9AT: AVENIR CORPORATION

Adviser Profile

As of Date	03/31/2026
Registration	SEC, Approved, 07/22/1988
Other registrations (1)	District of Columbia, Terminated, 04/10/2002
ADV Location	ALEXANDRIA, VA, United States
Contact Info	(20 xxxxxxx
Websites

AUM^*	849,280,840 -15%
of that, discretionary	849,280,840 -15%
Number of Employees	6
of those in investment advisory functions	3
Private Fund GAV^*	0
Avg Account Size	1,904,217 -8%
% High Net Worth	57.96% -3%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pooled investment vehicles
- Pension and profit sharing plans
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management

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 NIXON CAPITAL LLC	Hedge Fund20.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV20.3m	AUM389.9m	#Funds1
Adviser RUTHERFORD INVESTMENT MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM250.0m	#Funds-
Adviser STANLEY-LAMAN GROUP LTD.	Hedge Fund125.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV125.3m	AUM1.0b	#Funds1
Adviser PENBROOK MANAGEMENT LLC	Hedge Fund9.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV9.3m	AUM175.4m	#Funds1
Adviser GW&K INVESTMENT MANAGEMENT, LLC	Hedge Fund171.0m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV171.0m	AUM52.8b	#Funds3
Adviser TSAI CAPITAL CORPORATION	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM148.3m	#Funds1
Adviser UNIO CAPITAL LLC	Hedge Fund143.7m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV143.7m	AUM691.5m	#Funds2
Adviser PROSPECT HILL MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM256.6m	#Funds-
Adviser 16TH AMENDMENT ADVISORS LLC	Hedge Fund71.5m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV71.5m	AUM390.2m	#Funds4
Adviser HGI CAPITAL MANAGEMENT, LLC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM41.6m	#Funds-

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker570535104	Stock NameMARKEL GROUP INC	$ Position$86,350,091	% Position11.00%	$ Change-2.00%	# Change-4.00%
Stck Ticker594918104	Stock NameMICROSOFT CORP	$ Position$89,376,519	% Position11.00%	$ Change-1.00%	# Change-2.00%
Stck Ticker023135106	Stock NameAMAZON COM INC	$ Position$85,938,730	% Position10.00%	$ Change10.00%	# Change-4.00%
Stck Ticker03027X100	Stock NameAMERICAN TOWER CORP NEW	$ Position$66,591,893	% Position8.00%	$ Change-7.00%	# Change-2.00%
Stck Ticker037833100	Stock NameAPPLE INC	$ Position$62,258,065	% Position8.00%	$ Change7.00%	# Change-6.00%
Stck Ticker67103H107	Stock NameOREILLY AUTOMOTIVE INC	$ Position$67,331,880	% Position8.00%	$ Change-3.00%	# Change-2.00%
Stck Ticker084670702	Stock NameBERKSHIRE HATHAWAY INC DEL	$ Position$53,599,375	% Position7.00%	$ Change3.00%	# Change-2.00%
Stck Ticker217204106	Stock NameCOPART INC	$ Position$30,476,857	% Position4.00%	$ Change-17.00%	# Change-3.00%
Stck Ticker57636Q104	Stock NameMASTERCARD INCORPORATED	$ Position$32,752,232	% Position4.00%	$ Change1.00%	# Change-2.00%
Stck Ticker00724F101	Stock NameADOBE INC	$ Position$27,796,817	% Position3.00%	$ Change-10.00%	# Change7.00%

Brochure Summary

Overview

Avenir Corporation is an investment management firm registered with the Securities and Exchange Commission. The company was incorporated in July 1980, and functioned primarily as a family office prior to registering with the SEC on July 22, 1988, at which point the firm began accepting new accounts. Avenir is majority owned by its Chairman, Charles G. Mackall, Jr. (through the CGM 2006 Trust, as amended) and its active portfolio manager, James H. Rooney. Another shareholder identified in Schedule A of Part 1 ADV holds a controlling minority interest in the firm. Avenir provides investment management services on a discretionary basis. These services include the selection of securities for purchase or sale, placement of orders for securities transactions, and related services. Avenir’s services do not include processing claims relating to class action lawsuits or bankruptcies. Avenir provides advisory services for a diverse client base, ranging from taxable individual and family accounts, trusts and partnerships to non-taxable pension accounts and foundations. Avenir’s investment style is a highly disciplined core value strategy focused on capital preservation and real rates

of return, taking into consideration inflation and taxes. Avenir’s portfolios are relatively concentrated, reflecting Avenir’s belief that portfolios comprised of a limited number of superior investment opportunities combined with a high margin of safety can achieve better overall results than broadly diversified portfolios. Avenir understands that each client has special requirements and goals, and therefore clients may impose restrictions on investing in certain securities or types of securities. Avenir provides investment management services to certain clients who participate in wrap fee programs. Wrap fee programs are typically characterized by a bundled fee arrangement that covers both the investment manager’s services (i.e. those provided by Avenir) and any advisory fees paid to the wrap sponsor, as well as all brokerage commissions, custodial costs and related administrative costs. The total fees charged by these programs are set by the sponsoring broker, not by Avenir. From Avenir’s perspective, clients with wrap fee arrangements receive the same level of investment advisory services as non-wrap fee clients. Avenir managed approximately $1,267,094,000 of discretionary assets as of March 28, 2024.

AVENIR CORPORATION

AVENIR CORPORATION

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Top Holdings

Brochure Summary

Overview

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AVENIR CORPORATION AVENIR CORPORATION

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Top Holdings

Brochure Summary

Overview

AVENIR CORPORATION

AVENIR CORPORATION