Overview
                                    
                                    
                                        
                                            A. Description of the Advisory Firm 
INCEPTIONR LLC (hereinafter “INC”) is a Limited Liability Company organized in the 
State of California. The firm was formed in April 2019, and the principal owner is Li Lu. 
B. Types of Advisory Services 
Portfolio Management Services 
INC provides portfolio management to pooled investment vehicles, specifically acting as 
subadviser to private funds (the client).   
INC  will  require  discretionary  authority  from  clients  in  order  to  select  securities  and 
execute transactions without permission from the client prior to each transaction. INC 
seeks  to  provide  that  investment  decisions  are  made  in  accordance  with  the  fiduciary 
duties owed to its accounts and without consideration of INC’s economic, investment or 
other financial interests. To meet its fiduciary obligations, INC attempts to avoid, among 
other  things,  investment  or  trading  practices  that  systematically  advantage  or 
disadvantage certain client portfolios, and accordingly, INC’s policy is to seek fair and 
equitable allocation of investment opportunities/transactions among its clients to avoid 
favoring  one
                                        
                                        
                                              client  over  another  over  time.  It  is  INC’s  policy  to  allocate  investment 
opportunities and transactions it identifies as being appropriate and prudent among its 
clients on a fair and equitable basis over time. 
Services Limited to Specific Types of Investments 
INC  generally  limits  its  investment  advice  to  equities,  although  INC  may  use  other 
securities as well to help diversify a portfolio when applicable. 
C. Client Tailored Services and Client Imposed Restrictions 
INC offers the same suite of services to all of its clients. Clients may not impose restrictions 
in investing in certain securities or types of securities in accordance with their values or 
beliefs.  
D. Wrap Fee Programs 
A wrap fee program is an investment program where the investor pays one stated fee that 
includes  management  fees,  transaction  costs,  fund  expenses,  and  other  administrative 
fees. INC does not participate in any wrap fee programs. 
E. Assets Under Management 
INC has the following assets under management: 
Discretionary Amounts: Non-discretionary Amounts:  Date Calculated: 
$ 838,129,859 $0 May 2024