The Adviser is an investment advisory firm with its principal place of business in New York, New York. The
Adviser commenced operations in June of 2010. The Adviser is owned by Star Mountain Holdings, LP,
a Delaware limited partnership, which is owned by Star Mountain Capital, LLC, a Delaware limited
liability company, which is owned by Brett A. Hickey (the “Managing Member”).
The Adviser provides investment advisory services to its clients, both on a discretionary and non-
discretionary basis, which are currently pooled investment vehicles (the “Funds”), including a Fund that
is registered under the Investment Company Act of 1940 (“IC Act”) as a closed-end business development
company, and separately managed accounts (the “Accounts”) intended for institutional and other
sophisticated investors (collectively, the “Clients”). The Adviser provides investment advisory services to
the Clients based on each Client’s
specific investment objectives and strategies as set forth in each Client’s
investment management agreement, organizational documents, subscription agreements, Side Letters (as
defined in Item 8) or operating agreements (collectively, “Offering Documents”). Certain Clients have
investment restrictions on investing in certain securities or other assets, to the extent that such securities
are outside the applicable Client’s existing investment program. In certain situations, the Adviser is able
to tailor its advisory services and investments based on specific Client objectives and/or investment
strategies as agreed to with such Client’s investors.
As of March 22, 2024, the Adviser had approximately $3,878,021,174 in client regulatory assets under
management. As of that date, the Adviser managed approximately $3,332,724,970 on a discretionary basis
and approximately $545,296,204 on a non-discretionary basis.