XT Capital Partners, LLC Form CRS Relationship Summary
Introduction
Bluetower offers securities to US investors through XT Capital Partners LLC (“XTC”), which is registered with the Securities & Exchange Commission as a broker-dealer providing private placements of securities. XTC is also members of the Financial Regulatory Authority (“FINRA”), the Municipal Securities Regulatory Board (“MSRB”) and the Securities Investor Protection Corporation (“SIPC”). Brokerage and investment advisory services and fees differ. It is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at: www.investor.gov/CRS which also provides educational materials about broker-dealers, investment advisers and investing.
What investment services and advice can you provide me
The brokerage service XTC provides consists of facilitating investments in private placement funds. As a limited purpose firm, it does not offer accounts or hold your funds and securities. It solicits on behalf of a limited selection of funds. Other firms may offer a wider range of choices, some of which might have lower costs. The securities XTC offers are limited to private investments in illiquid, pooled investment funds. An investment into a fund would be reflected only in the records of that fund and with any transfer agent servicing that fund.
As a broker-dealer, XTC solicits on behalf of the funds. It does not provide any ongoing monitoring after that solicitation i.e.; it will not review your investment in the fund(s) nor recommend whether to continue that investment or not.
Questions to ask:
• Given my financial situation, should I choose a brokerage service?
• Why or why not?
• How will you choose investments to solicit to me?
• What is your relevant experience, including your licenses, education and other qualifications?
• What do these qualifications mean?
Fees, costs, conflicts and standard of conduct
1. What fees will I pay?
You should carefully review the offering documents for the funds you invest in to ensure that you understand all applicable fees for which you may be liable. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time.
Questions to ask:
• If I invest in a private fund offering, how much will go to fees and costs?
• Who will receive those fees?
• What do the costs represent and how much will be invested for me?
2. What are XTC’s legal obligations to me when providing recommendations? How else does
XTC make money and what conflicts of interest does it have?
When XTC provides you with a recommendation, it must act in your best interest and not put its interest ahead of yours. At the same time, the way XTC makes money creates some conflicts with your interests. You should understand and ask XTC about these conflicts because they can affect the recommendations it provides you.
By way of example, XTC may receive placement fees from the sponsors of the funds it solicits. These are generally based upon the amount of interests subscribed to by investors. Thus, XTC’s solicitations of such investments may be influenced by its desire to obtain these fees. It offers investments in a limited number of funds. There may be other funds that XTC does not offer that better suit your needs.
Questions to ask:
• How might XTC’s conflicts of interest affect me and how will you address them?
• How will XTC disclose these conflicts in each circumstance as they arise?
3. How do your financial professionals make money?
XTC’s registered representatives earn a combination of base salary and incentive compensation
based on assets raised for the specific funds.
4. Do XTC financial professionals or XTC have legal or disciplinary history?
No. Visit www.investor.gov/CRS for a free and simple tool to research XTC and its financial
professionals. For additional information about the XTC team and services, visit its web site http://www.xtcapital.com/. You may also review its history at
https://brokercheck.finra.org/firm/summary/118719.
Questions to ask:
• As a financial professional, do you have any disciplinary history?
• For what type of conduct?
5. Additional information
You can find additional information about XTC’s brokerage services at its website
http://www.xtcapital.com. You can also request a copy of the Form CRS Relationship Summary by contacting your marketing representative or by calling 212.909.2681 for a copy or to request up-to-date information.
Questions to ask:
• Who is the primary contact person for my relationship at XTC?
• Is he or she a registered representative of a broker-dealer?
• If I have concerns about how this person is interacting with me, who can I talk to?