INDEPENDENT VERDICT
AIM Defined Investment Fund LLC is a long-running Adams Wealth Advisors private fund with a verified SEC adviser relationship, but its latest Form D creates a reporting anomaly that materially changes how the vehicle should be described. The fund began filing in 2019 and followed a relatively orderly growth path for years: approximately $2.0 million sold to 10 investors in 2019, $5.50 million to 23 investors in 2020, $28.45 million to 58 investors in 2022, $34.21 million to 60 investors in 2023, $41.18 million to 65 investors in 2024, $49.45 million to 82 investors in 2025 and $53.74 million to 103 investors in the April 10, 2026 amendment. The September 1, 2026 amendment then reset the reported amount sold and investor count to zero. Nothing in the reviewed Form D history explains whether that reflects a technical correction, restructuring, reporting change, liquidation, transfer to another structure or some other event. The correct conclusion is therefore not that the fund "lost" or "returned" $53.7 million, but that the latest securities-offering filing no longer carries the previously reported cumulative capital figure and investors need current fund financial statements or manager confirmation to understand the economic position.
The sponsor identity is much clearer. Adams Wealth Management LLC, doing business as Adams Wealth Advisors, is directly identified as manager and promoter in the Form D history, while current Form ADV records identify both Adams Wealth Management LLC and AIM Defined Investment Fund GP LLC as managers or equivalent control entities for AIM Defined Investment Fund. Adams Wealth Advisors is an SEC-registered investment adviser under CRD 286087 / SEC 801-110862, registered since July 24, 2017, and latest 2026 regulatory data report approximately $565.8 million of discretionary regulatory assets across roughly 2,506 accounts. Steven Craig Adams is the central principal associated with the fund and has approximately three decades of industry experience. The adviser's official website uses the same 701 S. Main Street, Logan address and telephone as the issuer, removing any meaningful doubt about the sponsor relationship. Firmwide RAUM should not, however, be interpreted as AIM Defined Investment Fund assets.
The fund is also more operationally complex than the Form D alone suggests. Adams Wealth's regulatory brochure says the firm is registered with the CFTC as a Commodity Pool Operator and that AIM Defined Investment Fund is operated as one of its commodity pools. The same disclosure states that Adams Wealth or its affiliates may receive management and performance fees from private funds into which advisory clients invest, explicitly recognizing the resulting conflict of interest. AIM Defined Investment Fund GP LLC is wholly owned by Adams Wealth and serves as one of the fund's managers. Adams Wealth also has a material relationship with CacheTech Inc., a separate registered investment adviser owned by Steven Craig Adams, Patrick Cormac Murphy and Riley Crosbie; several owners and employees overlap between the two firms. CacheTech's own Form ADV also reports AIM Defined Investment Fund in its private-fund schedule. That overlap demonstrates a shared advisory and technology ecosystem but does not, by itself, establish that CacheTech replaced Adams Wealth as the fund's primary manager.
The most important unresolved issue is the investment strategy itself. Public Form D filings classify AIM Defined Investment Fund only as a pooled investment fund and do not provide enough detail to characterize it confidently as equities, futures, options, managed futures, multi-strategy, structured products or another specific approach. The CFTC/CPO disclosure establishes that the vehicle can fall within the commodity-pool framework, but commodity-pool status alone does not establish its precise current portfolio. FilingDossier should therefore resist filling this gap with generic language based on the name "Defined Investment Fund." The adviser's wider private-fund ecosystem includes AIM Real Asset Opportunities, AIM Ventura vehicles and Fairway Investment Fund, but those separate strategies do not prove the composition of AIM Defined Investment Fund. The public evidence supports the management platform and regulatory structure much more strongly than it supports a detailed fund-level asset-allocation description.
FINAL ASSESSMENT
AIM Defined Investment Fund has a credible and traceable sponsor, a seven-year Form D history and an SEC-registered manager, but the September 2026 filing reset creates an unusually important diligence issue. Through April 2026, the fund's Form D history suggested steady growth to $53.737 million and 103 investors; five months later the filing reported zero amount sold and zero investors without a public explanation. At the same time, Adams Wealth continued to report the vehicle in its private-fund disclosures, and its regulatory brochure continued to identify AIM Defined Investment Fund as an Adams Wealth-managed commodity pool. Investors should therefore obtain the latest NAV, audited financial statements, current number of beneficial owners, subscriptions and redemptions, any restructuring or transfer documents, strategy description, leverage and derivatives exposure, management and incentive fees, administrator, custodian, auditor and CFTC/NFA status before drawing conclusions from the September Form D alone.
KEY FINDINGS / FORM D HISTORY / REPORTING RESET
AIM Defined Investment Fund LLC is a Delaware 3(c)(1) pooled investment vehicle managed by Adams Wealth Management LLC and AIM Defined Investment Fund GP LLC. It relies on Rule 506(b) and has historically maintained an indefinite offering. The Form D series rose from $2,004,890 and 10 investors in April 2019 to $5,495,464 and 23 investors in September 2020, $28,454,412 and 58 investors in April 2022, $34,211,510 and 60 investors in April 2023, $41,178,642 and 65 investors in March 2024, $49,452,023 and 82 investors in March 2025 and $53,737,109 and 103 investors in April 2026. The September 1, 2026 amendment then reports $0 amount sold, zero investors and $0 minimum. These historical values must not be added together, and the September reset must not be interpreted as a $53.7 million loss or redemption without supporting documentation. The April filing's 103 reported investors alongside a Section 3(c)(1) exclusion also deserves careful legal reconciliation because Form D investor count and Investment Company Act beneficial-owner counting are not necessarily identical concepts.
MANAGER / REGULATORY STRUCTURE / CONFLICTS
Adams Wealth Advisors is the public-facing name of Adams Wealth Management LLC, an SEC-registered adviser under CRD 286087 / SEC 801-110862. Latest 2026 regulatory data report approximately $565.8 million of discretionary RAUM and roughly 2,506 accounts, while private-fund reporting places aggregate adviser private-fund gross assets around $74.7 million across multiple vehicles. Adams Wealth's own brochure identifies AIM Defined Investment Fund as one of its current private funds and says AIM Defined Investment Fund GP LLC, wholly owned by Adams Wealth, serves as one of its managers. The same disclosure states that Adams Wealth is registered as a Commodity Pool Operator and operates AIM Defined Investment Fund as a commodity pool. It also explicitly identifies the conflict created when advisory clients invest in affiliated funds from which Adams Wealth or an affiliate can earn management and performance fees. Those disclosures are important because they demonstrate both a substantive regulatory framework and an economic incentive that investors should evaluate.
CACHETECH / RELATED PLATFORM / ENTITY PENETRATION
CacheTech Inc. is a separate registered investment adviser with overlapping ownership and personnel. Adams Wealth's disclosure brochure identifies Steven Craig Adams, Patrick Cormac Murphy and Riley Crosbie as CacheTech owners and notes overlap with Adams Wealth ownership and employment. CacheTech was established to provide investment advisory and technology services to other RIAs, and its current private-fund reporting also references AIM Defined Investment Fund. The legal issuer name, 701 S. Main address, telephone, Adams Wealth manager relationship, Steven Craig Adams identity, AIM Defined Investment Fund GP and private-fund ID all reconcile across Form D, Form ADV and the official Adams Wealth website. The public record does not establish a sufficiently detailed current portfolio or explain whether CacheTech has a direct portfolio-management mandate for all or part of the fund, so its role should remain described as related/overlapping rather than automatically labeled primary investment manager.
INVESTOR DILIGENCE / CORE RISKS
Investors should first obtain a written reconciliation of the April and September 2026 filings: whether the fund remains active, current NAV, current beneficial-owner count, whether interests were redeemed, transferred, exchanged or reclassified, and whether another issuer or class succeeded the reported offering. They should then review the current commodity-pool disclosure document, underlying holdings, futures and options exposure, leverage, margin requirements, liquidity, valuation methodology, management fee, performance allocation, redemption rights, gates, side pockets, administrator, custodian, prime broker or futures commission merchant and independent auditor. The principal risks include opaque fund-level strategy disclosure, derivatives and commodity exposure where used, leverage and margin risk, manager/affiliate conflicts, overlapping Adams Wealth and CacheTech relationships, liquidity, key-person dependence, private-fund valuation and the possibility of misreading a Form D reporting reset as an economic event.
SEC SNAPSHOT / PRIMARY EVIDENCE
Issuer: AIM Defined Investment Fund LLC; CIK 0001773374; SEC File No. 021-337157; private fund ID 805-5837587097; Delaware LLC; business address 701 S. Main, Suite 400, Logan, Utah 84321; pooled investment fund; Rule 506(b); Section 3(c)(1); latest Form D/A September 1, 2026; latest reported amount sold $0; latest reported investors 0; latest reported minimum $0. Immediately preceding April 10, 2026 amendment: $53,737,109 sold and 103 investors. Primary evidence reviewed includes the 2019–2026 SEC Form D series, SEC IAPD profile for Adams Wealth Advisors, Adams Wealth Form ADV and private-fund schedules, Adams Wealth regulatory brochure, CacheTech Form ADV, the official Adams Wealth website and individual regulatory records for Steven Craig Adams.
IMPORTANT FORM D NOTICE
Form D is a notice of an exempt securities offering and does not mean the SEC has approved, endorsed, audited or verified AIM Defined Investment Fund, Adams Wealth Advisors, CacheTech, Steven Craig Adams, any commodity strategy, historical valuation or expected return. The September 2026 filing reports zero amount sold and zero investors even though the April 2026 amendment reported $53.737109 million and 103 investors; the reviewed public filing does not explain the reset. Adams Wealth's approximately $565.8 million regulatory AUM is firmwide and is not AIM Defined Investment Fund NAV. Investors should rely on current fund financial statements, capital-account records, CFTC/NFA disclosures, portfolio reports and offering documents rather than interpreting the Form D reset as proof of liquidation, redemption or investment loss.