Form CRS & Business Continuity
Our client relationship summary, Form ADV Part 2 brochure, and business continuity plan summary — updated as required by SEC rules following registration.
Senioa Life Management, LLC intends to register as an investment adviser with the U.S. Securities and Exchange Commission upon exceeding applicable AUM thresholds. Form ADV Parts 1, 2A ("Brochure"), 2B ("Brochure Supplement"), and Form CRS ("Relationship Summary") will be filed with the SEC and made available here at that time. Registration does not imply any level of skill or training.
1. Our Relationship With You
Senioa Life offers investment advisory services to privately offered pooled investment vehicles ("Funds") that invest in senior housing real estate and related operating platforms. We do not open retail brokerage or individual advisory accounts. Our clients are the Funds themselves; limited partners are investors in the Funds but are not advisory clients of Senioa Life.
2. Services and Fees
Senioa Life provides discretionary investment management to each Fund pursuant to that Fund's Limited Partnership Agreement and Investment Management Agreement. Compensation is structured primarily as carried interest, with fund-level operating expenses reimbursed by the Fund. Full economic terms are set forth in each Fund's Private Placement Memorandum and Limited Partnership Agreement.
3. Conflicts of Interest
Common conflicts include:
- Allocation of investment opportunities among multiple Funds and co-investment vehicles
- Cross-fund transactions between successor and predecessor Funds
- Fees paid by portfolio companies to Senioa Life affiliates for operating, development, or property-management services
- Personal trading by Senioa Life personnel
These conflicts are addressed in the Adviser's written Conflicts of Interest Policy, Allocation Policy, and Code of Ethics, with oversight by each Fund's Limited Partner Advisory Committee.
4. Standard of Conduct
Upon registration, Senioa Life will owe each Fund a fiduciary duty under the Investment Advisers Act of 1940, which includes a duty of care and a duty of loyalty. We will act in each Fund's best interest and disclose material conflicts of interest.
5. Disciplinary History
Neither Senioa Life Management, LLC nor any of its senior personnel has any legal or disciplinary history required to be disclosed under Item 9 of Form ADV Part 2A. Once we register, the SEC's Investment Adviser Public Disclosure website at adviserinfo.sec.gov will make Form ADV publicly available.
6. Business Continuity Plan Summary
Senioa Life maintains a written Business Continuity Plan ("BCP") designed to enable continued service to the Funds and their investors in the event of a significant business disruption, including but not limited to natural disaster, cyber incident, pandemic, terrorism, or the incapacity of key personnel.
Key elements:
- Data and systems: Cloud-based investor and portfolio systems with geographically diverse hot backups and daily encrypted replication
- Alternate operations: Remote work protocols and a secondary physical office
- Key-person succession: Documented delegation for investment, operational, and compliance functions
- Communications: Redundant email and voice systems, with capability to notify investors within 24 hours of a material disruption
- Vendors: Written BCP requirements for fund administrator, auditor, custodian, and IT providers
- Testing: Annual full-scale BCP exercise and quarterly cyber-tabletop exercise
7. How to Get More Information
To request Form ADV Parts 1 and 2, Form CRS, the full Business Continuity Plan summary, the Code of Ethics, or any related policy:
Chief Compliance Officer
Senioa Life Management, LLC
1910 Pacific Avenue
Suite 2000
Dallas, TX 75201
[email protected]
972.945.5050
8. Questions to Ask Us
The SEC recommends investors ask their advisers questions such as:
- Given my financial situation, should I choose an investment advisory service? Why or why not?
- How will you choose investments to recommend to me?
- What is your relevant experience, including your licenses, education, and other qualifications?
- How might your conflicts of interest affect me, and how will you address them?
- How do you get paid? Do you or your firm have a disciplinary history?
We welcome these conversations. Please contact us at [email protected].