9AT: STRATEGY CAPITAL LLC

other names

Adviser Profile

As of Date	06/04/2024
Adviser Type - Large advisory firm - An investment adviser (or subadviser) to an investment company
Number of Employees	6
of those in investment advisory functions	4
Registration	SEC, Approved, 10/12/2018
Other registrations (2)	California, ERA - Withdrawn, 09/12/2018 SEC, ERA - Withdrawn, 03/24/2014

AUM^*	920,544,000 80.72%
of that, discretionary	920,544,000 80.72%
Private Fund GAV^*	851,435,000 -2.36%
Avg Account Size	306,848,000 201.19%
SMA’s	Yes
Private Funds	2 1
Contact Info	650 xxxxxxx
Websites

Client Types

- Investment companies
- Pooled investment vehicles

Advisory Activities

- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Fund Type	Count	GAV
Fund TypeHedge Fund	Count2	GAV$851,435,000

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser MANTEIO CAPITAL LLC	Hedge Fund29.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund4.8m	Total Private Fund GAV34.1m	AUM409.5m	#Funds3
Adviser QVIDTVM MANAGEMENT LLC	Hedge Fund378.6m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund58.7m	Total Private Fund GAV437.2m	AUM437.3m	#Funds3
Adviser ZENTIFIC INVESTMENT MANAGEMENT LIMITED	Hedge Fund201.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV201.9m	AUM1.0b	#Funds2
Adviser RICHMOND HILL INVESTMENTS, LLC	Hedge Fund556.8m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund88.9m	Total Private Fund GAV645.7m	AUM645.7m	#Funds3
Adviser ALTA FOX CAPITAL MANAGEMENT, LLC	Hedge Fund425.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund12.0m	Total Private Fund GAV437.9m	AUM437.9m	#Funds2
Adviser WATERWHEEL CAPITAL MANAGEMENT	Hedge Fund55.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund36.0m	Total Private Fund GAV91.9m	AUM194.7m	#Funds2
Adviser WHETSTONE CAPITAL ADVISORS	Hedge Fund294.8m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund2.0m	Total Private Fund GAV296.8m	AUM296.8m	#Funds3
Adviser MALABAR INVESTMENTS, LLC	Hedge Fund1.8b	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund12.0m	Total Private Fund GAV1.9b	AUM1.1b	#Funds6
Adviser AZTLAN EQUITY MANAGEMENT, LLC	Hedge Fund6.0m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund11.9m	Total Private Fund GAV17.9m	AUM290.0m	#Funds3
Adviser FCCI CONSULTING, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM170.8m	#Funds-

Brochure Summary

Overview

A. Description of Advisory Firm Strategy Capital LLC (the “Manager” or “Strategy Capital”) is a Delaware limited liability company founded in 2002 and is now registered with the SEC. Strategy Capital is owned by Hamilton Helmer, Managing Member, and John Rutherford, Special Member, Chief Compliance Officer, and Chief Operating Officer. Strategy Capital GP LLC (“General Partner”), a Delaware limited liability company founded in 2014, is affiliated with Manager and is owned by Hamilton Helmer, Managing Member and John Rutherford, Special Member, Chief Compliance Officer, and Chief Operating Officer. B. Description of Advisory Services Strategy Capital currently provides investment advice and management services through the following types of products (each a “Client” and collectively, the “Clients”): (i) two privately placed investment funds structured as limited partnerships for which Strategy Capital is the investment manager, one established in 2013 (the “2013 Partnership”) and one established in 2019 (the “2019 Partnership”)(each a “Partnership” and collectively, the “Partnerships”); (ii) an investment company registered under the Investment Company Act of 1940 sponsored by advisers unaffiliated with Strategy Capital for which the Manager acts as sub-adviser (the “Sub Advised Account”); (iii) a separate account (the “Endowment SMA”); and (iv) a special purpose vehicle entity formed as a limited liability company

(“SPV”) for which Strategy Capital is the managing member. As a practical matter, the SPV was created to facilitate an investment in a private company on behalf of a limited number of Investors. Investment advisory services are provided to each Client pursuant to separate investment management or sub advisory agreement between each Client and Strategy Capital (for each client the “Constituent Documents”). Strategy Capital’s investment objective is to achieve long-term capital appreciation through investments in individual publicly traded equity securities. Current income is not an objective. Strategy Capital’s strategies and the risks involved are described in response to Item 8, below. Each Partnership conducts a private offering of its partnership interests (“Interests”) to certain qualified investors as described in response to Item 7, below (referred to herein as “Investors”). C. Client Tailored Services and Client Imposed Restrictions Advisory services are tailored to achieve the Clients’ investment objectives. Generally, Strategy Capital has the authority to select which and how many securities and other instruments to buy or sell without consultation with the Clients or their Investors. D. Wrap Fee Programs Strategy Capital does not participate in or offer wrap fee programs. E. Assets Under Management As of December 31, 2022, Strategy Capital had regulatory assets under management on a discretionary basis of $509,387,000.

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STRATEGY CAPITAL LLC

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