N-CSRS 1 d811401dncsrs.htm HEDGE FUND GUIDED PORTFOLIO SOLUTION Hedge Fund Guided Portfolio Solution

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form N-CSR

CERTIFIED SHAREHOLDER REPORT OF

REGISTERED MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number: 811-23347

Hedge Fund Guided Portfolio Solution

(Exact name of Registrant as specified in charter)

900 North Michigan Avenue, Suite 1100

Chicago, Illinois 60611

(Address of principal executive offices) (Zip code)

 

Scott J. Lederman

Grosvenor Registered Funds

900 North Michigan Avenue

Suite 1100

Chicago, Illinois 60611

 

George J. Zornada, Esq.

K&L Gates LLP

State Street Financial Center

One Lincoln Street

Boston, Massachusetts 02111-2950

(Name and address of agent for service)

Registrant’s telephone number, including area code: (312) 506-6500

Date of fiscal year end: March 31

Date of reporting period: September 30, 2019

 

1


ITEM 1 – REPORTS TO STOCKHOLDERS

The Report to Shareholders is attached hereto.

 

2


 

 

 

HEDGE FUND GUIDED PORTFOLIO SOLUTION

 

 

Consolidated Financial Statements (unaudited)

For the Six Months Ended September 30, 2019


Hedge Fund Guided Portfolio Solution

Consolidated Financial Statements (unaudited)

For the Six Months Ended September 30, 2019

Contents

 

Consolidated Statement of Assets and Liabilities (unaudited)      1  
Consolidated Schedule of Investments (unaudited)      2  
Consolidated Statement of Operations (unaudited)      5  
Consolidated Statement of Changes in Net Assets      6  
Consolidated Statement of Cash Flows (unaudited)      7  
Consolidated Financial Highlights      8  
Notes to Consolidated Financial Statements (unaudited)      9  

The Fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (the “SEC”) for the first and third quarters of each fiscal year on Form N-Q. The Fund’s Form N-Qs are available (i) without charge, upon request, by calling (877) 355-1469; and (ii) on the SEC’s website at www.sec.gov.

The Fund has adopted Proxy Voting Policies and Procedures under which the Fund votes proxies relating to securities held by the Fund. In addition, the Fund files Form N-PX, with its complete proxy voting record for the 12 months ended June 30th, no later than August 31st of each year. A description of the Fund’s Proxy Voting Policies and Procedures and the Fund’s proxy voting record (Form N-PX) are available (i) without charge, upon request, by calling (855) 426-9321; and (ii) on the SEC’s website at www.sec.gov.

The Fund’s prospectus and statement of additional information include additional information about the Trustees of Fund and other information about the Fund. These documents are available without charge, upon request, by calling (877) 355-1469.


Hedge Fund Guided Portfolio Solution

Consolidated Statement of Assets and Liabilities (unaudited)

September 30, 2019

 

ASSETS

  

Investments in Investment Funds, at fair value (cost $161,763,004)

   $         161,624,468  

Cash

     3,811,386  

Investments in Investment Funds paid in advance

     18,700,000  

Redemptions receivable from investments in Investment Funds

     11,034,549  

Deferred offering costs

     28,346  

Prepaid insurance

     4,638  
  

 

 

 

Total assets

     195,203,387  
  

 

 

 

LIABILITIES

  

Shareholders’ subscriptions received in advance

     12,355,000  

Loan payable

     1,400,000  

Repurchase of Shares payable

     164,847  

Advisory fee payable

     160,406  

Professional fees payable

     153,000  

Administration fee payable

     85,737  

Distribution fee payable - Class A

     69,318  

Commitment fee payable

     15,532  

Other liabilities

     64,802  
  

 

 

 

Total liabilities

     14,468,642  
  

 

 

 

NET ASSETS

   $ 180,734,745  
  

 

 

 

NET ASSETS

  

Represented by:

  

Paid-in Capital

   $ 182,117,341  

Distributable earnings

     (1,382,596 )  
  

 

 

 

NET ASSETS

   $ 180,734,745  
  

 

 

 

NET ASSETS - CLASS I

   $ 122,410,847  
  

 

 

 

NET ASSETS - CLASS A

   $ 58,323,898  
  

 

 

 

Class I Net asset value per Share (Shares outstanding of 120,519.49)

   $ 1,015.69  
  

 

 

 

Class A Net asset value per Share (Shares outstanding of 58,965.81)

   $ 989.11  
  

 

 

 

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

1


Hedge Fund Guided Portfolio Solution

Consolidated Schedule of Investments (unaudited)

September 30, 2019

 

Investment Funds*   

First

Acquisition
Date

     Cost     

Fair

Value

  % Net Assets      Liquidity**  

Event Driven

             

Elliott International Ltd.

     1/1/2019      $ 2,913,628      $ 2,989,043       1.65%        Quarterly  

Pentwater Merger Arbitrage Fund, Ltd.

     8/1/2019        12,885,000        12,948,638       7.16%        Monthly  

Wexford Offshore Spectrum Fund

     11/1/2018        9,970,000        9,502,569       5.26%        Quarterly  

York European Opportunities Unit Trust

     11/1/2018        985,000        1,009,005        0.56%        Quarterly  
     

 

 

    

 

 

 

 

 

 

    

Total Event Driven

        26,753,628        26,449,255       14.63%     
     

 

 

    

 

 

 

 

 

 

    

Long and/or Short Equity

             

BlackRock European Hedge Fund Limited

     4/1/2019        5,550,000        5,507,082       3.05%        Monthly  

Hitchwood Capital Partners, LP (a)

     11/1/2018        10,870,060        10,245,182       5.67%        Quarterly  

Redmile Capital Fund, LP (a)

     11/1/2018        15,300,000        14,740,130       8.15%        Quarterly  

Renaissance Institutional Equities Fund, LLC (a)

     11/1/2018        21,555,000        22,661,885       12.54%        Monthly  

Steadfast International, Ltd.

     11/1/2018        19,430,000        20,066,722       11.10%        Quarterly  
     

 

 

    

 

 

 

 

 

 

    

Total Long and/or Short Equity

        72,705,060        73,221,001       40.51%     
     

 

 

    

 

 

 

 

 

 

    

Macro/Commodities

             

Alphadyne International Fund, Ltd.

     9/1/2019        5,100,000        5,104,856       2.83%        Quarterly  

SteelMill Fund, Ltd.

     7/1/2019        8,550,000        7,937,061       4.39%        Quarterly  

Element Capital Feeder Fund Ltd.

     1/1/2019        4,750,000        4,936,557       2.73%        Quarterly  
     

 

 

    

 

 

 

 

 

 

    

Total Macro/Commodities

        18,400,000        17,978,474       9.95%     
     

 

 

    

 

 

 

 

 

 

    

Multi-Arbitrage

             

Canyon Value Realization Fund Ltd.

     11/1/2018        18,160,000        18,142,719       10.04%        Quarterly  

Magnetar Constellation Fund, Ltd.

     11/1/2018        4,525,345        4,605,365       2.55%        Quarterly  

Myriad Opportunities Offshore Fund Ltd.

     11/1/2018        4,670,000        4,444,001       2.46%        Quarterly  

Shelter Growth Opportunities Fund, Ltd.

     11/1/2018        10,631,250        10,791,146       5.97%        Quarterly  
     

 

 

    

 

 

 

 

 

 

    

Total Multi-Arbitrage

        37,986,595        37,983,231       21.02%     
     

 

 

    

 

 

 

 

 

 

    

Relative Value

             

ExodusPoint Partners International Fund, Ltd.

     11/1/2018        1,100,000        1,137,819       0.63%        Quarterly  

HBK Multi-Strategy Offshore Fund, Ltd.

     11/1/2018        4,817,721        4,854,688       2.69%        Quarterly  
     

 

 

    

 

 

 

 

 

 

    

Total Relative Value

        5,917,721        5,992,507       3.32%     
     

 

 

    

 

 

 

 

 

 

    

Total Investments in Investment Funds

      $ 161,763,004      $ 161,624,468       89.43%     
     

 

 

    

 

 

 

 

 

 

    

Total Investments

      $         161,763,004      $ 161,624,468       89.43%     
     

 

 

    

 

 

 

 

 

 

    

Other Assets, Less Liabilities

           19,110,277       10.57%     
        

 

 

 

 

 

 

    

Net Assets

         $         180,734,745       100.00%     
        

 

 

 

 

 

 

    

 

*

Non-income producing investments. The Fund’s investments in Investment Funds are considered to be illiquid and may be subject to limitations on redemptions, including the assessment of early redemption fees. Investment Funds are restricted securities per Rule 12-12.8 of Regulation S-X.

 

**

Available frequency of redemptions after initial lock-up period.

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

2


Hedge Fund Guided Portfolio Solution

Consolidated Schedule of Investments (unaudited) (continued)

September 30, 2019

 

(a)

The Investment Fund is held by Series A-C of HFGPS Subsidiary, LLC (the “Sub-Fund”), a wholly owned subsidiary of the Fund. Investment Funds held by the Sub-Fund represents 29.48% of the total investments in Investment Funds.

The following table represents the geographic regions of the Fund’s investments based on the investment mandate of each Investment Fund:

 

    Geographic Location    Percent of Investments in

 

Investment Funds

     
 

Asia

     2.75  
 

Europe

     4.03    
 

Global

     34.53    
 

United States/Canada

     58.69    
    

 

 

   
 

Total

     100.00  
    

 

 

   

The following table describes the investments held within each investment category:

(a) Event Driven This investment category includes the Investment Funds that take significant positions in companies with special situations, including distressed stocks, mergers and takeovers.

 

    Notice Period    Redemption Restrictions and Terms*   
    30 - 96 Days    0-1 year.   

(b) Long and/or Short Equities This investment category includes the Investment Funds that make long and short investments in equity securities that are deemed by the Investment Managers to be under or overvalued. The Investment Managers typically do not attempt to neutralize the amount of long and short positions.

 

    Notice Period    Redemption Restrictions and Terms*   
    34 - 75 Days    0-1 year.   

(c) Macro/Commodities This investment category includes the Investment Funds that invest in a variety of instruments including global currencies, interest rates, sovereign debt and commodities based on an analysis of many broad factors including: global monetary and trade policy, geopolitical events, supply and demand, global investor sentiment and various technical factors.

 

    Notice Period    Redemption Restrictions and Terms*   
    90 - 95 Days    0-1 year.   

 

The accompanying notes are an integral part of these Consolidated Financial Statements.
3


Hedge Fund Guided Portfolio Solution

Consolidated Schedule of Investments (unaudited) (continued)

September 30, 2019

 

(d) Multi-Arbitrage This investment category includes the Investment Funds that seek to exploit price differences of identical or similar financial instruments, on different markets or in different forms by simultaneously purchasing and selling an asset in order to profit from the difference.

 

    Notice Period    Redemption Restrictions and Terms*   
    62 - 90 Days    0-2 years.   

(e) Relative Value This investment category includes the Investment Funds that seek to take advantage of price differentials between related financial instruments, such as stocks and bonds, by simultaneously buying and selling the different securities—thereby allowing investors to potentially profit from the “relative value” of the two securities.

 

    Notice Period    Redemption Restrictions and Terms*   
    60 - 90 Days    0-1 year.   

 

  *

The information summarized in the table above represents the general terms of the specific asset class. Individual Investment Funds may have terms that are more or less restrictive than those terms indicated for the asset class as a whole. In addition, most Investment Funds have the flexibility, as provided for in constituent documents, to modify and waive such terms.

 

The accompanying notes are an integral part of these Consolidated Financial Statements.
4


Hedge Fund Guided Portfolio Solution

Consolidated Statement of Operations (unaudited)

For the Six Months Ended September 30, 2019

 

NET INVESTMENT INCOME

  

Interest income

   $ 91,676   
  

 

 

 

EXPENSES

  

Advisory fee

     355,466  

Offering cost expense

     170,076  

Professional fees

     157,783  

Distribution fee expense - Class A

     124,843  

Registration fees

     123,471  

Administration fee

     85,815  

Board of Trustees’ compensation

     75,000  

Facility fees

     19,684  

Insurance fees

     4,638  

Other expenses

     53,242  
  

 

 

 

Total expenses

     1,170,018  
  

 

 

 

Net investment loss before expense limitation reimbursement

     (1,078,342
  

 

 

 

Expense limitation reimbursement

     135,446  

Net investment loss

     (942,896
  

 

 

 

REALIZED AND UNREALIZED GAIN/(LOSS) ON INVESTMENTS

  

Net realized gain/(loss) from investments

     (197,106

Change in net unrealized appreciation/(depreciation) on investments

     (780,451
  

 

 

 

Net realized and unrealized gain/(loss) on investments

     (977,557
  

 

 

 

NET DECREASE IN NET ASSETS RESULTING FROM OPERATIONS

   $         (1,920,453
  

 

 

 

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

5


Hedge Fund Guided Portfolio Solution

Consolidated Statement of Changes in Net Assets

 

Net Assets, November 1, 2018 (commencement of operations)

   $ -  

Shareholders’ subscriptions

     24,129,000  
  

 

 

 

Net increase in Net Assets resulting from capital transactions

    

 

24,129,000

 

 

 

  

 

 

 

Net investment loss

     (104,058

Change in accumulated net unrealized appreciation/(depreciation) on investments

     641,915  
  

 

 

 

Net increase in Net Assets resulting from operations

    

 

537,857

 

 

 

  

 

 

 

Net Assets, March 31, 2019

     24,666,857  

Shareholders’ subscriptions

     158,153,188  

Shareholders’ interests repurchased

     (164,847
  

 

 

 

Net increase in Net Assets resulting from capital transactions

    

 

157,988,341

 

 

 

  

 

 

 

Net investment loss

     (942,896

Net realized gain/(loss), net of taxes

     (197,106

Change in accumulated net unrealized appreciation/(depreciation) on investments

     (780,451
  

 

 

 

Net decrease in Net Assets resulting from operations

    

 

(1,920,453

 

 

  

 

 

 

Net Assets, September 30, 2019 (unaudited)

   $

 

        180,734,745

 

 

 

  

 

 

 

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

6


Hedge Fund Guided Portfolio Solution

Consolidated Statement of Cash Flows (unaudited)

For the Six Months Ended September 30, 2019

 

CASH FLOWS FROM OPERATING ACTIVITIES

  

Net decrease in Net Assets resulting from operations

   $ (1,920,453

Adjustments to reconcile net decrease in Net Assets resulting from operations to net cash

used in operating activities:

  

Change in net unrealized (appreciation)/depreciation on investments

     780,451  

Net realized (gain)/loss from investments

     197,106  

Purchases of Investment Funds

     (145,498,687

Proceeds from the sale of Investment Funds

     2,483,969  

Proceeds from short-term investments, net

     2,388,925  

(Increase)/Decrease in operating assets:

  

Due from Adviser

     209,844  

Deferred offering costs

     170,076  

Prepaid insurance

     (4,638

Increase/(Decrease) in operating liabilities:

  

Advisory fee payable

     138,931  

Professional fees payable

     84,500  

Administration fee payable

     54,185  

Distribution fee payable – Class A

     69,318  

Commitment fee payable

     15,532  

Organizational expenses payable

     (114,826

Facility fees payable

     (5,288

Other liabilities

     53,599  
  

 

 

 

Net cash used in operating activities

     (140,897,456
  

 

 

 

CASH FLOWS FROM FINANCING ACTIVITIES

  

Proceeds from Shareholders’ subscriptions

     141,875,000  

Proceeds from bank note

     1,400,000  
  

 

 

 

Net cash provided by financing activities

     143,275,000  
  

 

 

 

Net increase in cash

     2,377,544  

Cash at beginning of period

     1,433,842  
  

 

 

 

Cash at end of period

   $         3,811,386  
  

 

 

 

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

7


Hedge Fund Guided Portfolio Solution

Consolidated Financial Highlights

The following represents certain ratios to average Net Assets, total return, and other supplemental information for the period indicated:

 

    Class A**   Class I
    For the
six months ended
September 30, 2019***
(unaudited)
  For the
six months ended
September 30, 2019***
(unaudited)
  November 1, 2018
(commencement of
operations) through
March 31, 2019****

Per Share operating performance: *

     

Net asset value per Share, beginning of period

  $ 1,000.00         $              1,022.97         $             1,000.00      

Income/(loss) from investment operations:

     

Net investment loss

    (10.07     (6.42     (5.59

Net realized and unrealized gain/(loss) from investments operations

    (0.81     (0.87     28.56  
 

 

 

 

 

 

 

 

 

 

 

 

Total income/(loss) from investment operations

    (10.89     (7.29     22.97  
 

 

 

 

 

 

 

 

 

 

 

 

Distributions to Shareholders from net investment income

    -           -           -      
 

 

 

 

 

 

 

 

 

 

 

 

Net asset value per Share, end of period

  $ 989.11     $ 1,015.69     $ 1,022.97  
 

 

 

 

 

 

 

 

 

 

 

 

Ratios to average Net Assets: (a)

     

Net investment loss - net of expense limitation reimbursement (b)

    (2.27%)           (1.36%)           (1.46%)      
 

 

 

 

 

 

 

 

 

 

 

 

Expenses - gross of expense limitation reimbursement (b)

    (2.60%)           (1.77%)           8.75%      
 

 

 

 

 

 

 

 

 

 

 

 

Expenses - net of expense limitation reimbursement (b)

    (2.43%)           (1.52%)           1.51%      
 

 

 

 

 

 

 

 

 

 

 

 

Total return (c)

    (1.09%)           (0.71%)           2.30%      
 

 

 

 

 

 

 

 

 

 

 

 

Portfolio turnover rate:

    13.05%           13.05%           0.00%      
 

 

 

 

 

 

 

 

 

 

 

 

Net Assets, end of period ($000)

  $ 58,324         $ 122,411         $ 24,667      

 

*

Based on Shares outstanding at the end of each month.

 

**

Commenced operations on April 1, 2019.

 

***

The ratios, excluding portfolio turnover and total return, for the period April 1, 2019 through September 30, 2019 have been annualized.

 

****

The ratios, excluding portfolio turnover rate and total return, for this period have been annualized. All non-recurring expenses, including those related to the organization of the fund have not been annualized.

 

(a)

Average Net Assets is determined by using the net assets as of the first day of the fiscal period and at the end of each month during the period.

 

(b)

Ratio does not reflect the Fund’s proportionate share of the net income (loss) and expenses, including incentive fees or allocations, of the Investment Funds. The Investment Funds’ expense ratios, excluding incentive fees or allocations, range from 0.05% to 7.94% (unaudited).

The Investment Funds’ incentive fees or allocations can be up to 30% of profits earned (unaudited).

 

(c)

Total return is not annualized. Total return is based on the combination of changes in the net asset value per Share and the effect of reinvested dividend income and reinvested capital gains distributions, if any, at the average price paid per Share at the time of reinvestment.

The accompanying notes are an integral part of these Consolidated Financial Statements.

 

8


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (unaudited)

September 30, 2019

1. Organization

Hedge Fund Guided Portfolio Solution (the “Fund”) was organized as a Delaware statutory trust on April 12, 2018, and is registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as a closed-end, non-diversified, management investment company. The Fund commenced operations on November 1, 2018.

The Fund’s primary investment objective is to seek absolute returns with low to moderate volatility and with minimal correlation to the global equity and fixed income markets while preserving capital. The Fund invests primarily through a multi-manager, multi-strategy program of investment in a diverse group of private investment funds (“Investment Funds”), managed by a select group of alternative asset managers (“Investment Managers”). The Fund seeks to implement its investment objective by investing in Investment Funds that will invest both long and short, in a wide range of “alternate” investment strategies.

The Fund will make the election to be treated as a regulated investment company under subchapter M of the Internal Revenue Code of 1986, as amended (the “Code”) (i.e. a 1099-issuing “RIC”).

The Board of Trustees (the “Board”) has overall responsibility to manage and supervise the operations of the Fund, including the exclusive authority to oversee and to establish policies regarding the management, conduct and operation of the Fund’s business.

Under the supervision of the Board and pursuant to an investment advisory agreement, Grosvenor Capital Management L.P., (the “Adviser” or “Grosvenor”) serves as the investment adviser of the Fund. The Adviser is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and is responsible for the day-to-day operations of the Fund as well as all portfolio management and investment advisory services.

The Fund holds certain investments in the HFGPS Subsidiary, LLC (the “Sub-Fund”), a Delaware limited liability company and wholly owned subsidiary of the Fund.

The Fund operates two share classes, Class I Shares (“Class I”) and Class A Shares (“Class A”). Class A commenced operations on April 1, 2019. All Shares issued prior to April 1, 2019 have been designated as Class I Shares in terms of rights accorded and expenses borne. Class I and Class A Shares are subject to different fees and expenses.

2. Summary of Significant Accounting Policies

a. Basis of Presentation

The Adviser has determined that the Fund meets the requirements of an investment company and as a result, maintains its accounting records and has presented these consolidated financial statements in accordance with the reporting requirements under Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) Topic 946, Financial Services – Investment Companies (“ASC 946”).

 

9


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

a. Basis of Presentation (continued)

 

The accompanying consolidated financial statements of the Fund have been prepared in conformity with accounting principles generally accepted in the United States (“GAAP”) and are stated in United States Dollars (“U.S. Dollars” or “$”). The following is a summary of the significant accounting and reporting policies used in preparing the consolidated financial statements:

b. Basis of Consolidation

The accompanying consolidated financial statements include the accounts of the Sub-Fund, which was established primarily to hold and manage certain Investment Funds. As of September 30, 2019, the Fund owns 100% of the Sub-Fund. The Fund’s investment in the Sub-Fund, including the results of its operations, has been consolidated and all intercompany accounts and transactions have been eliminated in consolidation.

c. Use of Estimates

The preparation of consolidated financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the amounts reported in the consolidated financial statements and accompanying consolidated notes. Management believes that the estimates utilized in preparing the Fund’s consolidated financial statements are reasonable and prudent; however, the actual results could differ from these estimates.

d. Income Taxes and Distributions

The Fund is classified as a corporation for federal income tax purposes, and intends to elect to be treated, and expects each year to qualify as a RIC under Subchapter M of the Code. The Fund has elected to have a tax year end of September 30. The Fund intends to annually distribute to its Shareholders substantially all of its ordinary income and net realized gains sufficient to relieve it from all, or substantially all, federal income and excise taxes. Accordingly, no provision for U.S. federal income or excise tax has been recorded in these consolidated financial statements.

 

10


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

d. Income Taxes and Distributions (continued)

 

As of September 30, 2019, the tax cost and unrealized appreciation (depreciation) of the investments held by the Fund, were as follows:

 

            Investments             
Tax Cost Basis of Investments     $ 162,714,408      
Gross Unrealized Appreciation     $ 2,031,187      
Gross Unrealized Depreciation     (3,121,127)     
 

 

 

 

  
Net Unrealized Appreciation/(Depreciation)     $ (1,089,940)     
 

 

 

 

  

The tax basis of undistributed earnings for the fiscal tax year ended September 30, 2019, shown below represents distribution requirements that will be met by the Fund subsequent to the fiscal tax year end in order to satisfy income tax requirements and the capital loss carryforward as of the tax year end. The capital loss carryforward is not subject to expiration. The capital loss carryforwards will reduce the Fund’s taxable income arising from future net realized gains on investments, if any, to the extent permitted by the Code, and thus will reduce the amount of the distributions to Shareholders which would otherwise be necessary to relieve the Fund of any liability for federal tax.

 

Undistributed

Ordinary Income

   Capital Loss
            Carryforward            
 

                                                                              $    -

     $     (50,182) 

The authoritative guidance on accounting for and disclosure of uncertainty in any significant tax positions requires management to determine whether a tax position of the Fund is “more likely than not” to be sustained upon examination, including resolution of any related appeals or litigation processes, based on the technical merits of the position. Management of the Fund has concluded that there are no significant uncertain tax positions that would require recognition in the financial statements. Furthermore, management of the Fund is also not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. Therefore no additional tax expense, including any interest or penalties was recorded for the six months ended September 30, 2019. To the extent the Fund is required to record interest and penalties, they would be included in income tax expense on its Consolidated Statement of Operations.

Under the respective statute of limitations, the Fund is generally subject to examinations by taxing authorities for up to three years from the date of filing. The Fund has no examinations in progress.

 

11


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

 

e. Security Transactions

Purchases of investments in the Investment Funds are recorded as of the first day of legal ownership of an Investment Fund and redemptions from the Investment Funds are recorded as of the last day of legal ownership. Realized gains or losses on investments in the Investment Funds are recorded at the time of the disposition of the respective investment based on specific identification. Short-term investment transactions are recorded on trade date.

For the six months ended September 30, 2019, aggregate purchases and sales of the Investment Funds amounted to $152,863,687 and $13,518,518, respectively.

f. Capital Transactions

Class I and Class A shares of the Fund (“Shares”) purchased by eligible investors may be accepted as of the first day of each month, or at such times as the Board may determine. Investors who purchase Shares of the Fund in the offering, and other persons who acquire Shares, will become shareholders of the Fund (“Shareholders”).

Because the Fund is a closed-end investment company, Shares are not redeemable at the option of Shareholders and are not exchangeable for Shares of any other fund. Although the Board in its discretion may cause the Fund to offer from time to time to repurchase Shares at the Shareholders’ capital account value, Shares are considerably less liquid than shares of funds that trade on a stock exchange or shares of open-end investment companies. With respect to any offer to repurchase Shares by the Fund, the aggregate repurchase amount will be determined by the Board in its discretion and such repurchase amount may represent only a small portion of outstanding Shares. Because the Fund’s investments in Investment Funds themselves have limited liquidity, the Fund may not be able to fund significant repurchases. Shareholders whose Shares are accepted for repurchase also bear the risk the Fund’s Shareholders’ capital account value may fluctuate significantly between the time that they submit their request for repurchase and the date as of which Shares are valued for the purpose of repurchase.

The Fund may, from time to time, offer to repurchase Shares from its Shareholders pursuant to written tenders by Shareholders. These repurchase offers will be made at such times and on such terms as may be determined by the Board, in its sole discretion, subject to the liquidity of the Fund’s assets and other factors considered by the Board. The Adviser expects that it will recommend to the Board that the Fund offer to repurchase Shares from Shareholders four times each year, effective as of the last day of each calendar quarter. Shareholders can only transfer or assign Shares under certain limited circumstances. Share repurchases are recognized as liabilities when the amount becomes fixed and determinable. This generally will occur on the last day of a fiscal period.    

 

12


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

 

g. Fund Expenses

GRV Securities LLC (“GSLLC”), an affiliate of the Adviser, serves as the distributor of Shares (the “Distributor”) for the Fund. GSLLC received payment of $55,525 from the Fund for these services during the period. Shares may be purchased through the Distributor or brokers or dealers (“Selling Agents”) that have entered into selling agreements with the Distributor.

In connection with Class A Shares of the Fund, under a plan adopted in accordance with Rule 12b-1 under the 1940 Act (“Class A Plan”), the Fund pays the Distributor or a designee a distribution and/or service fee equal to 0.75% per annum of the aggregate net asset value of the Fund’s Class A Shares outstanding, determined as of the last calendar day of each month (“Distribution and Service Fee”). The Distribution and Service Fee is payable monthly. Because this fee is paid out of Class A’s assets on an on-going basis, over time this fee will increase the cost of a Class A Shareholder’s investment and may cost the Shareholder more than paying other types of sales charges. The Distributor or designee may transfer or re-allow all or a portion of the Distribution and Service Fee to certain intermediaries. Class I Shares are not subject to a Distribution and Service Fee.

The Fund bears certain expenses incurred in its business, including, but not limited to, the following: all costs and expenses directly related to portfolio transactions; legal fees; accounting and auditing fees; custodial fees; fees paid to the Fund’s administrator; costs of insurance; service and sub-accounting fees; Advisory Fees (as defined in Note 6); advisory out-of-pocket fees; the fees and travel expenses and other expenses of the Board; all costs with respect to communications regarding the Fund’s transactions between the Adviser and any custodian or other agent engaged by the Fund; and other types of expenses approved by the Board. Expenses, including incentive fees or allocations, of the underlying Investment Funds are not included in expenses reported on the Consolidated Statement of Operations as the effect of these expenses is recognized in realized and unrealized gains and losses.

The Fund has retained BNY Mellon Investment Servicing (U.S.) Inc. (the “Administrator and Transfer Agent”) to provide accounting and certain administrative and investor services to the Fund, including fund accounting, investor accounting, and taxation services, and to act as the registrar and transfer agent. The Bank of New York Mellon (the “Custodian”) serves as the custodian of the assets of the Fund. The Fund pays a monthly fee to the Administrator, Transfer Agent and Custodian based primarily upon month-end Net Assets.

 

13


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

g. Fund Expenses (continued)

 

The Adviser and the Fund have entered into an expense limitation and reimbursement agreement (the “Expense Limitation Agreement”) under which the Adviser will, subject to possible reimbursement by the Fund as described below, waive fees or pay or absorb expenses of the Fund, to the extent necessary to limit the ordinary operating expenses of each class of the Fund to 0.80% per annum of the Fund’s average monthly net assets attributable to such class (the “Expense Limitation”) not including the Advisory Fee, Class A Distribution and Service Fee, investment-related costs and expenses (which includes Investment Fund fees and expenses), taxes, interest and related costs of borrowing, brokerage commissions, payments to certain financial intermediaries for providing servicing, sub-accounting, recordkeeping and/or other administrative services to the Fund and any extraordinary expenses of the Fund. In consideration of the Adviser’s agreement to limit the Fund’s expenses, each class of the Fund will carry forward the amount of fees waived and expenses paid or absorbed by the Adviser in excess of the Expense Limitation, for a period not to exceed three years from the time the fee was waived or the expense was paid or absorbed, and will reimburse the Adviser such amounts. Recoupment will be made as promptly as possible, but will be limited to the lesser of (a) the expense cap in effect at the time of a waiver and (b) the expense cap in effect at the time of the recoupment. The Expense Limitation Agreement will remain in effect until July 31, 2020, and will terminate unless renewed by the Adviser.

As of September 30, 2019, the Adviser may potentially recoup the following amounts from the Fund through the respective expiration dates indicated:

 

Expiration    March 31, 2023      March 31, 2022      March 31, 2021      March 31, 2020  

Amount available for recoupment

     $ 135,446            $ 941,062            $ –            $ –      

For the six months ended September 30, 2019, no expenses were recouped.

h. Organization and Offering Costs

Organization expenses consist of costs incurred to establish the Fund and enable them legally to do business. These expenses are paid by the Fund and charged to expenses as incurred. Offering costs include registration fees and fees regarding the preparation and printing of the initial registration statement. Offering costs are accounted for as deferred costs until operations begin and are then amortized over twelve months on a straight-line basis.

 

14


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

2. Summary of Significant Accounting Policies (continued)

 

j. Other

In accordance with the authoritative guidance on distinguishing liabilities from capital, repurchases are recognized as liabilities when the dollar amount requested in the repurchase notice becomes fixed, which generally occurs on the last day of the fiscal period.

Cash represents cash in banks. Interest income is recorded on the accrual basis. In circumstances when Federal Deposit Insurance Corporation insured limits are exceeded, the risk of default depends on the creditworthiness of The Bank of New York Mellon. Through September 30, 2019, the Fund has not experienced any losses in such accounts and the Adviser monitors the creditworthiness of the counterparties in an attempt to mitigate risk of loss. As a result, repurchases paid after the end of the period, but based upon fixed amounts as of September 30, 2019, are reflected as Repurchase of Shares payable on the Consolidated Statement of Assets and Liabilities at September 30, 2019.

3. Portfolio Valuation

Pursuant to Fund’s valuation policies, the Fund’s Board has delegated to the Adviser the general responsibility for valuation of the investments subject to oversight by the Board. The Board has approved procedures pursuant to which the Fund will value its investments in Investment Funds at fair value, generally at an amount equal to the Net Asset Value (“NAV”) of the Fund’s investment in the Investment Funds as determined by the Investment Fund’s general partner or Investment Manager. This is commonly referred to as using NAV as the practical expedient which allows for estimation of the fair value of an investment in an investment entity based on NAV or its equivalent if the NAV of the investment entity is calculated in a manner consistent with ASC 946. Because of the inherent uncertainty of valuations of the investments in the Investment Funds, their estimated values may differ significantly from the values that would have been used had a ready market for the Investment Funds existed, and the differences could be material.

In accordance with its valuation policies, if no such information is available, or if such information is deemed to not be reflective of fair value by the Adviser, an estimated fair value is determined in good faith by the Adviser pursuant to the Fund’s valuation procedures. All adjustments to fair value made by the Adviser are reviewed and approved by Grosvenor’s Valuation Committee, subject to Board approval.

The Investment Funds generally hold positions in readily marketable securities and derivatives that are valued at quoted market values and/or less liquid non-marketable securities and derivatives that are valued at estimated fair value. However, some of the Investment Funds may invest all or a portion of their assets in illiquid securities and may hold a portion or all of these investments independently from the main portfolio. These separate baskets of illiquid securities (“side pockets”) may be subject to additional restrictions of liquidity that are stricter than the liquidity restrictions applicable to general interests in the Investment Fund. If the Fund withdraws its interest from such an Investment Fund, it may be required to maintain its holding in the side pocket investments

 

15


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

3. Portfolio Valuation (continued)

 

for an extended period of time and retain this remaining interest in the Investment Fund. In instances, where such an Investment Fund closes its operations, the Fund may receive an “in-kind” distribution of a side pocket’s holdings in liquidation of its entire interest in the Investment Fund. The value of side pockets may fluctuate significantly. As of September 30, 2019, the Fund held no investments in side pockets and special liquidating vehicles. Additionally, the governing documents of the Investment Funds generally provide that the Investment Funds may suspend, limit or delay the right of their investors, such as the Fund, to withdraw capital. The primary restrictions applicable to Investment Funds as of September 30, 2019, are described in detail on the Fund’s Consolidated Schedule of Investments.

The Fund prioritizes the inputs to valuation techniques used to measure fair value. In accordance with Accounting Standards Update (“ASU”) No. 2015-07, Disclosures for Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent) (“ASU 2015-07”), investments that are measured at fair value using the NAV per share (or its equivalent) as a practical expedient have not been classified in the fair value hierarchy. When the Adviser believes the reported NAV per share (or its equivalent) of an Investment Fund is not representative of fair value, the Adviser categorizes the investment in accordance with ASC Topic 820, Fair Value Measurement (“ASC 820”).

Short-term investments represent an investment in a money market fund. Short-term investments are recorded at fair value, which is their published net asset value and are listed in the table below as a Level 1 investment.

ASC 820 establishes a hierarchal disclosure framework which prioritizes and ranks the inputs to valuation techniques used in measuring investments at fair value. In accordance with ASC 820, the Fund has categorized its financial instruments into a three level fair value hierarchy. The fair value hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The levels of the fair value hierarchy are defined as follows:

 

  ·  

Level 1 - Inputs that reflect unadjusted quoted prices in active markets for identical assets or liabilities that the Fund has the ability to access at the measurement date. This level of the fair value hierarchy provides the most reliable evidence of fair value and is used to measure fair value whenever available.

 

  ·  

Level 2 - Inputs other than quoted prices that are observable for the asset or liability either directly or indirectly. These inputs include (a) quoted prices for similar assets in active markets; (b) quoted prices for identical or similar assets in markets that are not active; (c) inputs other than quoted prices that are observable.

 

  ·  

Level 3 - Inputs that are unobservable.

 

16


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

3. Portfolio Valuation (continued)

 

Inputs are used in applying valuation techniques and broadly refer to the assumptions that market participants use to make valuation decisions, including assumptions about risk. If the inputs used to measure an investment fall within different levels of the hierarchy, the categorization is based on the lowest level input that is significant to the fair value measurement of the instrument. The determination of the significance of a certain input and what constitutes an observable input requires judgment by the Adviser. The categorization of an investment within the hierarchy is based upon the observable inputs of each investment and does not necessarily correspond to the Adviser’s perceived risk of the investment. The units of account that are valued by the Fund are its interests in the Investment Funds and not the underlying holdings of such Investment Funds. Thus, the inputs used by the Fund to value its investments in each of the Investment Funds may differ from the inputs used to value the underlying holdings of such Investment Funds. Thus, an Investment Fund with all of its underlying investments classified as Level 1 may be classified as a Level 2 or Level 3 investment.    

The following table summarizes the valuation of the Fund’s investments by the above fair value hierarchy levels as of September 30, 2019:

 

Description      Level 1
Quoted Prices
      

Level 2

Significant
Observable Inputs

       Level 3
Significant
Unobservable
Inputs
      

Total Fair Value

at

September 30,

2019

 
Investment Funds measured at NAV          $        $  –        $        $ 161,624,468  

Total Investments

     $        $        $        $ 161,624,468  
                                             

The level classifications in the table above may not be indicative of the risk.

4. Capital Commitments of the Fund to the Investment Funds

As of September 30, 2019, the Fund had no unfunded capital commitments to the Investment Funds.

5. Credit Facility

The Fund may borrow from time to time on a short-term basis for liquidity purposes and has established a committed U.S. Dollar denomination credit facility (the “Facility”) with one financial institution. The Facility is shared with several other affiliated funds which are managed by the Adviser and was originally set to terminate on September 13, 2019. A decision was made to extend the current Facility to October 21, 2019 at which time the Facility will renew through October 19, 2020. The Facility contains annual renewal provisions. Under the terms of the Facility, the Fund may draw up to $17,000,000 subject to a combined maximum amount of $580,500,000. The Facility is subject to annual fees related to any unused portion of the Facility which are allocated based on the amount available to the Fund. Under the terms of the Facility, the Fund is subject to, among other things, Investment Fund liquidity tests and Investment Fund concentration tests. In the event that

 

17


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

5. Credit Facility (continued)

 

the Fund breaches certain of the liquidity and concentration covenants, the Fund’s ability to borrow is reduced. Facility fees payable, as reflected on the Consolidated Statement of Assets and Liabilities, represents unused borrowing under the Facility which accrues and compounds interest daily based on the base rate of the financial institution plus a spread. As of September 30, 2019, the Fund has $1,400,000 of loan payable outstanding on the Consolidated Statement of Assets and Liabilities. During the six months ended September 30, 2019, the Fund had average outstanding borrowings of $7,609 with an average interest rate of 5.00%. Maximum borrowings of $1,400,000 were outstanding for one day as of September 30, 2019.

6. Related Party Transactions

The Board is made up of six Board members, five of whom are not “interested persons,” as defined by the 1940 Act, (the “Independent Trustees”). The Independent Trustees each receive annual compensation in the amount of $30,000 for their services to Fund. All compensation to the Independent Trustees is paid by the Fund. All Independent Trustees may be reimbursed for out-of-pocket expenses of attendance at each regular or special meeting of the Board or of any committee thereof and for their expenses, if any, in connection with any other service or activity they perform or engage in as Independent Trustees.

The Fund incurred $75,000 of Independent Trustees’ compensation fees, for the six months ended September 30, 2019, of which none was payable as of September 30, 2019. The total fees and expenses (including compensation) of the Independent Trustees and Fund Officer are shown on the Fund’s Consolidated Statement of Operations.

The Adviser generally bears all of its own expenses incurred in providing services to the Fund, except that the Fund reimburses the Adviser for certain out-of-pocket costs and expenses incurred in connection with the operation of the Fund. Any such costs and expenses will not exceed 0.05% per annum of the Fund’s average month-end net assets.

Pursuant to the terms of the advisory agreement between the Fund and the Adviser, the Fund pays the Adviser a monthly fee at an annual rate of 0.55% (the “Advisory Fee”) based on the Fund’s net assets determined as of the last business day of each month before taking into consideration the Advisory Fee. For the six months ended September 30, 2019, the Advisory Fee was $355,466.

7. Risks

In the normal course of business, the Investment Funds in which the Fund invests trade various financial instruments and may enter into various investment activities with off-balance sheet risk. These include, but are not limited to, short selling, writing option contracts and equity swaps. However, as a result of the investments by the Fund as a limited partner, member or shareholder, the Fund’s liability with respect to its investments in the Investment Funds is generally limited to the NAV of its interest in each Investment Fund. Because the Fund

 

18


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

7. Risks (continued)

 

is a closed-end investment company, Shares are not redeemable at the option of Shareholders and are not exchangeable for of any other fund. Although the Board in its discretion may cause the Fund to offer from time to time to repurchase Shares at the Shareholders’ net asset value, Shares are considerably less liquid than shares of funds that trade on a stock exchange or shares of open-end investment companies. With respect to any offer to repurchase by the Fund, the aggregate repurchase amount will be determined by the Board in its discretion and such repurchase amount may represent only a small portion of outstanding. Because the Fund’s investments in Investment Funds themselves have limited liquidity, the Fund may not be able to fund significant repurchases. Shareholders whose Shares are accepted for repurchase also bear the risk that the Fund’s Shareholders’ net asset value may fluctuate significantly between the time that they submit their request for repurchase and the date as of which Shares are valued for the purpose of repurchase.

As described in the footnotes of the Fund’s Consolidated Schedule of Investments and in Note 3, some Investment Funds have suspended or restricted withdrawals of capital, which increases the liquidity risk for the Fund. Liquidity risk is the risk that the Fund will encounter difficulty in meeting obligations associated with financial liabilities. Among other things, liquidity could be impaired by an inability to access secured and/or unsecured sources of financing, an inability to sell assets or to withdraw capital from the Investment Funds, or unforeseen outflows of cash to meet tender demands. This situation may arise due to circumstances outside of the Fund’s control, such as a general market disruption or an operational issue affecting the Fund or third parties, including the Investment Funds. Also, the ability to sell assets may be impaired if other market participants are seeking to sell similar assets at the same time.

The Fund’s capital investment in the Investment Funds can be withdrawn on a limited basis. As a result, the Fund may not be able to liquidate quickly some of its investments in the Investment Funds in order to meet liquidity requirements or respond to market events.

There are a number of other risks to the Fund. Three principal types of risk that can adversely affect the Fund’s investment approach are market risk, strategy risk, and manager risk. The Fund also is subject to multiple manager risks, possible limitations in investment opportunities, allocation risks, lack of diversification, and other risks for the Fund and potentially for each Investment Fund.

The Adviser utilizes certain quantitative analytical reports generated by its proprietary risk management software to test and refine its judgment regarding: (i) its selection of Investment Funds for the Fund and (ii) the amount of assets to be allocated to each such Investment Fund. Such reports are designed to enable the Adviser to evaluate the risk and return characteristics of proposed alternative allocations to particular Investment Funds. Such reports currently consist of historical simulation analyses, historical simulation stress tests and scenario analyses, forward-looking analyses, look-through exposure analyses, portfolio liquidity analyses, Value at Risk analyses, portfolio optimization and factor analyses.

 

19


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

7. Risks (continued)

 

Certain personnel within the Adviser are responsible for staying abreast of market developments affecting specific investment strategies and communicating their findings to the investment committee. The investment committee reviews such findings to determine whether particular investment strategies continue to be appropriate. The investment committee may determine to add or terminate a strategy based on any number of factors, such as: (i) better alternatives for investing the capital invested in such strategy; (ii) changes in the expectations for the strategy; (iii) a manager specific event at the Investment Fund; or (iv) changes in the investment or economic environment.

The Adviser monitors certain aspects of Investment Fund performance, stays abreast of current developments affecting Investment Funds and communicates from time to time with Investment Managers of Investment Funds to review the performance of the Investment Funds managed by such Investment Managers and to discuss such Investment Managers’ investment outlook.

The Adviser obtains certain exposure-level information that enables the analysis of various strategies, markets and sectors on a “look-through” basis. Although the Adviser does not require that Investment Funds provide position-level transparency, Investment Managers of Investment Funds typically provide aggregated, portfolio-level information with respect to the invested positions and risk profile of their Investment Funds. This information typically includes, but may not be limited to, data related to each

Investment Fund’s long, short, gross, and net exposure, industry sector and geographic exposure (where appropriate), concentration, and leverage. The information set provided by Investment Managers of Investment Funds varies depending upon their strategy focus and investment style. This summary-level risk statistics are augmented through on-going conversations with the Investment Managers of the Investment Funds and, together, are intended to provide an overall view of the Investment Fund’s risk exposure.

8. Guarantees

Under the Fund’s organizational documents, its Independent Trustees and fund officers are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts that contain a variety of representations and warranties and which provide general indemnities. The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims against the Fund that have not yet occurred. However, based on experience, the Fund expects the risk of loss due to these warranties and indemnities to be remote.

 

20


Hedge Fund Guided Portfolio Solution

Notes to Consolidated Financial Statements (continued) (unaudited)

September 30, 2019

 

9. Share Capital

Shares are offered monthly at the NAV of the Fund, which will vary. For the six months ended September 30, 2019, the following Share transactions occurred:

 

     

Beginning

  Shares  

  

Shares

  Subscribed  

  

Shares

  Repurchased  

 

Shares

  Outstanding  

  

NAV per

  Share  

 

Class I

   24,112.95    96,568.84    (162.30)   120,519.49    $     1,015.69    

Class A

      58,965.81      58,965.81    $ 989.11    

10. Subsequent Events

The Fund has evaluated all subsequent events through the date that the consolidated financial statements were issued and noted no material events requiring disclosure.

 

21


ITEM 2 – CODE OF ETHICS

Not applicable.

ITEM 3 – AUDIT COMMITTEE FINANCIAL EXPERT

Not applicable.

ITEM 4 – PRINCIPAL ACCOUNTANT FEES AND SERVICES

Not applicable.

ITEM 5 – AUDIT COMMITTEE OF LISTED REGISTRANTS

Not applicable.

ITEM 6 – INVESTMENTS

 

(a)

Schedule of Investments in securities of unaffiliated issuers as of the close of the reporting period is included as part of the report to shareholders filed under Item 1 of this form.

 

(b)

Not applicable.

ITEM 7 – DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES

Not applicable.

ITEM 8 – PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES

 

(a)

Not applicable.

 

(b)

Not applicable.

ITEM 9 – PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS

Not applicable.

ITEM 10 – SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS

There have been no material changes to the procedures by which members may recommend nominees to the Registrant’s board of trustees, where those changes were implemented after the Registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S-K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR 240.14a-101)), or this Item.

ITEM 11 – CONTROLS AND PROCEDURES

 

(a)

The Registrant’s principal executive officer and principal financial officer, based on their evaluation of the Registrant’s disclosure controls and procedures as of a date within 90 days of the filing of this report, have concluded that such controls and procedures are adequately designed to ensure that information required to be disclosed by the Registrant in Form N-CSR is accumulated and communicated to the Registrant’s management, including the principal executive officer and principal financial officer, or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.

 

3


(b)

There was no change in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the Registrant’s second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.

ITEM 12 – DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END INVESTMENT MANAGEMENT COMPANIES

Not applicable.

ITEM 13 – EXHIBITS

 

(a)(1)

Not applicable.

 

(a)(2)

Certifications pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

 

(a)(3)

Not applicable.

 

(a)(4)

Not applicable.

 

(b)

Certification as required by Section 1350 of Chapter 63 of Title 18 of the United States Code (18 U.S.C. 1350) is attached hereto.

 

4


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

HEDGE FUND GUIDED PORTFOLIO SOLUTION

   By:  

/s/ Scott J. Lederman                                     

  Scott J. Lederman
  Trustee, Chief Executive Officer and President

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the dates indicated.

 

By:      /s/ Scott J. Lederman  

Trustee, Chief Executive

Officer and President

   December 9, 2019
   Scott J. Lederman     
By:      /s/ Kathleen P. Sullivan  

Chief Financial Officer and

Treasurer

   December 9, 2019
   Kathleen P. Sullivan     

 

5