Regulatory Notice

Version 2 · Effective: March 20, 2026 · Published: March 20, 2026

Malcolm

1. Nature of Services

Malcolm is a business-to-business software-as-a-service (SaaS) platform that provides data management, analytics, and operational tools for investment professionals. Malcolm is a technology vendor — it is not a bank, broker-dealer, investment adviser, fund manager, or financial institution of any kind.

Malcolm is intended exclusively for use by institutional and professional investors, fund managers, and their authorised personnel. It is not designed for, marketed to, or intended for use by retail consumers. By using Malcolm, you represent that you are acting in a professional capacity on behalf of an investment firm, fund, or similar institutional entity.

The platform enables users to:

  • Aggregate and organise investment data (deal pipelines, portfolio companies, fund positions)
  • Perform mathematical modelling (waterfall calculations, distribution schedules, carried interest computations)
  • Generate reports and analytics (fund performance, LP reporting, KPI tracking)
  • Accelerate due diligence through AI-assisted document analysis and data extraction
  • Manage investor relations workflows (capital calls, distributions, LP communications)

All outputs produced by Malcolm — including calculations, reports, charts, AI-generated summaries, and analytics — are informational and operational in nature. They are designed to support, not replace, the professional judgement of qualified investment professionals.


2. Not Investment Advice

Malcolm does not provide investment advice. Specifically:

  • Malcolm does not recommend the purchase, sale, or holding of any security, fund interest, or financial instrument.
  • Malcolm does not predict market performance, asset valuations, or investment outcomes.
  • Malcolm does not act as a fiduciary to any user, investor, or limited partner.
  • Malcolm does not make portfolio allocation recommendations or suggest investment strategies.

All investment decisions — including decisions to invest, divest, allocate capital, make distributions, or modify fund terms — are the sole responsibility of the user and their organisation's investment committee, portfolio managers, or other authorised decision-makers.

The inclusion of financial data, performance metrics, or analytical outputs on the platform does not constitute a recommendation or endorsement of any investment action.

No third party, including Limited Partners, may rely on any report, calculation, or output generated by Malcolm as a substitute for independent audit, formal fund reporting, or professional advice. Reports and outputs are produced for the internal operational use of the customer organisation and carry no representation or warranty of accuracy when shared with or relied upon by third parties.


Malcolm performs financial modelling, including waterfall calculations, carried interest computations, distribution schedules, and fund performance analytics. These outputs are for illustrative and analytical purposes only.

  • Malcolm is not a tax adviser, solicitor, accountant, or auditor.
  • Waterfall calculations and distribution models may not account for all applicable tax rules, partnership agreement nuances, side letter provisions, or jurisdiction-specific regulations.
  • Carried interest and performance fee computations are mathematical models based on user-provided inputs and may not reflect the final amounts due under applicable tax law or partnership agreements.

Malcolm accepts no liability for errors in outputs resulting from inaccurate, incomplete, or outdated data entered by the user, extracted from user-uploaded documents, or sourced from third-party integrations. All models operate on a "data in, data out" basis — the accuracy of outputs is fundamentally dependent on the accuracy of inputs. Users are solely responsible for the quality and completeness of data provided to the platform.

Users must independently verify all outputs and consult their own qualified tax professionals, legal counsel, or accountants before making distributions, filing tax returns, reporting to regulators, or taking any action with legal or financial consequences.


4. AI-Generated Content

Malcolm incorporates artificial intelligence and large language models (LLMs) to assist with data extraction, document analysis, entity resolution, and content synthesis. AI-generated content on the platform is clearly identified where practicable.

Important limitations of AI-generated content:

  • AI outputs may contain errors, omissions, or inaccuracies. They are not a substitute for human review.
  • AI models can produce outputs that appear plausible and authoritative but are factually incorrect (commonly referred to as "hallucinations"). This is an inherent limitation of current AI technology, not a defect specific to Malcolm. Human-in-the-loop review is strictly mandatory — users must verify all AI-generated content before relying on it or sharing it with third parties.
  • AI-generated analysis does not constitute professional advice of any kind — financial, legal, tax, or otherwise.
  • AI models are provided by third-party providers (as disclosed in our Privacy Policy and Subprocessor List) and are subject to the inherent limitations of current AI technology.
  • Users should treat AI-generated outputs as a starting point for their own analysis, not as a definitive conclusion.

Malcolm does not guarantee the accuracy, completeness, or fitness for purpose of any AI-generated content.


5. Regulatory Status

United Kingdom

Malcolm is provided by Part Central Limited, a company registered in England and Wales (Company Number 15296116). Part Central Limited is not authorised or regulated by the Financial Conduct Authority (FCA). The services provided by Malcolm do not constitute a regulated activity under the Financial Services and Markets Act 2000 (FSMA). Malcolm does not:

  • Advise on investments (Article 53, RAO)
  • Arrange deals in investments (Article 25, RAO)
  • Manage investments (Article 37, RAO)
  • Safeguard or administer assets (Article 40, RAO)

Malcolm is a software tool used by regulated and unregulated firms alike. The regulatory obligations of our customers — including compliance with AIFMD, MiFID II, FCA rules, or any other applicable regulation — remain entirely the responsibility of those customers.

United States

Malcolm is provided in the United States by Malcolm Inc., a Delaware corporation. Malcolm Inc. is not registered with the Securities and Exchange Commission (SEC) as an investment adviser under the Investment Advisers Act of 1940, nor as a broker-dealer under the Securities Exchange Act of 1934. Malcolm Inc. does not meet the definition of an "investment adviser" because it does not provide advice about securities for compensation based on individual circumstances.

Malcolm is a software tool. It does not hold client funds, execute securities transactions, or provide bespoke financial advice to retail consumers or any other person.

General

Malcolm does not hold any financial services licence, authorisation, or registration in any jurisdiction. Nothing on the platform or in any communication from Malcolm should be construed as an offer, solicitation, or recommendation to buy or sell any security, fund interest, or financial instrument.


6. User Responsibility

Users of Malcolm are responsible for:

  • Ensuring their own compliance with all applicable laws, regulations, and professional standards
  • Verifying the accuracy and completeness of all data entered into and outputs generated by the platform
  • Ensuring the accuracy and completeness of all data provided to the platform, including data entered manually, uploaded via documents, or synced from third-party integrations
  • Obtaining independent professional advice (legal, tax, accounting, regulatory) before acting on any information derived from the platform
  • Ensuring that their use of the platform — including any sharing of reports, analytics, or AI-generated content with investors, limited partners, or regulators — complies with their own regulatory and contractual obligations
  • Reviewing and verifying all AI-generated content before reliance or distribution

7. Limitation of Liability

This notice supplements the limitation of liability provisions in our Terms of Service. To the maximum extent permitted by applicable law, Malcolm and its affiliates shall not be liable for any losses, damages, or costs arising from reliance on any output, calculation, report, or AI-generated content produced by the platform.


8. Contact

If you have questions about Malcolm's regulatory status or this notice:

  • Email: legal@aimalcolm.com
  • UK Entity: Part Central Limited, registered in England and Wales, Company Number 15296116
  • US Entity: Malcolm Inc., incorporated in Delaware

This Regulatory Notice is reviewed and updated periodically. Users are encouraged to check this page for the most current version.

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