which are available upon request. We do not maintain relationships with or accept payments from the asset managers we evaluate.
  • If you allow plans to pay your consulting fees using the plan’s brokerage commissions, do you monitor the amount of commissions paid and alert plans when consulting fees have been paid in full? If not, how can a plan make sure it does not over-pay its consulting fees? Not applicable.
  • If you allow plans to pay your consulting fees using the plan’s brokerage commissions, what steps do you take to ensure that the plan receives best execution for its securities trades? Not applicable.
  • Do you have any arrangements with broker-dealers under which you or a related company will benefit if money managers place trades for their clients with such broker-dealers? No.
  • If you are hired, will you acknowledge in writing that you have a fiduciary obligation as an investment adviser to the plan while providing the consulting services we are seeking? If the nature of our engagement involves our providing investment advice, Yes.
  • Do you consider yourself a fiduciary under ERISA with respect to the recommendations you provide the plan? If the nature of our engagement involves our providing investment advice, Yes.
  • What percentage of your plan clients utilize money managers, investment funds, brokerage services or other service providers from whom you receive fees? 0%.
Last updated September 16, 2020.