Advisory Business
A. General Description of Advisory Firm
Heights Point Management, LP (“Heights Point”, “we”, “us”, and similar terms) is a Delaware
limited partnership formed in November 2020. Heights Point began operations as an investment
adviser on July 1, 2021 and has been registered with the SEC since June 2021. Heights Point
serves as the discretionary investment manager to its private fund clients. Heights Point was
founded by Brian Belke, Managing Partner and Chief Investment Officer (the “Chief Investment
Officer”). Mr. Belke is the principal owner of Heights Point and has ultimate responsibility for its
management and investment decisions. Heights Point Management GP, LLC, a Delaware limited
liability company, serves as the general partner of Heights Point and is owned by Mr. Belke.
Heights Point maintains its principal place of business in New York City.
Heights Point’s registration on Form ADV also covers Heights Point Partners GP, LLC (the “Fund
General Partner”), a Delaware limited liability company. The Fund General Partner is an affiliate
of Heights Point and serves as the general partner of clients that are organized as U.S. and Cayman
Islands exempt limited partnerships. Heights Point and the Fund General Partner share facilities
and personnel. Brian Belke is the Managing Member, and principal owner, of the Fund General
Partner.
B. Description of Advisory Services
This Brochure generally includes information about us and our relationships with our clients.
While much of this Brochure applies to all such clients, certain information included herein applies
to specific clients only.
Heights Point provides investment advisory services on a discretionary basis to the following
private fund clients (the “Funds”):
• Heights Point Partners Onshore, LP, a Delaware limited partnership (the “Domestic
Fund”); and
• Heights Point Partners Master Fund, LP, a Cayman Islands exempted limited partnership
(the “Master Fund”), which serves as the master fund into which the Domestic Fund
invests substantially all of its assets through a “master feeder” structure.
Heights Point intends to launch Heights Point Partners Offshore, LP, a Cayman Islands exempted
limited partnership (the “Offshore Fund”), which will also invest substantially all of its assets in
the Master Fund.
References throughout this document to “Clients” refer to the Funds and to any other private funds
or accounts Heights Point may advise in the future.
Entities related to or affiliated with certain strategic investors (collectively, the “Strategic
Investors”) have made a significant investment in the Funds. In connection with such investment,
the Strategic Investors benefit from certain rights that are
customary for strategic investors in a
private fund and that are in addition to, and more favorable than, the rights of other investors, as
fully described in the Funds’ offering memorandum.
Through its investment authority with respect to its management of the Funds’ assets, Heights
Point pursues a long-short equity strategy focused on performing fundamental research into small
to mid-capitalization public equities. Please see “Item 8: Methods of Analysis, Investment
Strategies, and Risk of Loss” for a description of the Height Point’s investment strategies and
certain related risks.
Notwithstanding the foregoing, subject to any limitations in the governing documents of the Funds,
Heights Point is not limited with respect to the types of investment strategies it may employ or the
markets or instruments in which it may invest.
This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities.
The securities of the Funds are offered and sold on a private placement basis under exemptions
promulgated under the Securities Act of 1933, as amended and other applicable state, federal or
non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds,
including requirements that they be “Accredited Investors” as defined in Regulation D, “Qualified
Purchasers” as defined in the Investment Company Act, as amended, or non-“U.S. Persons” as
defined in Regulation S. Persons reviewing this Brochure should not construe this as, and should
understand that this Brochure is not, an offer to sell or a solicitation of an offer to buy the securities
of any of the Funds described herein. Any such offer or solicitation will be made only by means
of a confidential private placement memorandum.
C. Tailored Advisory Services for Clients
Heights Point manages assets in accordance with the stated investment objectives of the Clients,
as described in the applicable investment management agreement or in an offering memorandum
(collectively, the “Offering Documents”). Investment advice is provided directly to the Clients
and not individually to existing investors (“Investors”) or prospective investors in the Clients.
Heights Point generally does not accept Investor-imposed investment restrictions, other than
certain limitations on its trading and investment portfolio as outlined in the Offering Documents.
D. Wrap Fee Programs
Heights Point does not participate in wrap fee programs.
E. Assets Under Management
Heights Point manages, on a discretionary basis, approximately $88,383,000 of Client regulatory
assets under management. This figure for regulatory assets under management was determined as
of December 31, 2023. Heights Point does not manage any assets on a non-discretionary basis.