Pendulum Asset Management

Yes. Pendulum Asset Management maintains an active registration with the U.S. Securities and Exchange Commission, which requires periodic updating of Form ADV filings. The most recent filing available through the SEC's Investment Adviser Public Disclosure database confirms the firm remains in operation, though no details about its current client base or investment activities are disclosed.

No. According to its SEC disclosures, Pendulum Asset Management does not advise any registered investment companies or business development companies. Its filing indicates it is an adviser exclusively to separately managed accounts, consistent with a firm that structures bespoke mandates for a private client base rather than pooling capital in vehicles open to external investors.

Ownership information is not publicly available. The firm's regulatory filings shed no light on direct or indirect control persons, a disclosure posture that is generally permissible for exempt reporting advisers under certain thresholds. Without independent reporting or a firm-maintained website, the identity of its principals remains unknown.

The SEC's Investment Adviser Public Disclosure database shows no disciplinary events, regulatory actions, or investor complaints for Pendulum Asset Management. The firm appears to have maintained a clean compliance record across the period of its registration, though this assessment is limited to information the SEC makes publicly available.

Due diligence would hinge on obtaining the firm's full Form ADV Part 2A brochure, which registered advisers are required to deliver to clients and prospective clients. That document discloses material facts about advisory business, fees, conflicts, and personnel that are not summarized in the publicly searchable IAPD extracts. Absent that brochure — or a direct introduction — an allocator has no practical path to evaluating the firm's capabilities.