The Firm
The Firm is an investment adviser organized as a Delaware limited liability company and formed
on February 5, 2009. The owners of the Firm are David J. Millstone1 and David S. Winter (the
“Principals”). The Firm’s principal office is at 9 West 57th Street, 47th Floor, New York, New
York 10019.
Services
The Firm is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an
investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).
The Firm provides discretionary investment advisory services to pooled investment vehicles that
are exempt from registration under the Investment Company Act of 1940, as amended (the “1940
Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the
“Securities Act”). As of the date hereof, the Firm serves as investment manager of Standard
Legacy Fund LP, a Delaware limited partnership (“Standard Legacy Fund”), 237 Beige LLC, a
Delaware limited liability company (“237 Beige”), Standard CS Holdings LLC, a Delaware
limited liability company (“Standard CS”), Standard QOZ Fund LP, a Delaware limited
partnership (“Standard QOZ”), Standard Ventures Fund LP, a Delaware limited partnership
(“Standard Ventures”), Standard Latitude Fund LP, a Delaware limited partnership (“Standard
Latitude Feeder”), and Standard Latitude Master Fund Ltd., a Cayman Islands exempted company
incorporated with limited liability (“Standard Latitude Master”, and together with Standard
Latitude Feeder, collectively, “Standard Latitude”).
The Firm provides non-discretionary investment advice (i.e., conducts research, executes
securities trades, conducts post-trade order activities on a non-discretionary basis) for Ronsam
Management LLC (“Ronsam”), Alettar LLC (“Alettar”), and five separately managed accounts
and other clients (the “SMAs”) including an SMA that is a charitable organization (the “Charitable
SMA”). Ronsam, Alettar, and the SMAs are collectively referred to in this brochure as “Non-
Discretionary Clients”). The Firm also provides occasional investment recommendations to one
client (the “Advisory Client Relationship”). The beneficial owners, beneficiaries and control
persons of each of Ronsam, Alettar, the SMAs, and the Advisory Client Relationship are all related
to one of the Principals.
As the Manager of Winter Properties LLC (“WP LLC”), the Firm provides certain management
services to WP LLC for no direct remuneration. WP LLC predominantly holds real property
interests and is not a “private fund” or “securities portfolio” for purposes of Form ADV.
Standard Legacy Fund, Standard Latitude Feeder, Standard Latitude Master, 237 Beige, Standard
CS, Standard Ventures, and Standard QOZ each are referred to herein as a “Discretionary Fund”
and collectively as the “Discretionary Funds”, and together with the Non-Discretionary Clients,
1 Mr. Millstone’s 50% interest in the Firm is held through DJM Management Holdco LLC, which he wholly owns.
the Advisory Client Relationship and WP LLC, collectively as the “Clients”, unless the context
dictates otherwise. As the investment adviser of the Discretionary Funds, the Firm identifies
opportunities for acquisition, management, monitoring, and disposition of investments of the
Discretionary Funds. Investment advice is provided directly to the Discretionary Funds and not to
their underlying investors. Investment advice is not subject to the discretion and control of the
underlying investors of the Discretionary Funds. Investment advice is subject to the discretion and
control of the respective general partners or managing members (referred to herein for simplicity
as the “General Partners”) of the Discretionary Funds. Each General Partner is wholly controlled
by the Principals and directly or indirectly owned by the Principals individually or by trusts for the
benefit of their families. The Firm does not participate in wrap fee programs.
The Clients
Standard Legacy Fund is an opportunistic investment fund with the flexibility to establish
concentrated and less-liquid positions. Standard Legacy Fund may invest across a variety of asset
classes, including, but not limited to, U.S. and foreign equity and credit securities.
237 Beige is an opportunistic investment vehicle that typically invests in specialized, less liquid
positions. 237 Beige may invest across a variety of asset classes, including, but not limited to,
U.S. and foreign equity, credit securities and pooled investment funds. Standard Legacy Fund and
Standard Latitude Master are members of 237 Beige, each holding different classes of interests.
237 Beige has a limited number of co-investors in addition to Standard Legacy Fund and Standard
Latitude Master.
Standard CS is an opportunistic investment vehicle that typically invests in specialized, less liquid
positions. Standard CS may invest across a variety of asset classes, including, but not limited to,
U.S. and foreign equity securities. Standard Latitude Master is a member of Standard
CS.
Standard CS has a limited number of co-investors in addition to Standard Latitude Master.
Standard Latitude Master is a long-biased investment fund that typically takes long-term,
concentrated, strategic positions in public equities. Standard Latitude Master is managed on a tax
aware basis and seeks to optimize for long-term capital gains. Standard Latitude Master invests
across a variety of instruments, including, but not limited to, U.S. and foreign equity and credit
securities, currencies, rates, and derivatives. Standard Latitude Master consists of (a) a “main
book,” which includes, among other things, certain cash holdings and liquid public equity
investments, and (b) specialized investments through special purpose co-investment vehicles,
which contain allocations to less liquid assets and certain pooled investment funds including the
following (the “SPVs”):
• Standard Advisers Fund LP (“Standard Advisers”) is an SPV fund-of-funds portfolio that
invests across an array of underlying alternative investment strategies with both new and
established managers; and
• Standard QOZ is an SPV that invests substantially all investable capital, directly or through
subsidiaries, in “qualified opportunity zone property”. Standard QOZ has co-investors in
addition to its beneficial ownership by Standard Latitude Master.
• Standard Ventures is an SPV that provides investors with the opportunity to realize long-
term capital appreciation from venture capital investments.
The Firm treats the assets of each of the SPVs as assets of Standard Latitude Master. The Class
A Interests of Standard Latitude Feeder reflect the net performance of the “main book”. The SPVs
are elective investments the performance of which is reflected on a standalone basis in other classes
of interests of Standard Latitude Feeder.
Standard Latitude Feeder invests substantially all of its capital and conducts its investment
program and trading activities through Standard Latitude Master. Standard Latitude Feeder also
is the sole limited partner of Standard Legacy Fund. As such, Standard Legacy Fund is also a
master fund for Standard Latitude Feeder. The performance of Standard Legacy Fund is reflected
on a standalone basis in a separately-designated class of interest in Standard Latitude Feeder.
Ronsam, Alettar, the Charitable SMA, and Standard Advisers (collectively, the “Multi-Manager
Portfolios”) primarily invest in hedge funds, separately managed accounts, mutual funds, and
private equity funds managed by third-party advisers (for convenience, collectively referred to as
“Underlying Funds”). The SMAs generally make securities investments either directly or through
Underlying Funds. Two SMAs, Dalbergia Investments LLC (“Dalbergia”) and Standard
Industries Technologies LLC (“Standard Tech”), make investments that are strategic to an
Associated Organization (as defined in Item 10 below) and its affiliated operating businesses. The
Advisory Client Relationship primarily invests in index funds and publicly traded securities.
WP LLC is a privately held, vertically integrated real estate investment business engaged in the
acquisition, sale, financing, development, management, ownership and operation of real estate
assets.
The Firm may in the future organize other investment funds, including feeder funds for the
Discretionary Funds or parallel funds for the Principals or employees of the Firm, or manage
investment funds or separately managed accounts that may either co-invest with the Discretionary
Funds or follow an investment program similar to or different from the Discretionary Funds’
programs. The Firm may in the future establish additional special purpose vehicles or subsidiaries,
and the Firm or the Discretionary Funds may in the future invest in or act through such additional
special purpose vehicles or subsidiaries.
Services are provided to the Discretionary Funds, and directly or indirectly to the SPVs, in
accordance with the Firm’s advisory agreements (each, an “Advisory Agreement” and collectively,
the “Advisory Agreements”) and/or the governing documents of the applicable Discretionary Fund
(e.g., limited partnership agreements or limited liability company agreements) (each, a “Governing
Document”, and collectively the “Governing Documents”). Investment restrictions, if any, for the
Discretionary Funds are generally established in the Governing Documents. All purchases, sales,
or trading activities of the Discretionary Funds are undertaken by the Firm pursuant to a grant of
discretionary authority. The General Partners may, from time to time and in their sole discretion,
modify or waive certain terms applicable to one or more Discretionary Fund investors under the
Governing Documents including, but not limited to, fee terms, withdrawal terms, and notice
requirements.
Assets Under Management
As of December 31, 2023, the Firm manages a total of approximately $4,856,581,304 of assets on
a discretionary basis and a total of approximately $261,933,532 of assets on a non-discretionary
basis.