About Me

I spent the first half of my life on the East Coast and the second half on the West Coast…. from Manhattan to Manhattan Beach. I worked in the institutional bond business for 30 years in Sales, Portfolio Management and Client Services, spending the last 19 years at Western Asset, where I was Head of their Endowment, Foundation and Healthcare channel. During that time, I was fortunate to work closely with investors to assure that their guidelines aligned with their beliefs, also known as Socially Responsible Investing (SRI).

In 2017 I joined TriLinc Global and was enlightened by the impact that private capital can have, especially on Small and Medium Enterprises (SMEs) in developing economies (EM), where access to capital is significantly constrained or non-existent.

In 2020 I launched Impact Capital Partners to make a difference in my own way – by creating a platform to facilitate the flow of capital from institutional investors to “impact investments.”

My happy place is the great outdoors and I love hiking and connecting with Nature. When there, I always try to respect the Leave No Trace (LNT) principles, so that future visitors will have the same (or better) experience when they pass by too.

I also believe it is our responsibility to leave the planet the same (or better) for our children, so I am happy to be trying to do my part every day!

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MORE ABOUT IMPACT CAPITAL PARTNERS

Grand Canyon 2017
Kilimanjaro 2018

About Impact Capital Partners

In 2020 I launched Impact Capital Partners to make a difference in my own way – by creating a platform to connect impact opportunities with institutional capital.

Our listed opportunities include Private Equity & Private Debt funds, direct investments and co-investments that, for the most part, are sourced by in-region / in-country Investment Partners who source, due diligence, and share them with us. In turn, Impact Capital Partners LLC, can share them with institutional investors in the US, through its registration with Pinnacle Capital Securities LLC, who is authorized by FINRA to act as a chaperone under SEC Rule 15a-6.

Importantly, I realize that there are many shades-of-green, and that each investor has their own thoughts on what constitutes an “impact investment”, but I believe the UN’s Sustainable Development Goals (SDGs) provide a framework that most agree on, so our listed opportunities will always state alignment with specific SDGs.

Through Impact Capital Partners, I hope to make it easier for institutional investors to find and invest in impact investments because I believe that as larger dollar amounts seek investments with market-rate returns AND positive social impact, we will have a better chance of solving the world’s toughest problems!

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SEC Rule 15a-6 / “Chaperoning”

Impact Capital Partners LLC is registered with Pinnacle Capital Securities, LLC, who is authorized by FINRA to act as a chaperoning US Broker-Dealer to Foreign entity Broker-Dealers (FBDs) wishing to effect unsolicited transactions in the US.

Background

Rule 15a-6 under the Securities Exchange Act of 1934 provides conditional exemptions from broker-dealer registration for foreign broker-dealers1 that engage in certain specified activities involving U.S. investors. These activities include:

1) Effecting unsolicited securities transactions;
2) Providing research reports to major U.S. institutional investors, and effecting transactions in the subject securities with or for those investors;
3) Soliciting and effecting transactions with or for U.S. institutional investors or major U.S. institutional investors through a “chaperoning broker-dealer”2; and
4) Soliciting and effecting transactions with or for registered broker-dealers, banks3 acting in a broker or dealer capacity, certain international organizations, foreign persons temporarily present in the U.S., U.S. citizens resident abroad, and foreign branches and agencies of U.S. persons.4
In adopting Rule 15a-6, the SEC sought “to facilitate access to foreign markets by U.S. institutional investors through foreign broker-dealers and the research that they provide, consistent with maintaining the safeguards afforded by broker-dealer registration,” and “to provide clear guidance to foreign broker-dealers seeking to operate in compliance with U.S. broker-dealer registration requirements.”5

Since that time, the staff has provided guidance on the operation of Rule 15a-6 in various no-action letters. For example, in a 1996 letter to counsel for seven registered broker-dealers, staff indicated that they would not recommend enforcement action to the SEC if a foreign broker-dealer affiliated with any of the firms named in the letter (each, a “U.S. Affiliated Foreign Broker-Dealer”) effected transactions in Foreign Securities (as defined therein) with a U.S. Resident Fiduciary (as defined therein) for Offshore Clients (as defined therein) without the U.S. Affiliated Foreign Broker-Dealer either registering with the SEC or effecting the transactions in accordance with Rule 15a-6.6 The following year, staff informed counsel to nine registered broker-dealers (including all of the firms party to the Seven Firms Letter) that they would not recommend enforcement action to the SEC if any U.S. Affiliated Foreign Broker-Dealer (as modified to reflect the addition of two additional firms party to the letter) engaged in certain activities without the U.S. Affiliated Foreign Broker-Dealer either registering with the SEC as a broker-dealer or effecting the transactions in accordance with Rule 15a-6.7 Among other things, the Nine Firms Letter:

1) Established an expanded interpretation of the definition of “major U.S. institutional investor” to include “any entity, including any investment adviser (whether or not registered under the Investment Advisers Act), that owns or controls (or, in the case of an investment adviser, has under management) in excess of $100 million in aggregate financial assets,” subject to certain limitations set forth in the letter;

2) Permitted a foreign broker-dealer or its agent, in reliance on Rule 15a-6(a)(3), to transfer funds or securities directly to a U.S. institutional investor or its agent so long as: (i) the transactions involve Foreign Securities (as defined in the Seven Firms Letter) or U.S. government securities; (ii) the foreign broker-dealer agrees to make available to the chaperoning broker-dealer all clearance and settlement information related to such transfers; (iii) the foreign broker‑dealer is not acting as a custodian of the funds or securities of the U.S. investor; and (iv) the foreign broker-dealer is not in default to any counterparty on any material financial market transaction; and

3) Permitted foreign associated persons of a foreign broker‑dealer, without the participation of an associated person of a chaperoning broker-dealer, to (i) engage in oral communications from outside the U.S. with U.S institutional investors (that do not qualify as major U.S. institutional investors) where such communications take place outside of the trading hours of the New York Stock Exchange, so long as the foreign associated persons do not accept orders to effect transactions other than those involving Foreign Securities, and (ii) have in-person contacts during visits to the U.S. with major U.S. institutional investors (as such definition was expanded in the letter), so long as the number of days on which such in-person contacts occur does not exceed 30 per year and the foreign associated persons engaged in such in‑person contacts do not accept orders to effect securities transactions while in the U.S.8

******************FOOTNOTES******************
1 Rule 15a-6(b)(3) defines foreign broker-dealer to include “any non‑U.S. resident person (including any U.S. person engaged in business as a broker or dealer entirely outside the United States, except as otherwise permitted by this rule) that is not an office or branch of, or a natural person associated with, a registered broker or dealer, whose securities activities, if conducted in the United States, would be described by the definition of ‘broker’ or ‘dealer’ in sections 3(a)(4) or 3(a)(5) of the [Exchange] Act.”
2 For purposes of these FAQs, the term “chaperoning broker-dealer” means a registered broker-dealer that satisfies all of the requirements set forth in Rule 15a-6(a)(3)(iii) including, among other things, effecting transactions, issuing confirmations, maintaining books and records, participating in oral communications, and obtaining certain representations and consents.
3 As explained in the release adopting Rule 15a-6, the term “bank” is defined in section 3(a)(6) of the Exchange Act to mean a bank directly regulated by U.S. state or federal bank regulators. Accordingly, a foreign bank is excluded from this term except to the extent that the “foreign bank establishes a branch or agency in the United States that is supervised and examined by a federal or state banking authority and otherwise meets the requirements of section 3(a)(6).” See Registration Requirements for Foreign Broker-Dealers, Exchange Act Release No. 27017 (July 11, 1989), 54 FR 30013, n.16 (July 18, 1989) (“Rule 15a-6 Adopting Release”) (noting, however, that the determination whether any particular financial institution meets the requirements of section 3(a)(6) is the responsibility of the financial institution and its counsel) (internal citations omitted).
4 17 C.F.R. § 240.15a-6.
5 Rule 15a-6 Adopting Release at 54 FR 30013; see also Registration Requirements for Foreign Broker-Dealers, Exchange Act Release No. 25801 (June 14, 1988), 53 FR 23645 (June 23, 1988).
6 See Letter re: Transactions in Foreign Securities by Foreign Brokers or Dealers with Accounts of Certain Foreign Persons Managed or Advised by U.S. Resident Fiduciaries from Catherine McGuire, Chief Counsel, Division of Market Regulation to Giovanni P. Prezioso, Cleary, Gottlieb, Steen & Hamilton, dated January 30, 1996 (“Seven Firms Letter”).
7 See Letter re: Securities Activities of U.S.-Affiliated Foreign Dealers from Richard R. Lindsey, Director, Division of Market Regulation to Giovanni P. Prezioso, Cleary, Gottlieb, Steen & Hamilton, dated April 9, 1997 (“Nine Firms Letter”), available HERE


8 See id.

U.N. Sustainable Development Goals

Impact Capital Partners only sources opportunities that have impacts that are aligned with the U.N. Sustainable Development Goals (SDGs).

About the Sustainable Development Goals

The Sustainable Development Goals are the blueprint to achieve a better and more sustainable future for all. They address the global challenges we face, including those related to poverty, inequality, climate change, environmental degradation, peace and justice. The 17 Goals are all interconnected, and in order to leave no one behind, it is important that we achieve them all by 2030.

GOAL 1: NO POVERTY

Economic growth must be inclusive to provide sustainable jobs and promote equality.

GOAL 2: ZERO HUNGER

The food and agriculture sector offers key solutions for development, and is central for hunger and poverty eradication.

GOAL 3: GOOD HEALTH AND WELL-BEING

Ensuring healthy lives and promoting the well-being for all at all ages is essential to sustainable development.

GOAL 4: QUALITY EDUCATION

Obtaining a quality education is the foundation to improving people’s lives and sustainable development.

GOAL 5: GENDER EQUALITY

Gender equality is not only a fundamental human right, but a necessary foundation for a peaceful, prosperous and sustainable world.

GOAL 6: CLEAN WATER AND SANITATION

Clean, accessible water for all is an essential part of the world we want to live in.

GOAL 7: AFFORDABLE AND CLEAN ENERGY

Energy is central to nearly every major challenge and opportunity.

GOAL 8: DECENT WORK AND ECONOMIC GROWTH

Sustainable economic growth will require societies to create the conditions that allow people to have quality jobs.

GOAL 9: INDUSTRY, INNOVATION, AND INFRASTRUCTURE

Investments in infrastructure are crucial to achieving sustainable development.

GOAL 10: REDUCED INEQUALITIES

To reduce inequalities, policies should be universal in principle, paying attention to the needs of disadvantaged and marginalized populations.

GOAL 11: SUSTAINABLE CITIES AND COMMUNITIES

There needs to be a future in which cities provide opportunities for all, with access to basic services, energy, housing, transportation and more.

GOAL 12: RESPONSIBLE CONSUMPTION AND PRODUCTION

Responsible Production and Consumption

GOAL 13: CLIMATE ACTION

Climate change is a global challenge that affects everyone, everywhere.

GOAL 14: LIFE BELOW WATER

Careful management of this essential global resource is a key feature of a sustainable future.

GOAL 15: LIFE ON LAND

Sustainably manage forests, combat desertification, halt and reverse land degradation, halt biodiversity loss

GOAL 16: PEACE, JUSTICE AND STRONG INSTITUTIONS

Access to justice for all, and building effective, accountable institutions at all levels.

GOAL 17: PARTNERSHIPS

Revitalize the global partnership for sustainable development.

RELATED OPPORTUNITY

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Ford Foundation allocates $1 billion for MRIs

Impact Investing for Foundations

View original article here.

The Ford Foundation’s Board of Trustees has authorized the allocation of up to $1 billion of its endowment, to be phased in over 10 years, for mission-related investments (MRIs). This comes as a result of the foundation’s efforts to explore impact creation through the capital markets. However, to understand why the Ford Foundation is pushing capital to MRI’s, it’s important to understand the history between traditional investments and philanthropic impact.

For foundations, investing with impact started with grant making. Since 1969, US tax law has mandated that foundations pay out a minimum of 5 percent of their total assets each year. For the Ford Foundation today, this translates to an annual grant-making budget of around $500 million to $550 million.

Meanwhile, the other 95% of investments gets put to work in the investment market, with the goal of earning enough profit to sustain the grant making going forward. As one can imagine, this law created a natural divide between philanthropic impact and investments.

On one hand, you are required to grant 5 percent of your total assets every year, while on the other hand, 95 percent of assets need to generate enough profit to maintain, or increase, assets under management.

A potential solution to this problem was identified 50 years ago in 1967, when Ford Foundation staff presented a report to trustees, titled Program-Directed Investments.

Optimizing the 5%: Program-related investments (PRIs)

The Ford Foundation’s ‘Program-Directed Investments’ report argued that philanthropy was about more than grant making. The following year, the foundation sought and received a ruling from the IRS that allowed them to create a new investment vehicle called program-related investments (“PRIs”). These are essentially charitable instruments that take the form of loans, guarantees, and equity.

Like grants, PRIs count toward the 5 percent foundations are required to pay out every year, but unlike grants, they are expected to be repaid. They are not, however, expected to provide a return at competitive, risk-adjusted market rates.

Despite this, PRIs have proven to be effective at optimizing the 5 percent, allowing foundations to take risks consistent with their mission in ways that much larger investors, such as pension funds, often cannot.

Optimizing the 95%: Mission-related investments (MRIs)

While PRIs have allowed foundations, like the Ford Foundation, to tap the power of grant-making budgets in innovative ways, the remaining 95 percent remained untapped.

That brings us to mission-related investments, or MRIs. This new tool seeks to achieve attractive financial returns while also advancing the foundation’s mission.

By doing so, foundations can leverage the power of their endowments, and start to unlock the potential of the 95 percent to create impact through the market.

The changing landscape

A number of foundations have started to use MRIs, including the More for Mission movement, the Rockefeller Brothers Fund, Kellogg Foundation, John D. and Catherine T. MacArthur Foundation, Kresge Foundation, McKnight Foundation, F.B. Heron Foundation, Wallace Global Fund, Surdna Foundation, Bill & Melinda Gates Foundation, and Open Society Foundations.

While these institutions have taken a variety of approaches, their commitment demonstrates leadership and courage. Their initial steps should inspire all of us to consider how we might leverage the power of our endowments to promote dignity, equality, and justice for people around the world.

How Mission Related Investments work – Ford Foundation 1:53

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