principal owner(s).
H. Barton Asset Management, LLC (“HBAM”) was formed in 2010 and is primarily owned by Harris Barton
(the “Principal”).
HBAM provides discretionary investment advisory services to a number of privately offered pooled
investment funds, including the Funds of Funds and the Direct Funds (each defined below) (collectively
the “Funds”). HBAM advises a number of funds of funds (the “Fund of Funds”) that invest in a select list
of U.S. venture capital funds (“Portfolio Funds”) managed by third-party investment advisers (“Portfolio
Managers”).
Additionally, HBAM has established certain Funds to invest directly in private companies typically
alongside third-party venture capital fund managers (“Direct Funds”).
Advisory Structure
The activities of each Fund are governed by an operating agreement, or similar document (each an
“Operating Agreement”), that specifies the investment guidelines and investment restrictions applicable
to each Fund.
HBAM serves as the managing member of each of the Funds (the “Managing Member”), although it may
in the future organize separate entities to serve as managing members of future formed funds. As the
Managing Member, HBAM provides investment management and advisory services and retains
management authority over the business and affairs of the Funds.
particular type of advisory service, such as financial planning, quantitative analysis, or market timing,
explain the nature of that service in greater detail. If you provide investment advice only with respect
to limited types of investments, explain the type of investment advice you offer, and disclose that your
advice is limited to those types of investments.
HBAM offers investment advice solely with respect to the investments made by the Funds. Such services
consist of investigating, identifying, and evaluating investment opportunities and making investments
on behalf of the Funds, monitoring the performance of such investments, and disposing of such
investments. As noted above, HBAM advises Funds of Funds that invest in select venture capital Portfolio
Funds and Direct Funds that invest in portfolio companies generally, but not always, alongside select
third-party venture capital fund managers.
clients. Explain whether clients may impose restrictions on investing in certain securities or types of
securities.
HBAM generally has broad and flexible investment authority with respect to the Direct Funds. With
respect to the Funds of Funds, HBAM may cause them to invest in the venture capital funds managed by
Portfolio Managers on a pre-disclosed list. Each Fund’s investment objective and strategy is set forth in
the respective Fund’s Operating Agreement or confidential private placement agreement (“PPM”).
HBAM tailors its investment advice to each Fund in accordance with the Fund’s investment objectives
and strategy as set forth in such documents. Certain investment limitations are included in the Operating
Agreements. All investors in the Funds (“Investors”) are provided with an Operating Agreement and a
PPM prior to making an investment. Investors are urged to carefully review those documents prior to
making an investment.
HBAM has and may in the future enter into side letter agreements with certain Investors. Side letters
are negotiated prior to investment and may establish rights that supplement, or alter the terms of, the
applicable Operating Agreement. Pursuant to such side letters, certain Investors may have rights which
are not available to other Investors for example, advisory committee representation.
describe the differences, if any, between how you manage wrap fee accounts and how you manage
other accounts, and (2) explain that you receive a portion of the wrap fee for your services.
Not applicable. HBAM does not participate in wrap fee programs.
discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose
the date “as of” which you calculated the amounts.
As of December 31, 2023, HBAM manages approximately $1,280,903,006 of Fund assets on a
discretionary basis. HBAM does not have any Funds whose assets are managed on a non-discretionary
basis.