Firm Description
AltraVue Capital, LLC, (“AltraVue”, the “Firm,” “us,” “we,” or “our”), is an SEC-registered investment firm and
was formed as a Delaware limited liability company in January of 2016.In this document we refer to current
and prospective investors and clients of AltraVue as “you,” “client,” or “your.”
AltraVue is a minority and women owned investment management services firm, jointly founded by Touk
Sinantha and DeShay McCluskey. Ms. Sinantha and Ms. McCluskey are jointly the managing members of
AltraVue and together are responsible for the overall investment strategy and management of the Fund and
separate accounts.
Types of Advisory Services
Pooled Investment Vehicles
AltraVue provides investment management services on a discretionary basis to privately offered pooled
investment vehicles exempt from registration under the Investment Company Act of 1940, as amended.
AltraVue currently serves as the investment manager to AltraVue Fund I, LP, a Delaware limited partnership
(the “Fund,”). AltraVue also serves as the investment manager to AltraVue Fund I-P, LP, a private pooled
vehicle formed at the request of a single institutional investor and not available to other investors
(“Institutional Pooled Vehicle”). Because the Fund is currently open to new investors, we discuss the Fund’s
terms in some detail, though investors must understand that those terms are ultimately governed by the
Fund’s offering documents. We discuss the terms of the Institutional Pooled Vehicle primarily to highlight
the conflicts of interest we’ve identified (see especially Item 6.Side-by-Side Management, below). AltraVue
Capital GP I, LLC, a Delaware limited liability company, is the General Partner to the Fund and the
Institutional Pooled Vehicle.
Investment advice is provided directly to the Fund. AltraVue may, in the future, organize additional
investment vehicles that follow an investment program similar to or different from the investment program of
the Funds.
Advisory services are tailored to achieve the Fund’s investment objectives. However, AltraVue has the
authority to select which and how many securities and other instruments to buy or sell without
consultation with the Fund or the investors in the Fund. Neither the Fund nor the investors in the Fund
may impose restrictions on investing in certain types of securities. A more detailed description of the
investment strategy and related risks of the Fund are included in Item 8 below and in the Fund’s offering
documents.
The Funds offers interest through a limited partnership (“LP”). The detailed terms applicable to investors
in the Fund are described in the organizational documents and the offering memorandum of the Fund.
The Fund is governed by a limited partnership agreement that sets forth the specific investment
guidelines and restrictions applicable to the Fund.
Separately Managed Accounts
AltraVue also provides ongoing discretionary investment management services to advisory clients
through separately managed accounts. You must appoint AltraVue as your investment advis or of
record on specified accounts (collectively, the “Account”). The Account consists only of separate
account(s) held by a qualified custodian under your name. The qualified custodians maintain physical
custody of all funds and securities of the Account and you retain all rights of ownership (e.g., right to
withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of
the Account.
We manage the Account on a discretionary basis based on your financial situation, investment
objectives and risk tolerance. We actively monitor your account(s) and provide advice regarding
buying, selling, reinvesting or holding securities, cash or other investments of the Account. Our advice
is based on receiving information from you related to your financial situation, risk tolerance, liquidity
needs, and other investment objectives. You also have the ability to impose reasonable restrictions on
the management of your accounts, including the ability to instruct us not to purchase certain securities.
AltraVue manages investments for other clients, including a private fund, and we may give them advice
or take actions for them or for our personal accounts that are different from the advice we provide to
you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or
other investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts and Funds
we
manage. We strive to allocate investment opportunities believed to be appropriate for your accounts
and other accounts advised by AltraVue equitably and consistent with the best interest of all accounts
(and Funds) involved. However, there can be no assurance that a particular investment opportunity that
comes to our attention will be allocated in any particular manner. Please see Item 6 – Side by Side
Management, Item 11 – Code of Ethics, and Item 12 – Brokerage Practices for additional information
about allocating investment opportunities and conflicts related to allocation of investments.
Fund Recommendations to Clients: Investment Restrictions
AltraVue Fund I, LP
AltraVue may allow the purchase of LP interests in the Fund by persons who meet qualification
requirements for an offering following an evaluation of the prospective client’s particular financial
circumstances, investment goals, liquidity needs and time horizons. In the event a Fund investor seeks
to acquire additional LP interests, AltraVue will inquire about changes in the client’s circumstances or
goals.
An investment in the Fund is illiquid and subject to strict limitations on withdrawals. An investor in the
Fund will be subject to an initial lock up period of 24 months (the “Lock-Up Period”) from the date of
initial investment. Any subsequent investments by Limited Partners are subject to the initial Lock-Up
period.
A Limited Partner (“LP”) may make a withdrawal of their LP interest by giving AltraVue, through the
General Partner, notice at least 60 days prior to the last business day of any calendar quarter on or
after the 24 month anniversary of the Limited Partner’s capital contribution to the Fund. Each
investment made by a Limited Partner will be subject to its own Lock -up Period, with the effect that
multiple investments made by a Limited Partner at different times will be subject to separate Lock -up
Periods. Withdrawals of amounts invested by Limited Partners will be affected by the Fund on a “first
in, first out” basis. The General Partner, in its discretion, may waive, reduce or modify any terms related
to withdrawals for a Limited Partner.
For LPs withdrawing 90% or less of the balance of their capital account, payment will be made within 30
days of the effective date of the withdrawal. For LPs withdrawing more than 90% of the amount of the
balance of their capital account, payment of 90% will be made within 30 days of the effective date of
the withdrawal with the balance of the amount of the capital account within 30 days following delivery of
the audited financial statements of the Fund for the period inclusive of the withdrawal date.
At the option of the General Partner, the amount of a withdrawal may be made in whole in cash, in
whole or in-kind, or in part in cash and in part in-kind. In-kind payments may but need not be pro-rata
as to the assets of the Fund.
As indicated above, the liquidity of an investment in the Fund is limited. There is no market for the limited
partnership interests and none is expected to develop. While a Limited Partner generally will be permitted
to make withdrawals from its capital account on a quarterly basis following an initial twenty four-month
holding period for each new contribution, Limited Partners must provide 60 days advance, written notice of
any withdrawal. Transfers of limited partnership interests will be permitted only with the written consent of
the General Partner. Further, if a substantial number of Limited Partners were to withdraw from the Fund
and the Fund did not have a sufficient number of liquid securities, the Fund might have to meet such
withdrawals through distributions of thinly-traded or illiquid securities directly to Limited Partners as
discussed in more detail in the Fund’s offering documents. Accordingly, limited partnership interests should
only be acquired by investors willing and able to commit their funds for an appreciable period of time. The
General Partner may also suspend withdrawals in certain limited circumstances and may establish
reserves, requiring a Limited Partner to remain fully or partially invested in the Fund for an indefinite period
of time.
Institutional Pooled Vehicle
As indicated in above, this Institutional Pooled Vehicle was formed on behalf of a private client and is closed
to new investors.
Wrap Fee Programs
AltraVue does not participate in wrap fee programs.
Assets Under Management
As of December 31, 2023, we had a total of $1,117,253,751 in regulatory assets under management. All
assets are managed on a discretionary basis.