A. Description of the Advisory Firm Altar Rock LLC (hereinafter “Altar Rock” or “we” and its derivatives) is a Limited Liability Company organized in the State of Delaware. The firm was formed in December 2020, and the principal owners are Archan Kumar Basu, Andrew Harding Barnes, and Warren Neil Litman.
Altar Rock was created out of a belief that wealthy clients (hereinafter “clients” or “you” and its derivatives) deserve more than you are currently getting. Our firm asserts that clients deserve precision, clarity, and control over your most pressing financial choices. In our founders’ view, this helps differentiate Altar Rock from almost every wealth manager.
While many professional investors seek “Investment Alpha” — commonly defined as excess returns over a passive benchmark, this is widely recognized to be nearly impossible to generate consistently in competitive markets and especially so on an after tax basis.
Altar Rock instead seeks “Structural Alpha” which we define as growing wealth by harnessing persistent opportunities, embedded in the tax code or the client’s own situation, that lie within a client’s grasp. Familiar examples of this are: harvesting taxable losses while letting gains run; or utilizing certain trusts to avoid gift and estate taxes. Since structural alpha is often larger and easier to achieve than investment alpha, it can serve as a more reliable form of outperformance over a passive benchmark. Often structural alpha arises from deep planning, and can be enhanced by aligning asset allocation, asset location and portfolio construction to produce distinct outcomes for each client.
Put differently, Altar Rock views Investment Alpha as a “nice to have” tailwind whereas it views Structural Alpha as the “must have” target for discerning clients.
Altar Rock builds upon a wealth allocation framework (Chhabra 2005) to help tailor structural alpha toward your specific situation. More specifically, the client’s goals are classified as Critical Needs (essential), Wealth Enhancement & Transfer (important) or Aspirational Growth (ideal).
The client’s wealth is allocated toward these three goals in priority order, and a portfolio approach is developed for each. The allocation is dynamic as goals may, for instance, arrive within reach as markets perform better than expected — or conversely may grow more distant when markets underperform.
These client goals and the corresponding allocation interact with Altar Rock’s market outlook in our proprietary Global Path Simulator (GPS). GPS aims to incorporate everything that the Altar Rock team knows about the client’s situation, as well as about current global macro-economic and market conditions. By stress-testing your goals and pre-experiencing the tradeoffs among them, together we seek to unlock your full financial potential.
B. Types of Advisory Services Portfolio Management Services Altar Rock offers ongoing portfolio management services that seek to secure each client’s goals: ●Wealth Strategy: we scope out your situation, purpose, goals and values; then we help you to sort through key trade-offs to arrive at sound, durable choices.
●Market Outlook: we scan all major asset classes, sub-classes and sectors to quantify secular, cyclical and tactical views.
●Asset Allocation and Location: we divide the client’s holdings across a variety of buckets, accounts, jurisdictions, beneficiaries, and asset classes.
●Investment vehicle selection: we implement cheaply or curate the best (in our view) external managers; we subject each candidate to a thorough risk x-ray.
●Risk-aware Portfolio Construction: we determine precise holdings for clients, then trade as needed. We also handle cash flows, tax harvests and other requests.
●Performance Reporting: we review your accounts’ investment performance against market benchmarks and goals.
Altar Rock’s investment process culminates in deliberation by our Investment Committee, whose members have over a century of combined market experience. The Committee applies best practices of decision-making and carefully applies risk, liquidity, tax and fee budgets.
Underlying Altar Rock’s investment processes is a philosophy that life circumstances evolve, as do economic and market opportunities; so the best-informed decisions require constant effort and a framework that anticipates change. More specifically, Altar Rock believes that: ● Alignment is essential. Investing isn’t just about the markets but also about supporting clients’ purpose, goals and values.
● Initial conditions matter, as does horizon. It pays to wait for a fat pitch. Also, the longer clients’ time horizon, the less risky are stocks.
● Investors should remain skeptical. Markets are fairly efficient in the short-term. Reliably beating public indexes requires rare skill or structural advantage.
● Investors should cast a wide net and constantly reassess. There is no asset, structure, location or strategy that we won’t at least consider owning.
Altar Rock requests discretionary authority from clients in order to select securities and execute transactions without the delay or disruption required to consult on every transaction. Goals, horizon, benchmarks, and risk capacity are documented in the Investment Policy Statement that we develop with and for you.
Altar Rock seeks to form investment decisions in accordance with the fiduciary duty we owe to every client and without consideration of our own economic or other interests. To meet our fiduciary obligation, we attempt to avoid, among other things, investment or trading practices that systematically advantage certain clients over others. Rather, our policy is to allocate investment opportunities and transactions among our clients on a fair and equitable basis over time.
Financial Planning We believe that financial planning (or “wealth strategy”) must properly assess current market conditions — the starting point of analysis — and moreover must examine relationships over years and across asset classes to project a range of paths that your investments may take.
Such longer-term projections should be the building blocks of any true financial plan.
We recognize that developing

trustworthy asset class projections can be difficult. Financial firms offer up assumptions resembling long-term historical averages that at times appear overly rosy toward risk assets like equities.
In our view, a thorough approach should incorporate starting yields, valuation ratios, and the state of the business cycle, as well as causal or statistical linkages among these. It’s important to proceed with rigor, discipline, and humility. GPS constructs 10,000 plausible future paths of asset class returns, but unlike a basic Monte Carlo simulation, here each path is a plausible sequence of market outcomes starting in the present — with realistic levels of momentum, reversal, and knock-on effects. Volatility and correlations for each horizon are then computed off these paths rather than being hard coded.
To plan a journey, in the familiar analogy of a global positioning system (GPS), you first need a digital roadmap. The starting point clearly matters. Short-term predictive accuracy isn’t critical—we don’t obsess over nailing the market forecast during the next month or quarter.
Rather, we focus upon the likely range of market and cash-flow projections over years and decades. Our aim is to project the general tendency of wealth outcomes at key percentiles such as the median. All of this enables impactful strategic advice (“head northwest”), cyclical guidance (“take this shortcut to avoid rush hour traffic”), richer client dialogue (“are we getting close?”) and, in certain key moments, high-conviction risk bulletins (“this time is dangerously different”).
Layered on top of GPS’ wide range of market projections — which to be emphatic are neither “assumptions” nor “forecasts” — are the client’s situation as well as the choices you face. The client’s situation comprises your balance sheet, income & cash flows, dependents, human capital, risk capacity and personal tax rates. The choices we together face include asset allocation and location — including complex trust and estate planning instruments. Putting all of this together, we obtain visualizations of ranges of outcome under different choice scenarios, illustrating key tradeoffs that must be resolved. By pre-experiencing those tradeoffs, and in particular the downside outcomes that accompany each potential choice, clients may form durable decisions. Those decisions are then captured in the client’s investment policy.
Selection of Investment Vehicles, Including Third-Party Advisers There is almost no investment that Altar Rock won’t at least consider owning. That doesn’t mean we are indifferent to what we own. Nor should it be taken to imply that we have equal familiarity with every potential investment. What it does mean is that we strive to take an expansive view of the available investment universe. We achieve this using a variety of research tools and methods; for instance, GPS unpacks venture capital by modeling its underlying linkages to equities and the economy.
Altar Rock client portfolios may utilize passive or active management, traditional or alternative instruments, liquid or illiquid markets, in potentially every sector and asset sub-class, domestically or abroad. We commonly hold mutual funds, exchange traded funds (ETFs), separately managed accounts (SMAs) and limited partnership interests (LPs) as well as stocks and bonds. Margin is used for leverage or shorting where appropriate, or simply to generate liquidity without disturbing the client’s existing holdings.
When a third party adviser is involved — such as for a mutual fund, ETF, SMA or LP — an additional management fee is typically deducted directly by that third party from the client’s assets. Additional fees, such as incentive or carry fees, may apply as well. We are thoughtful about such fees, which are in addition to the advisory fee that we ourselves levy. Before selecting such third party advisers for clients, Altar Rock will verify that all recommended advisers are properly licensed, notice-filed, or exempt in the states where Altar Rock is recommending the adviser to clients.
Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding a retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ●Meet a professional standard of care when making investment recommendations (give prudent advice); ●Never put our financial interests ahead of yours when making recommendations (give loyal advice); ●Avoid misleading statements about conflicts of interest, fees, and investments; ●Follow policies and procedures designed to ensure that we give advice that is in your best interest; ●Charge no more than is reasonable for our services; and ●Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions Altar Rock will tailor a portfolio for each individual client. This will include interview sessions to get to know your specific situation, purpose, goals and values. Utilizing our proprietary financial planning framework (which we call GPS), then helps us to allocate and invest accordingly.
Clients may impose restrictions to prevent our investing in certain securities or types of securities on your behalf. If such restrictions prevent us from properly servicing your account, or if such restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship.
D. Wrap Fee Programs A wrap fee program is an investment program where the client pays one stated fee that includes management fees and transaction costs. Altar Rock does not participate in wrap fee programs.
E. Assets Under Management Altar Rock has the following assets under management: Discretionary Amounts:Non-discretionary Amounts: Date Calculated: $ 3,094,589$0 December 2023