Our controls
ACM's advisory offering is supported by a governed, multi-layer risk framework — an SEC-registered adviser, a separately managed account structure, custody at a third-party custodian, with MPC-based signing controls, and controls designed to operate before, during and after capital deployment.
A governed, multi-layer framework
- Regulated
An SEC-registered adviser
View on SEC IAPDAbra Capital Management, LP is registered with the U.S. Securities and Exchange Commission as an investment adviser. Registration does not imply a particular level of skill or training or endorsement by the SEC. Its Form ADV and Form CRS are public.
- Structure
Built on an SMA framework
Client portfolios are managed through separately managed accounts rather than pooled investment vehicles. Account positions and activity are maintained and reported at the individual client-account level.
- Custody
Institutional custody
Custody is provided by third-party custodians. The custodian for each strategy is listed in its terms, and the custodian for your account is identified in your account documentation. Transaction signing is supported by MPC-based controls.
Custody and signing controls
The custodians and the signing technology are two different things
Third-party custodians hold client assets in the custody arrangement. Multi-party computation (MPC) is the signing technology used to authorize transactions. It is a control, not a regulated status.
A conventional wallet has one private key, and whoever holds it can move everything. MPC is designed to reduce reliance on a single private key by distributing signing functionality across multiple components. Signing material is split into shares held on independent systems, and a transaction requires a quorum of those systems to approve it against policy and contribute its share of the signature.
Protocol destinations are subject to pre-approved access controls and monitoring.
Separately managed accounts
Individual accounts, not a pooled vehicle
Abra Capital Management's managed offering is delivered through separately managed accounts. Rather than investing through a pooled fund, each client's portfolio is managed and accounted for separately pursuant to the client's investment management arrangement.
That account structure allows custody (at a third-party custodian), collateral and reporting to operate against a single balance, with execution effected through applicable trading venues, counterparties, and service providers. On-chain data can provide additional transparency into certain wallet holdings and transactions.
Controls before, during and after deployment
The framework incorporates review before deployment, ongoing monitoring of deployed positions, and valuation and reconciliation controls supporting portfolio reporting.
Review and approval come before allocation
- Protocol due diligence. Each protocol is reviewed for security and audit history, governance, liquidity, maturity and TVL, and prior exploit history before any capital is allocated.
- Committee governance. The ACM Executive Investment Committee approves strategies, protocols, venues and supported assets, sets portfolio rules and risk parameters, and reviews allocations. Deviations from approved parameters are returned to the committee before implementation.
- Diversification and exposure parameters. Applied across return sources, approved protocols, counterparties and venues, with position sizing informed by liquidity and protocol risk.
How positions are constructed and monitored
- Hedging and market-exposure management. Certain strategies seek to reduce directional market exposure through stablecoin positioning or hedging. Hedging may reduce, but does not eliminate, market, basis, liquidity, counterparty or execution risk.
- Collateral risk management. LTV and health-factor metrics are monitored relative to applicable liquidation thresholds. Positions may be rebalanced, borrowing reduced, or collateral adjusted as thresholds are approached.
- Ongoing protocol monitoring. Approved protocols are monitored after deployment, with exposure reduced or removed if the risk profile changes.
Valuation and reconciliation controls
- External pricing sources. Portfolio valuation incorporates external market and/or oracle pricing sources rather than relying solely on internally generated prices.
- Regular portfolio reconciliation. Portfolio value is reconciled against position and custody records on a regular basis.
- Ongoing monitoring. Position, risk and reconciliation are supported by third-party analytics and on-chain tools alongside Abra's internal dashboard and alerts.
Specific pricing sources, analytics providers and on-chain tooling are identified in diligence materials on request.
External price sources
Portfolio valuation incorporates external market and/or oracle pricing sources rather than relying solely on internally generated prices. Specific sources are identified in diligence materials on request.
Monitoring and analytics
Third-party analytics and on-chain tooling run alongside Abra's internal dashboard and alerting. Specific providers are identified in diligence materials on request.
Registrations and public filings
- Investment adviser
- Abra Capital Management, LP — registered with the U.S. Securities and Exchange Commission as an investment adviser. Registration with the SEC does not imply a particular level of skill or training or endorsement by the SEC.
- SEC / CRD number
- 323353Investment Adviser Public Disclosure
- Custodians
- Third-party custodians, identified in ACM's Form ADV and client account documentation
- Account structure
- Separately managed accounts. Client portfolios are managed through separately managed accounts rather than pooled investment vehicles, with positions and activity reported at the individual client-account level.
Questions your diligence team needs answered?
Our team can walk through the control framework, custody arrangements and reporting in detail.
Important disclosures
Abra is a brand used by affiliated entities that provide different products and services.
Abra Capital Management, LP (“ACM”) is an SEC-registered investment adviser that provides investment advisory and investment-management services, including through separately managed accounts. Registration does not imply a particular level of skill or training or endorsement by the SEC. Products and services offered by affiliated entities, including AbraFi Labs Ltd., are not investment advisory services of ACM. Services available through the Abra platform may be provided by ACM, an Abra affiliate, or an identified third-party service provider, depending on the product or service. Product availability, custody arrangements, asset deployment, risks and terms vary by service and account type. Digital assets may be subject to market, custody, counterparty, operational, smart-contract and protocol risks, including loss of principal.
