FocusGrowth Asset Management, LP

FocusGrowth provides discretionary investment management to private pooled vehicles and co‑investment funds, managing approximately $412 million on behalf of those pooled clients and, in the future, may advise separately managed accounts for institutional, non‑retail investors. Its advisory services focus on privately negotiated and public investments in equity and debt, including loan originations and participations, with an expressed emphasis on companies operating in the legal cannabis industry.

The firm pursues an opportunistic strategy aimed at long‑term appreciation with current income, deploying capital across secured and unsecured debt, term loans (including multi‑tranche and unitranche financings), and equity positions that may arise from restructurings or foreclosures; it also describes use of hedging, derivatives and leverage in managing risk. Investment decisions are made on a discretionary basis under the Funds’ governing documents, with co‑investment allocation policies (including priority and non‑priority co‑investor rules) and typical private‑fund carried interest and allocation procedures.

The brochure discloses several features that differentiate FocusGrowth from many peers: an affiliated entity, FG Agency Lending LLC, that arranges loans and will receive borrower‑paid “Service Fees”; an affiliate, FG Advisors LLC, that provides advisory and consulting services to third parties; and a strategic institutional investor that holds revenue‑sharing rights, an Advisory Board seat, priority co‑investment rights and most‑favored‑nation side‑letter protections. The firm’s detailed discussion of derivatives, swaps and the role of CFTC/SEC regulation, together with the affiliate fee arrangements and the strategic investor terms, highlights regulatory and conflict‑of‑interest considerations that are less common among investment managers of this type.