The Firm offers advisory services to private investment funds and investment companies
registered under the Investment Company Act of 1940 (the “1940 Act”). Prior to the Firm rendering
any of the foregoing advisory services, clients are required to enter into one or more written
agreements with the Firm setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
The Firm registered as an investment adviser in June 2020 and is owned by HighTower Holding,
LLC (“Hightower”). Hightower is the owner of other registered investment advisory firms, broker
dealers, wealth managers and trust companies that provide wealth management services to high
net worth individuals and institutional investors. While the Firm is operationally independent from
Hightower, the Firm may share certain resources and back-office support with Hightower.
As of December 31, 2023, the Firm had approximately $1,292,637,646 billion of assets under
advisement of which $1,292,637,646 billion was managed on a discretionary basis.
While this Brochure generally describes the business of the Firm, certain sections also discuss
the activities of its employees (or “Access Persons”), which include, among others, the Firm’s
officers, partners, directors (or other persons occupying a similar status or performing similar
functions). Access Persons also include employees or any other person who provides investment
advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
Types of Advisory Services Offered
The Firm provides discretionary investment management services to a limited group of private
investment funds and investment companies registered under the 1940 Act. The Firm does not
provide investment advisory
services to individuals or entities aside from registered and private
funds.
The Firm serves as sub-adviser to certain Exchange Traded Funds (“ETFs”) managed by
Exchange Traded Concepts (“ETC”), which are series of the Exchange Traded Concept Trust,
and as sub-adviser to an ETF managed by ETFArchitect. All the ETFs sub-advised by the Firm
are registered investment companies under the 1940 Act.
The Firm also serves as an adviser or sub-adviser to unregistered pooled investment vehicles
that are exempt from registration under the 1940 Act (the “Private Funds”). Currently, these
include various series of BlueArc Credit Alternatives Fund, LLC, BlueArc Diversified Hedge Fund
Strategies, LLC and BlueArc Real Estate Investments, LLC (the “BlueArc Funds”).
These relationships are described at length in Item 10. MAS may provide discretionary investment
advisory services to other private funds in the future.
The Firm tailors its advisory services to meet the needs of its clients and seeks to ensure, on a
continuous basis, that portfolios are managed in a manner consistent with the client’s investment
objectives, strategy, and guidelines, as described in the relevant private placement memorandum
(“PPM”) delivered to investors in the Private Funds, and the relevant prospectus and statement
of additional information publicly filed with the SEC for the registered funds (“Registration
Statements”).
Clients may impose reasonable restrictions or mandates on the management of their accounts if
consistent with the relevant PPMs and Registration Statements and if the Firm determines, in its
sole discretion, the conditions would not materially impact the performance of a management
strategy or prove overly burdensome to the Firm’s management efforts.