Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Ac Investment Management LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Ac Investment Management LLC.
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-03-31 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | EAGLE I, LLCMEMBERDomestic entity | AC INVESTMENT MANAGEMENT LLC | 10% to less than 25%Code B | No | MEMBER01/2011 | Schedule APDF page 40 |
| 2 | EAGLE I, LLCMEMBER (AURELIAN CAPITAL GP, LLC; GENERAL PARTNER OF AGR MASTER LP)Domestic entity | AC INVESTMENT MANAGEMENT LLC | 10% to less than 25%Code B | No | MEMBER (AURELIAN CAPITAL GP, LLC; GENERAL PARTNER OF AGR MASTER LP)01/2011 | Schedule APDF page 40 |
| 3 | EAGLE I, LLCMEMBER (AURELIAN HOLDINGS, LLC; MANAGER OF AURELIAN PLUS, LLC)Domestic entity | AC INVESTMENT MANAGEMENT LLC | 10% to less than 25%Code B | No | MEMBER (AURELIAN HOLDINGS, LLC; MANAGER OF AURELIAN PLUS, LLC)01/2011 | Schedule APDF page 40 |
| 4 | Daphne Wilmerding ScalamandreMEMBERIndividual | AC INVESTMENT MANAGEMENT LLC | 75% or moreCode E | Yes | MEMBER11/2023 | Schedule APDF page 40 |
| 5 | Daphne Wilmerding ScalamandreMEMBER ((AURELIAN CAPITAL GP, LLC; GENERAL PARTNER OF AGR MASTER LP)Individual | AC INVESTMENT MANAGEMENT LLC | 75% or moreCode E | Yes | MEMBER ((AURELIAN CAPITAL GP, LLC; GENERAL PARTNER OF AGR MASTER LP)11/2023 | Schedule APDF page 40 |
| 6 | Daphne Wilmerding ScalamandreMEMBER (AURELIAN HOLDINGS, LLC; MANAGER OF AURELIAN PLUS, LLC)Individual | AC INVESTMENT MANAGEMENT LLC | 75% or moreCode E | Yes | MEMBER (AURELIAN HOLDINGS, LLC; MANAGER OF AURELIAN PLUS, LLC)11/2023 | Schedule APDF page 40 |
| 7 | TIMOTHY WARDCHIEF COMPLIANCE OFFICER (CCO)Individual | AC INVESTMENT MANAGEMENT LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER (CCO)11/2023 | Schedule APDF page 40 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 3/31/2026 6:40:19 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 1 source block
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PDF pages 48–50
- Regulator name — filed text
- NATIONAL FUTURES ASSOCIATION
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
ACIM PAID A FINE OF $100,000 TO THE NFA IN DECEMBER OF 2024 AND HAS TAKEN APPROPRIATE ACTIONS TO MEET THE NFA'S SETTLEMENT OFFER AND CEASED FROM COMMITTING OR CAUSING ANY VIOLATIONS OF NFA COMPLIANCE RULE 2-45.
Other filed details
Description of allegations — filed text
THE NATIONAL FUTURES ASSOCIATION ("NFA") ALLEGED THAT AC INVESTMENT MANAGEMENT LLC ("ACIM") PERMITTED AURELIAN PLUS, LLC, A POOL ACIM OPERATES, TO MAKE AN IMPROPER LOAN TO AN AFFILIATED ENTITY, IN VIOLATION OF NFA COMPLIANCE RULE 2-45. THE COMPLAINT ALSO ALLEGED THAT ACIM FAILED TO UPHOLD HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE BY FAILING TO ACT IN THE BEST INTERESTS OF AURELIAN PLUS, LLC AND AGR MASTER, LP, ANOTHER POOL ACIM OPERATES, AND THEIR PARTICIPANTS, IN VIOLATION OF NFA COMPLIANCE RULE 2-4. ACIM NEITHER ADMITTED NOR DENIED THE ALLEGATIONS PRESENTED BY THE NFA.
Sanction detail — filed text
PURSUANT TO A SETTLEMENT OFFER, ACIM AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF NFA COMPLIANCE RULE 2-45; PAY A $100,000 FINE; AND ADHERE TO UNDERTAKINGS AGREED TO BETWEEN NFA AND ACIM IN CONNECTION WITH THE SETTLEMENT OFFER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NATIONAL FUTURES ASSOCIATION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
12/18/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
23BCC00011
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NATIONAL FUTURES ASSOCIATION ("NFA") ALLEGED THAT AC INVESTMENT MANAGEMENT LLC ("ACIM") PERMITTED AURELIAN PLUS, LLC, A POOL
ACIM OPERATES, TO MAKE AN IMPROPER LOAN TO AN AFFILIATED ENTITY, IN VIOLATION OF NFA COMPLIANCE RULE 2-45. THE COMPLAINT ALSO
ALLEGED THAT ACIM FAILED TO UPHOLD HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE BY FAILING TO
ACT IN THE BEST INTERESTS OF AURELIAN PLUS, LLC AND AGR MASTER, LP, ANOTHER POOL ACIM OPERATES, AND THEIR PARTICIPANTS, IN VIOLATION
OF NFA COMPLIANCE RULE 2-4. ACIM NEITHER ADMITTED NOR DENIED THE ALLEGATIONS PRESENTED BY THE NFA.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
10/29/2024
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
PURSUANT TO A SETTLEMENT OFFER, ACIM AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF NFA
COMPLIANCE RULE 2-45; PAY A $100,000 FINE; AND ADHERE TO UNDERTAKINGS AGREED TO BETWEEN NFA AND ACIM IN CONNECTION WITH
THE SETTLEMENT OFFER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ACIM PAID A FINE OF $100,000 TO THE NFA IN DECEMBER OF 2024 AND HAS TAKEN APPROPRIATE ACTIONS TO MEET THE NFA'S SETTLEMENT OFFER
AND CEASED FROM COMMITTING OR CAUSING ANY VIOLATIONS OF NFA COMPLIANCE RULE 2-45.* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.