General Information Wallace Hart LLC, d/b/a Wallace Hart Capital Management was formed in 2016, and became registered as an investment adviser in January 2017. Jeremy Wallace and Andrew Hart are the principal owners of Wallace Hart. Please see the Part 2B brochures for more information on Mr. Wallace and Mr. Hart.
At the outset of each client relationship, Wallace Hart spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Wallace Hart generally develops with each client:  a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”); and  the client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments Wallace Hart will make or recommend on behalf of the client in order to meet those goals. The Financial Profile and the Investment Plan are discussed regularly with each client, but are not necessarily written documents.
Financial Planning Wallace Hart currently offers limited financial planning services to those clients in need of such service in conjunction with portfolio management services. Although Wallace Hart does not currently offer financial planning services as a stand-alone service, Wallace Hart may do so in the future. Wallace Hart’s limited financial planning services normally addresses areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess the financial circumstances of the client in order to more effectively develop the client’s Investment Plan.
Portfolio Management As described above, at the beginning of a client relationship, Wallace Hart meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Wallace Hart based on updates to the client’s financial or other circumstances.
To implement the client’s Investment Plan, Wallace Hart will manage the client’s investment portfolio on a non-discretionary or discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, Wallace Hart will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non- discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding

the foregoing, clients may impose certain written restrictions on Wallace Hart in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Wallace Hart.
Pooled Investment Vehicle Advisory Services Wallace Hart provides discretionary investment advisory services to two pooled investment vehicles: Wallace Hart Momentum Fund, LP, a Delaware limited partnership (the “Onshore Fund”) and Wallace Hart Momentum Offshore Fund, LP, a British Virgin Islands limited partnership formed for the purpose of investing solely in the Onshore Fund (the “Offshore Fund” and, together with the Onshore Fund, the “Funds”). Each of the Onshore Fund and the Offshore Fund are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and neither Fund’s securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). As the investment adviser to the Funds, Wallace Hart, along with Wallace Hart Capital Partners, LLC, the Funds’ general partner (the “General Partner”) identifies investment opportunities for, and participate in the acquisition, management, monitoring, and disposition of, investments of the Funds.
Wallace Hart provides investment advisory services to the Funds pursuant to the terms of separate investment advisory agreements (each, a “Fund Agreement”). Investment advice is provided by Wallace Hart directly to the Funds, subject to the direction and control of the General Partner, and not individually to the investors in the Funds.
Any restrictions on investments in certain types of securities are established by Wallace Hart and are set forth in each Fund’s offering documents, which are provided to prospective investors prior to investment in the applicable Fund. Once invested in the applicable Fund, investors cannot impose restrictions on the types of securities in which such Fund may invest. While the Funds generally expect to use an equities-based long/short strategy investing in equities issued by mid- and large-cap publicly traded companies, currently there are no restrictions on the types of securities or sectors in which the Funds may invest.
Additional information related to the Funds is set forth below in Item 10 –Other Financial Industry Activities and Affiliations.
Type and Value of Assets Currently Managed As of December 31, 2023, Wallace Hart managed approximately $208,437,210 on a discretionary basis and $ 26,000,000 on a non-discretionary basis.