ACR Alpine Capital Research, LLC is an SEC-registered investment adviser with its principal
place of business located in St. Louis, Missouri. ACR is a fundamental valuation-based asset
management firm which provides portfolio management services to institutional investors and
intermediaries. ACR began conducting business in 1999 under the name Alpine Investment
Management, LLC (“AIM”). ACR is wholly owned by ACR Alpine Capital Research, LP (“ACR
LP”), whose general partner is ACR Alpine Capital GP, LLC (“ACR GP”). AIM is the principal
shareholder (i.e., controlling 25% or more of the company) of ACR GP. Alpine Holdings Corp is the
sole owner of AIM and a trust controlled by Nicholas Tompras is Alpine Holdings Corp’s principal
shareholder (i.e., controlling 25% or more of the company). Mr. Tompras also serves as both Chief
Executive Officer and Chief Investment Officer for ACR.
Institutional Account Management
ACR offers investment advisory services in the form of discretionary portfolio management to
institutional investors (“Institutional Account Management”), either directly, through sub-advisory
arrangements or through commingled funds managed by ACR; frequently, institutional investors
are advised by an investment consultant. Each institutional investor has the opportunity to select,
typically in consultation with its investment consultant, one or more of ACR’s investment
strategies: either ACR Equity Quality Return (“EQR”) or ACR Equity Partners(“Equity Partners”),
long-only, multi-capitalization equity strategies, and/or one of the commingled funds managed by
ACR (either one or more mutual funds or limited partnerships, as described below).
Separately Managed Accounts (SMA)
SMA Advisory and SMA Sub-Advisory
ACR provides investment advisory services in the form of discretionary portfolio management to
certain clients, either directly (“SMA Advisory” clients) or through sub-advisory arrangements on
behalf of clients (“SMA Sub-Advisory” clients). Each SMA Advisory or SMA Sub-Advisory
client has the opportunity to select, typically in consultation with his/her/its investment consultant
or financial adviser, one or more of ACR’s investment strategies or products.
For separately managed accounts, ACR offers EQR and Equity Partners strategies. SMA Advisory
and SMA Sub-Advisory accounts for both strategies are managed in accordance with each client’s
investment objectives and financial situation. In that respect, SMA Advisory and SMA Sub-
Advisory clients may impose reasonable restrictions on the management of their accounts.
Wrap Programs
ACR provides investment sub-advisory services in the form of discretionary portfolio management
to separately managed account programs sponsored by various broker-dealers or registered
investment advisers (each, the “Sponsor”) in both “dual contract” and “single contract” wrap fee
programs under which an all-inclusive (or “wrap”) fee is paid by the client to the Sponsor and the
Sponsor in turn pays ACR a portion of the fee collected from the wrap fee client (“Wrap
Programs”). Under ACR’s Wrap Program services, clients are provided access to ACR’s EQR and
Equity Partners strategies and ACR will generally execute trades on the client’s behalf through the
Sponsor. There are instances, however, where executing trades away from the Sponsor are more
advantageous to the Wrap Program client. In these instances, the Wrap Program client will pay
commissions and other charges for trade execution purposes. See Item 12 – Brokerage Practices
for additional details. Custody, tax reporting, client reporting, trading commissions, performance
monitoring and other services are typically provided by each Sponsor. ACR contracts directly with
each Sponsor’s client in dual contract programs and with the Sponsor in single contract programs.
In both the dual contract and single contract Wrap Programs in which ACR participates, the
Sponsor typically:
• assists the client in defining the client’s investment objectives based on information
provided by the client and provides the client with the opportunity to impose reasonable
restrictions on management of the account;
• determines whether the fee arrangement is suitable for the client;
• aids in the selection of an investment adviser to manage
the account (or a portion of its
assets);
• periodically contacts the client to ascertain whether there have been any changes in the
client’s financial circumstances or objectives that warrant a change in the arrangement or
the manner in which the client’s assets are managed, whether the client wishes to impose
reasonable restrictions (or additional reasonable restrictions) on the management of the
account or reasonably modify existing restrictions; and
• ensures that personnel who are knowledgeable about the account are reasonably available
to the client for consultation.
Wrap Program clients generally receive all ACR disclosure documents (including Form ADV Parts
2A and 3), as well as any required prospectuses, from their respective Sponsor.
Unified Management Accounts (UMAs)
ACR provides recommendations, typically in the form of a “model portfolio” to a number of
unified managed account (“UMA”) program sponsors (the “UMA Program Sponsors”). For these
accounts, ACR does not have discretion and does not report the performance of UMA relationships
in its various investment composites. Trades recommended by ACR may or may not be executed
by each UMA Program Sponsor, and ACR’s recommendations may or may not be implemented
by each UMA Program Sponsor in all of that sponsor’s client portfolios. ACR is not responsible
for either trade execution or reconciliation of these accounts but does provide specific trade
instructions to each UMA Program Sponsor’s trading desk. As such, ACR has determined that it
provides continuous and regular management services as it relates to its services to UMA Program
Sponsors.
Privacy and Security
For privacy safeguards and security purposes, ACR has established a Privacy Notice, which is sent
to all new clients at the time of account opening. Any material changes to ACR’s Privacy Notice
will be distributed to existing clients promptly and is available upon request by contacting us any
time as described in Item 1. When applicable, a separate supplemental Privacy Notice is
distributed to Clients residing in certain states that have enacted additional privacy disclosure
obligations. In addition, the Firm has in place a Business Continuity Plan to protect the firm and
its clients in the event of a significant business disruption. To cover all aspects of the firm’s use of
technology, a Written Information Security Plan is in place which includes a detailed cybersecurity
plan.
Mutual Fund and Limited Partnership Management
ACR also serves as the investment adviser to various commingled funds. These funds are described
below and collectively referred to within this Brochure as “the ACR Funds”:
• The “Mutual Funds” (each a series of the Investment Managers Series Trust II, registered
under the Investment Company Act of 1940), include the ACR Opportunity Fund and the
ACR Equity International Fund.
• ACR also serves as investment adviser to the ACR Opportunity, LP and ACR Strategic
Credit, LP (“ASC LP”), private funds that are structured as limited partnerships and may
advise other registered investment companies or private funds in the future (the
“Partnerships”).
ACR continuously manages the assets of the ACR Funds based on the investment goals and
objectives as outlined in the Mutual Funds’ prospectuses and the Partnerships’ private placement
memorandum, respectively. The individual needs of the investors in the ACR Funds are not the
basis of investment decisions made by ACR; investment advice is provided directly to ACR Funds
and not to the individual investors holding shares of the funds.
ANY REFERENCE TO THE ACR FUNDS WITHIN THIS BROCHURE SHALL NOT
CONSTITUTE AN OFFER TO SELL OR THE SOLICITATION OF AN OFFER TO BUY
INTERESTS IN THE ACR FUNDS.
Educational Due Diligence
ACR offers current and prospective financial intermediaries educational due diligence visits at its
home office. ACR will incur all costs including travel, meals, and lodging.
Amount of Managed Assets
As of December 31, 2023, ACR was actively managing $3,758,684,382 of clients’ assets on a
discretionary basis. Additionally, through unified managed accounts (UMAs), the Firm provides
advice on $1,862,655,387 of clients’ assets on a non-discretionary basis.