PEI Media names Mei-Li da Silva Vint as one of its 2022 Women of Influence in Private Markets, in the private debt category

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Disclaimer

Brevet Capital Management, LLC’s (“Brevet”) refers to the attached article (the “Article”) written by a third party and titled “Women of Influence: Private Debt” (the “Honor”). Brevet’s inclusion of the Article about the Honor on its website may be deemed an “endorsement” under the SEC’s Investment Advisers Act Rule 206(4)-1 (the “Marketing Rule”). The Marketing Rule defines an endorsement as “any statement by a person other than a current client or private fund investor that indicates approval, support, or recommendation of the investment adviser or its supervised persons or describes that person’s experience with the investment adviser or its supervised persons.” To comply with the Marketing Rule, Brevet provides the following disclosures:

  1. Source – The Article was written and the Honor was issued by PrivateDebtInvestor.com (“PEI”). According to its website, PEI is “a publication of record for the world’s private credit markets. It is written expressly for the providers and users of debt for private assets. The publication tracks the institutions, the funds and the transactions shaping the private debt markets.” PEI is published by PEI Group.
  2. Period – The Honor covers the evaluation period from April 2021 to May 2022, and was announced on July 1, 2022.
  3. Compensation – Brevet and Mei-Li da Silva Vint (“Mei-Li”), the subject of the Honor, were not directly involved in the nomination process, but notified by their public relations firm that a nomination was being submitted on Mei-Li’s behalf. Neither Brevet nor Mei-Li submitted any materials, responses, or nominations in connection with the selection process. No compensation, whether in the form of cash, services, subscriptions, or other consideration, was provided by Brevet or Mei-Li in exchange for receiving the Honor or being mentioned in the Article. For more information about Brevet’s compensation policies and disclosures, please refer to Brevet’s Form ADV Part 2, accessible at http://adviserinfo.sec.gov/firm/summary/151672.
  4. Content of Article – The Article highlights Mei-Li’s role as Chief Compliance Officer and her contributions to Brevet’s strategic initiatives, growth efforts, and client relationships. The Article also mentions transactions or achievements attributed to Mei-Li’s leadership. Brevet did not provide this information to the publisher and is not aware of the specific sources used by the publisher in drafting the Article.
  5. Potential Conflict – Brevet and Mei-Li were informed of the nomination by their public relations firm but were not involved in the selection process and did not influence the outcome. Brevet does not believe there is a conflict of interest related to the receipt of the Honor.
  6. Compliance with Marketing Rule – Brevet has no reason to believe that PEI failed to comply with the SEC’s Marketing Rule, based on the following: (a) Brevet was informed by its public relations firm that Mei-Li was being submitted for consideration, but neither Brevet, Mei-Li, nor its public relations firm were involved in the selection process; (b) neither Brevet nor Mei-Li provided any compensation in connection with the receipt of the Honor; and (c) Brevet is not aware of any material conflict of interest related to the Honor.
  7. No Client Testimonials – This disclosure relates solely to a third-party endorsement and does not constitute a testimonial by any client. Brevet does not solicit or selectively use client testimonials. Where client testimonials are used in other contexts, Brevet endeavors to comply with all applicable requirements of the Marketing Rule.