CE INVESTMENT MANAGEMENT, LLC – Hedge Fund Database

CE INVESTMENT MANAGEMENT, LLC

CEIM was founded in 2018 by William and Linda Cameron as part of the Cameron Enterprises group
of Companies. CEIM was formed by centralizing the investment management activities previously
performed in house by various affiliates throughout the Cameron Enterprises Group.
CEIM is primarily focused on fixed income investments and provides advice solely to affiliated
companies. In the future, CEIM may elect to advise outside clients.

CEIM’s Investment Strategy consists of the recommendation of fixed income assets, with a focus on
liability matched investing for an insurance company general account. We also oversee three external
managers for private placements and one external manager focusing on collateral loan obligations
(“CLO”s).

As of September 30, 2019, CEIM had approximately $5.15B in regulatory assets under management.

CEIM was founded in 2018 by William and Linda Cameron as partially of the Cameron Enterprises group of Companies. CEIM was formed by centralizing the investment management activities previously performed in house by versatile affiliates throughout the Cameron Enterprises Group. CEIM is chiefly focused on fixed income investments and provides advice entirely to consort companies. In the future, CEIM may elect to advise outside clients.CEIM ’ s Investment Strategy consists of the recommendation of fixed income assets, with a focus on liability matched investing for an insurance party general bill. We besides oversee three external managers for secret placements and one external coach focusing on collateral loanword obligations ( “ CLO ” mho ) .As of September 30, 2019, CEIM had approximately $ 5.15B in regulative assets under management. please register to get more information
Advisory Fees
As mentioned previously, CEIM provides services solely to affiliates under asset-based fee
schedules.

Asset-based fees are calculated based on the value of a client’s portfolio at periodic measurement
dates or over specified periods of time. The actual fee to be paid is negotiated with each client. In
addition, as part of its investment management services, CEIM may recommend investment with
outside third-party managers who provide a specialized investment se…

As mentioned previously, CEIM provides services entirely to affiliates under asset-based fee schedules.Asset-based fees are calculated based on the value of a customer ’ mho portfolio at periodic measurement dates or over stipulate periods of time. The actual fee to be paid is negotiated with each customer. In addition, as contribution of its investment management services, CEIM may recommend investment with external third-party managers who provide a speciate investment selenium … please cash register to get more information
As described above in Item 5, we negotiate fees with our clients individually. At present, CEIM does not charge
performance fees to any clients, but may do so in the future.
Side-by-Side Management of Accounts and Related Conflicts of Interest

CEIM does not receive any performance-based fees and therefore does not have any conflicts with
regard to side-by-side management.

As described above in Item 5, we negotiate fees with our clients individually. At introduce, CEIM does not charge performance fees to any clients, but may do thus in the future.CEIM does not receive any performance-based fees and consequently does not have any conflicts with respect to side-by-side management. please register to get more information

As mentioned previously, at the time of this filing, we provide investment advisory services to affiliated
insurance companies:
o American Fidelity Assurance Company (“AFA”),
o American Fidelity International (Bermuda), Ltd. (“AFIBL”),
o American Public Life Insurance Company (“APL”).

Minimum account sizes vary by investment strategy. We may waive these minimums in our
discretion.

Our investment management or similar agreements with clients, which include investment guide…

As mentioned previously, at the time of this file, we provide investment advisory services to consort insurance companies : o american english Fidelity Assurance Company ( “ AFA ” ), oxygen american english Fidelity International ( Bermuda ), Ltd. ( “ AFIBL ” ), o american english Public Life Insurance Company ( “ APL ” ) .Minimum account sizes vary by investment scheme. We may waive these minimums in our discretion.Our investing management or exchangeable agreements with clients, which include investment guidebook … please register to get more information
Methods of Analysis and Investment Strategies

Our research-based investment process integrates credit and structured products research,
quantitative research, and risk management. CEIM may invest in the following asset types:

o Corporate fixed income
o Private Placements
o Commercial Mortgage Loans
o Leveraged Finance (including high yield and bank loans)
o Municipal fixed income
o Global and Macro:
o Global-Indexed Multi-Sector
o Global Developed M…

Our research-based investment process integrates credit and structure products research, quantitative research, and gamble management. CEIM may invest in the adopt asset types : o Corporate fixed income o Private Placements o commercial mortgage Loans o Leveraged Finance ( including high succumb and bank loans ) o Municipal fixed income o Global and Macro : o Global-Indexed Multi-Sector o Global Developed M … please cash register to get more information
There have been no material legal or disciplinary events related to CEIM that are required to be
disclosed pursuant to Item 9.

There have been no fabric legal or corrective events related to CEIM that are required to be disclosed pursuant to Item 9. please register to get more information
As a wholly-owned subsidiary of the Partnership, CEIM is part of a diversified, corporate organization.
We are affiliated with many types of U.S. financial service providers, including insurance companies,
broker-dealers, and other investment advisers. Some of our employees are officers of and/or provide
services to some of these affiliates.
InvesTrust, an affiliated trust company provides custodial and back office services to CEIM clients. In
addition, they will also act as the inter…

As a wholly-owned auxiliary of the Partnership, CEIM is function of a diversify, corporate constitution. We are affiliated with many types of U.S. fiscal service providers, including indemnity companies, broker-dealers, and other investment advisers. Some of our employees are officers of and/or provide services to some of these affiliates. InvesTrust, an affiliate confidence caller provides custodial and back office services to CEIM clients. In addition, they will besides act as the bury … please register to get more information
Trading
Code of Ethics
We maintain a code of ethics as required by applicable SEC rules. Our code of ethics requires
employees to conduct business in an honest and forthright manner in accordance with the highest of
ethical standards. In addition, the code of ethics requires employees to put client interests ahead of
our own and disclose actual and potential meaningful conflicts of interest. The code of ethics
incorporates our information barrier and personal securities…

We maintain a code of ethics as required by applicable SEC rules. Our code of ethics requires employees to conduct business in an honest and blunt manner in accord with the highest of ethical standards. In addition, the code of ethics requires employees to put node interests ahead of our own and disclose actual and electric potential meaningful conflicts of interest. The code of ethics incorporates our data barrier and personal securities … please register to get more information

Factors Used in Selecting or Recommending Broker-Dealers

Counterparties

Transactions for client accounts are delivered with each payment transaction. In the event CEIM decides
to use a counterparty to effect transactions for client accounts, all counterparties will be reviewed,
approved and monitored by our credit research group.

Execution of Trades

We seek to execute transactions in client accounts at the most advantageous terms r…

Transactions for node accounts are delivered with each payment transaction. In the event CEIM decides to use a counterparty to effect transactions for node accounts, all counterparties will be reviewed, approved and monitored by our accredit research group.We search to execute transactions in client accounts at the most advantageous terms r … please register to get more information
Periodic Review of Client Accounts

CEIM closely monitors portfolios on behalf of clients. CEIM portfolio managers and professional staff
continually review and analyze portfolio performance, concentrations, duration, valuations and other
relevant portfolio metrics.

Risk Management Reviews

CEIM portfolio managers are responsible for risk management on a daily basis. Additionally, CEIM
formally reviews portfolio risks at least monthly with me…

CEIM closely monitors portfolios on behalf of clients. CEIM portfolio managers and professional staff continually revue and analyze portfolio operation, concentrations, duration, valuations and early relevant portfolio metrics.CEIM portfolio managers are responsible for risk management on a daily basis. additionally, CEIM formally reviews portfolio risks at least monthly with me … please register to get more information
Other Compensation
We do not receive economic benefits from anyone who is not a client in connection with the advisory
services we provide to our clients.
Client Referrals
We do not engage in providing client referrals to any other party. Similarly, we do not compensate
any parties for the referral of client accounts. However, as noted, certain components of the
compensation of sales employees is determined based on the successful sales of our and our
affiliates advi…

We do not receive economic benefits from anyone who is not a customer in joining with the advisory services we provide to our clients.We do not engage in providing node referrals to any other party. similarly, we do not compensate any parties for the referral of node accounts. however, as noted, certain components of the compensation of sales employees is determined based on the successful sales of our and our affiliates advi … please register to get more information
We generally do not take physical custody of the assets of our clients. Client assets are generally
held in custodial accounts with banks, broker-dealers or other qualified custodians retained by our
clients under arrangements negotiated by them. Although we do not have possession of client assets,
when our clients permit or instruct us to deduct our management fees directly from their custodial
accounts, the SEC nevertheless deems us to have custody over the assets of those clients. The…

We by and large do not take physical custody of the assets of our clients. Client assets are generally held in custodial accounts with banks, broker-dealers or early modify custodians retained by our clients under arrangements negotiated by them. Although we do not have monomania of client assets, when our clients permit or instruct us to deduct our management fees directly from their custodial accounts, the SEC however deems us to have hands over the assets of those clients. The … please cash register to get more information

We typically have the discretionary authority to purchase and sell assets for client accounts. This
authority is granted pursuant to a written investment management or similar agreement between the
client and CEIM.

Our discretionary authority to manage client accounts is in all cases subject to the specific objectives,
guidelines and limitations set forth in the applicable investment management agreement.

We typically have the discretionary authority to purchase and sell assets for node accounts. This authority is granted pursuant to a written investment management or like agreement between the node and CEIM.Our discretionary authority to manage customer accounts is in all cases subject to the specific objectives, guidelines and limitations set away in the applicable investment management agreement. please register to get more information
Proxy Voting
We do not generally accept the authority to vote proxies or engage in other solicitations on behalf of
clients.
Class Actions
In addition to voting rights with respect to securities held in our clients’ portfolios, there may be other
rights associated with those securities, including the right or opportunity to participate in class actions.
We generally will not participate in class actions on behalf of clients.
Corporate Actions
In addition to v…

We do not generally accept the authority to vote proxies or engage in other solicitations on behalf of clients.In accession to voting rights with respect to securities held in our clients ’ portfolios, there may be early rights associated with those securities, including the right or opportunity to participate in class actions. We broadly will not participate in class actions on behalf of clients.In accession to v … please record to get more information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to our clients.

We have no fiscal commitment that impairs our ability to meet contractual and fiduciary commitments to our clients. please register to get more information
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