Overview
A. Northern Lakes is a Delaware limited partnership that was formed in July 2021. The Firm’s
general partner is Northern Lakes Capital, LLC, and the Firm is owned directly and indirectly
by certain members of the Firm’s management team.
B. The Firm provides investment advisory services to pooled investment vehicles (each a “Fund”
and collectively, the “Funds”). The Funds generally seek to rely on an exemption from
registration under the Investment Company Act of 1940, as amended (the “Investment
Company Act”), and whose securities are not registered under the Securities Act of 1933, as
amended (the “Securities Act”). Northern Lakes provides discretionary investment
management services to the Funds in accordance with the applicable limited partnership
agreement (or analogous organizational document), management agreement, subscription
agreement and side letters of each Fund (each, an “Advisory Agreement”). The Advisory
Agreements of a Fund, along with any private placement memoranda and related materials are
referred to herein collectively as the “Offering Documents” of such Fund.
The Firm’s primary investment objective for each Fund is set forth in such Fund’s Offering
Documents. In accordance with a Fund’s individual investment objectives, investments are
generally made in privately held companies located in the United States and elsewhere (each
such company is referred to herein as a “Portfolio Company,” and collectively, the “Portfolio
Companies”).
Northern Lakes is affiliated with other entities that serve as general partner (each a “General
Partner” and collectively the “General Partners”) to each Fund. The advisory services of
Northern Lakes and of the General Partners
are described in this Brochure and in the Advisory
Agreements applicable to a Fund, but generally consist of: investigating, identifying, and
evaluating investment opportunities; structuring, negotiating, and making investments on
behalf of the Funds; managing and monitoring the performance of such investments; and
disposing of such investments. The information set forth herein regarding the investment
advisory services provided by Northern Lakes shall also apply in respect of the General Partners
unless specifically noted.
C. Northern Lakes provides investment advice directly to each Fund, subject to the discretion and
control of the applicable General Partner, and not individually to the investors in the Funds.
Such investors accept the terms of advisory services as set forth in a Fund’s Advisory
Agreements. The Firm expects to have broad investment authority with respect to the Funds
and, as such, investors should consider whether the investment objectives of the Funds are in
line with their individual objectives and risk tolerance prior to investing.
D. As of December 31, 2022, Northern Lakes manages approximately $207 million in regulatory
assets on a discretionary basis. The Firm does not manage any assets on a non-discretionary
basis.
E. Certain of the owners and employees of the Adviser are owners and employees of Stone Arch
Capital, LLC (inclusive of its advisory affiliates “Stone Arch”). Stone Arch is a separately
registered investment adviser that provides investment advisory services to pooled investment
vehicles privately offered to qualified investors in the United States and elsewhere. More
information regarding Stone Arch can be found on its Form ADV Part 2A.