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ITEM 1 – COVER PAGE
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, IL 60606
312 429 3000
www.altairadvisers.com
10/31/2025
Part 2A of Form ADV
This brochure provides information about the qualifications and business practices of Altair
Advisers LLC (“Altair” or “Altair Advisers”). If you have any questions about the contents of this
brochure, Part 2A of Form ADV, please contact us at (312) 429-3000 or
info@altairadvisers.com. The information in this brochure has not been approved or verified by
the United States Securities and Exchange Commission or by any state securities authority.
Altair Advisers is a registered investment adviser. Registration does not imply any level of skill
or training. The oral and written communications of an adviser provide you with information
which you may use to determine to hire or retain an adviser. Additional information about Altair
also is available on the SEC’s website at www.adviserinfo.sec.gov. You may also find additional
information within our Form CRS Disclosure about how we work with clients including a
description of business practices and conflicts we face at www.altairadvisers.com/disclosures.
Investment advisers including Altair face conflicts of interest in working with clients. We use this
disclosure brochure, along with our Form CRS Disclosure, to communicate conflicts of interest
which we believe could have a meaningful impact on you. We strive to disclose these conflicts
of interest in a clear manner with sufficient information to allow you to understand their
implications. We encourage you to review this disclosure brochure carefully and notify us if you
have questions regarding the conflicts of interest identified.
No part of this brochure represents an offer to invest in any fund. Only authorized fund agents
may solicit investors after delivering the relevant Confidential Private Placement Memorandum.
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ITEM 2 – MATERIAL CHANGES
Altair Advisers LLC (“Altair” and/or “Altair Advisers”) is required to identify and discuss any
material changes made to this brochure since the last annual update (dated as of December 31,
2024). Material changes since our last annual update:
Item 1: Altair moved to a new location as of August 4, 2025. Altair’s new mailing address is:
225 W. Washington Street, Suite 2400
Chicago, IL 60606
Item 4: Added disclosure that Altair serves as investment adviser, and Altair’s wholly owned
subsidiary Rialta, LLC (“Rialta”) serves as the General Partner, to a proprietary private fund.
Altair encourages investors to consider the Confidential Private Placement Memorandum as
the authoritative source for information about the proprietary private fund and associated
conflicts.
Item 5: Added disclosure regarding the proprietary private fund’s fee structure and valuation
practices, including a reference to the Confidential Private Placement Memorandum as the
authoritative source regarding investor fees.
Item 6: Added disclosure of future performance-based fees for non-client investors in the
proprietary private fund.
Item 7: Disclosed that Altair serves as the investment adviser to its proprietary private fund.
Item 8: Removed the disclosure that described Altair’s role as a fiduciary when advising on
retirement account rollovers, as the existing disclosures describe the conflicts Altair
encounters when giving advice about retirement account rollovers.
Item 8: Added disclosure regarding the proprietary private fund’s investment style.
Item 10: Updated to note Altair will accept offers of free services and gifts from its vendors if
Altair believes these offers will improve its business.
Item 10: Disclosed Rialta LLC, a wholly owned subsidiary of Altair and General Partner to
Altair’s proprietary private fund, as an affiliate.
Item 10: Disclosed Altair’s practice of allowing select employees to serve on Limited Partner
Advisory Committees for third-party private funds and advisory boards for third-party
advisers.
Item 11: Added disclosure that certain employees may invest in Altair’s proprietary private
fund.
Item 11: Clarified that Altair offers eligible clients the opportunity to invest in private funds
ahead of Altair employees, and to redeem no later than employees when Altair recommends
redeeming client investments from a private fund.
Item 12: Disclosed Altair’s practice of offering third-party private equity investment funds to
its proprietary private fund first.
Item 13: Added disclosure that Altair’s Investment Committee monitors the proprietary
private fund.
Item 14: Noted that Rialta receives a fee for general partner services it provides to Altair’s
proprietary private fund and Altair shares advisory board compensation with employees.
Item 15: Added disclosure that Altair intends to deliver audited financial statements of the
proprietary private fund within 180 days of the fiscal year end.
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We will provide you with a summary of any material changes to this and subsequent disclosure
brochures annually. From time to time, we will provide other disclosure information about
material changes as necessary.
Currently, our disclosure brochure may be requested by contacting Claire Browne, Director of
Compliance, at (312) 429-3000. Our disclosure brochure also is available on our website
www.altairadvisers.com/disclosures. You may also find additional information about how we
work with clients including a description of business practices and conflicts we face on our
website at www.altairadvisers.com/disclosures. Additional information about Altair is also
available via the SEC’s website www.adviserinfo.sec.gov.
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ITEM 3 – TABLE OF CONTENTS
Item 1 – Cover Page…………………………………………………………………
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Item 2 – Material Changes…………………………………………………………..
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Item 3 – Table of Contents……………………………………………………………
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Item 4 – Advisory Business…………………………………………………………
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Item 5 – Fees and Compensation……………………………………………...........
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Item 6 – Performance-Based Fees and Side-By-Side Management………........... 5
Item 7 – Types of Clients…………………………………………………………….
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss…………
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Item 9 – Disciplinary Information…………………………………………………..
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Item 10 – Other Financial Industry Activities and Affiliations…………………..
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Item 11 – Code of Ethics………………………………………………………………
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Item 12 – Brokerage Practices ……………………………………………………….
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Item 13 – Review of Accounts……………………………………………………….
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Item 14 – Client Referrals and Other Compensation……………………………...
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Item 15 – Custody……………………………………………………………………..
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Item 16 – Investment Discretion…………………………………………………….
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Item 17 – Voting Client Securities…………………………………………………..
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Item 18 – Financial Information…………………………………………………….
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Item 19 – Other Information………………………………………………………...
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Brochure Supplement(s)
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ITEM 4 – ADVISORY BUSINESS
Altair provides objective, discretionary and non-discretionary investment advisory and financial
planning services for wealthy individuals, families and foundations.
History and Ownership
Altair Advisers was formed on June 1, 2002. It was created with an exclusive focus on providing
investment counsel to high net worth individuals, families and foundations. We believe that
providing investment and financial advice is a separate and distinct business from the selling of
investment products. Altair’s principals formerly led the Investment Advisory Services practice of
Arthur Andersen’s Chicago office. We serve a nationwide base of clients who have entrusted us
to oversee more than $8.6 billion (as of December 31, 2024).
Altair is primarily employee-owned and committed to building long-term successful relationships
by providing responsive and highly personal service. The employee group participates broadly
in Altair’s ownership. One of the firm’s owners is an entity controlled by a client who helped fund
the firm at its inception. The client which controls this entity does not, nor has requested to,
receive preferential treatment, aside from access to financial and operational information about
the firm and other rights customarily provided to an investor in a business.
What We Do
Altair’s core investment consulting services include: investment policy creation, asset allocation
advice, investment manager due diligence and portfolio management services. We also provide
performance reporting, capital sufficiency analysis and cash flow management for all investment
consulting clients.
ALTAIR’S SERVICE APPROACH
Altair first works with the client to develop an overall investment strategy. This phase of the
process includes an analysis of financial goals, which generally considers advice regarding
capital sufficiency and cash flow, retirement planning, income tax planning, education funding,
corporate benefit decisions and consideration of estate planning. The result of this overall
analysis serves as the foundation for a client's strategic investment plan, which includes
investment education, portfolio design and preparation of an Investment Policy Statement.
After developing an overall strategy documented in a written Investment Policy Statement, for
discretionary clients, Altair will be directly responsible for making investment decisions on behalf
of those clients. For non-discretionary clients, Altair will obtain a client's consent before making
an investment decision on behalf of those clients.
For both discretionary and non-discretionary clients, the client’s assets will be invested with
third-party investment managers, mutual funds (potentially including mutual funds for which
Altair serves as investment adviser), Exchange Traded Funds (“ETFs”), private investments
(potentially including Altair’s affiliated private fund) and derivatives. For assets where there is
not a predetermined list of investment options, Altair will only utilize those third-party managers,
mutual funds, ETFs, private investments or derivatives after it has conducted due diligence on
each recommendation for investment (“Altair assets”). For client assets that have pre-
determined investment choices (e.g., inside a client’s 401(k) plan), Altair will assist the client
with regard to those choices to the extent permitted and practicable (“outside assets”).
Altair serves as investment adviser to the Adara Smaller Companies Fund and Aquarius
International Fund of the RBB Fund, Inc. (each an “Altair Fund” and collectively the “Altair
Funds”), each an investment company registered under the Investment Company Act of 1940,
as amended. Altair expects only select individuals and entities known to Altair to be
shareholders of the Altair Funds, including Altair clients, employees and other related parties.
Altair often recommends each Altair Fund as an investment vehicle for its clients, including
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clients governed by the Employee Retirement Income Security Act (“ERISA”). Altair has
adopted the following practices and controls in recommending each Altair Fund to its clients
subject to ERISA:
As more fully described in Item 5 below, Altair does not charge a separate fee for
managing the Altair Funds;
The ERISA plan will not pay any sales commission or redemption fee related to
investments in the Altair Funds; and
Altair will obtain approval to invest the client’s assets in each Altair Fund from an
independent fiduciary of the ERISA plan after providing information about each Altair
Fund to the independent fiduciary, including a description of: a) fees paid; b) Altair’s
rationale for recommending each Altair Fund as a suitable investment; and c) any
limitations related to the timing of purchases and withdrawals.
As described more fully within the prospectus, the Altair Funds utilize a “multi-manager”
approach whereby the Altair Funds’ assets are allocated to one or more third-party advisers
(“Sub-Advisers”) in percentages determined by Altair. Each Sub-Adviser acts independently
from other Sub-Advisers and utilizes its own distinct investment style in selecting securities.
However, each Sub-Adviser, under the oversight of Altair, operates within the constraints of
each Altair Fund’s investment objective and strategies and the particular investment restrictions
applicable to that Sub-Adviser.
Altair serves as investment adviser, and Altair’s wholly owned subsidiary Rialta, LLC (“Rialta”)
serves as the General Partner, to a proprietary private fund. This fund invests in other
unaffiliated private equity funds (each an “Underlying Fund”). Only qualified investors may invest
in Altair’s proprietary private fund, as described in the Confidential Private Placement
Memorandum. Altair encourages investors to consider the Confidential Private Placement
Memorandum as the authoritative source for information about the proprietary private fund and
associated conflicts.
Altair does not provide investment services related to specific securities or sectors other than:
(a) to recommend third-party investment managers, mutual funds, ETFs, private investments
and derivatives; and (b) in connection with its role as adviser to the Altair Funds and the
proprietary private fund.
Altair will be responsible for arranging the execution of the investment decisions for its
discretionary clients. For its non-discretionary clients, Altair will arrange the execution of the
investment decision only after it receives authorization to do so from the client. Clients can
impose restrictions with respect to specific securities or types of securities in the accounts
managed by third-party investment managers.
In addition, Altair typically provides administrative services to both its discretionary and non-
discretionary clients, including transferring assets between a client's accounts. For clients who
have invested their assets in private investment vehicles that make additional capital calls
(including Altair’s proprietary private fund), Altair generally has limited discretion to respond
directly to such capital calls without the need to first seek client authorization. Specifically, Altair
will process the capital call by transferring assets to the investment vehicle directly from the
client's account. Further, should a client's account not have sufficient cash to fund the capital
call, Altair's limited discretion would give it the ability to dispose of holdings/investments in the
client's account sufficient to meet the capital call.
Altair also provides consulting and investment advisory services to retirement plans, trusts,
estates, charitable organizations, corporations or other business entities. Typical services
provided to these clients are consistent with the process described above.
As described within Item 19, Altair works with a third-party vendor which provides class action
litigation monitoring and securities claim filing services. This vendor will complete claims for all
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of our clients who do not opt out of such a service. In return for this service, the vendor receives
a percentage of any settlement collected. Altair does not receive a payment for services
provided by the third-party vendor, aside from its negotiated investment management fees for
managing Altair assets as described within Item 5 below. Altair is not responsible for class
action or similar legal litigation matters related to the Altair Funds.
SERVICES FOR LIMITED FINANCIAL PLANNING CLIENTS
Altair provides financial planning services in addition to investment advisory services. Financial
planning services include an analysis of financial goals, which generally considers advice
regarding capital sufficiency and cash flow, retirement planning, income tax planning, education
funding, corporate benefit decisions and estate planning matters.
Altair is at times retained by a corporation to provide these financial counseling services to key
officers and executives of the corporation and to provide financial planning seminars and other
educational services to groups of employees.
PROJECTS
Altair will provide other limited, negotiated services as an accommodation to clients, as agreed
to by Altair.
ASSETS UNDER ADVISEMENT
As of December 31, 2024, Altair had total assets under advisement of $8,681,860,723. Of this
total, $3,977,273,186 were managed on a discretionary basis and $4,704,587,537 were
managed on a non-discretionary basis.
ITEM 5 – FEES AND COMPENSATION
Fees for Altair’s services are documented in a written engagement contract at the inception of
each engagement. While we generally do not negotiate fees, we will negotiate fees in certain
circumstances based primarily on the size of the account and relationship with Altair.
Fees for Investment Advisory Clients
In the case of investment advisory services clients (i.e., for both Altair assets and outside
assets), Altair will at times charge fees for the first phase of services, which includes developing
a strategic investment plan. These fees are determined based on the complexity of the client's
situation and the scope of the work involved. If there is a fee for this phase it is generally billed
as a one-time project fee.
Fees for the second phase of services, including implementation and ongoing portfolio review,
are generally calculated based on a percentage of client assets under advisement and are
payable quarterly in advance. Assets under advisement include those mutually determined and
agreed upon with the client and Altair.
Our current standard fee schedule is:
Fees as a Percentage of Assets
Assets Subject to Fee
0.80% on the first $5 million
plus 0.50% on the next $15 million up to assets of $20 million
plus 0.35% on the next $30 million up to assets of $50 million
plus 0.25% on the next $50 million up to assets of $100 million
plus 0.10% on the assets above $100 million
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Altair has had other fee schedules in effect during the time it has been in business that could be
lower or higher than those outlined above. Based on the fee schedule in effect at the time of
engagement and the size of a particular account, Altair clients will probably pay different fees.
Altair manages client accounts based on their investment goals, regardless of their fees. While
Altair’s fee schedule creates an incentive to encourage clients to remain invested, Altair follows
investment guidelines created with the client and documented within an investment policy
statement in advising that client.
Altair imposes a minimum annual fee of $50,000 which increases by 3% every four quarters.
This minimum will be reduced under certain limited circumstances and/or certain long-time
clients are “grandfathered” under a prior fee arrangement.
Altair deducts fees directly from the client’s account, unless otherwise mutually agreed upon.
Altair generally does not take into consideration cash flows occurring during the subsequent
quarter when calculating fees except in unusual circumstances (such as in connection with a
new client account or a substantial new cash flow as agreed upon with the client). As agreed
upon between Altair and the client, Altair generally consolidates fees for accounts under the
same household for fee billing purposes.
Fees to Altair do not include any fees due to third-party investment managers, mutual funds,
ETFs, private investments and derivatives, any fees due to brokers or to custodians of those
assets or the fees associated with outside assets (e.g., 401(k) fund fees). Such charges, fees
and commissions are exclusive of and in addition to Altair’s fee, and these fees will vary based
on the nature of the investment vehicle. Clients considering an investment in private investment
funds offered by third-parties should consult the applicable offering documents as the
authoritative source for a description of fees to be charged.
Altair strives to recommend that its clients invest in the lowest mutual fund share class available
to the client, though that share class does not always represent the lowest share class available
to other shareholders as determined by the mutual fund’s sponsoring company.
Neither Altair nor any of its supervised persons receive any portion of the commissions or fees
clients pay to any recommended investment manager, mutual fund, ETF, private investment or
derivative broker or custodian. See Item 12 for a discussion of our brokerage practices. Owners
of Altair are eligible to use its services free of charge, and some family members of employees
receive fee discounts.
Clients could obtain access to these same investment managers, mutual funds, ETFs, private
investments and derivatives directly without going through Altair. However, in order to do so, we
believe they would likely have to invest at a substantially higher minimum investment and/or pay
higher management fees associated with such investments.
Other financial planning-related projects are billed in a manner agreed upon by Altair and the
client. Accounts initiated or terminated during a calendar quarter are charged a prorated fee.
Upon termination of any account, any prepaid, unearned fees are refunded to the client.
Fees for Limited Financial Planning Clients
As described in Item 4, Altair also provides financial planning services. When we are retained by
a corporation to provide financial counseling services to key officers and executives of the
corporation (collectively, “executives”), fees are generally charged to the corporation based on a
fixed-fee entitlement arrangement for each executive dependent on the scope and complexity of
the services being performed. Altair's fees generally range from $5,000 to $30,000 per
executive participant. When we are retained by a corporation to provide financial planning
seminars and other educational services to groups of employees, fees for these services are
based on fixed-fee arrangements as negotiated with the corporation.
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Fund Fees
Altair does not charge an investment management fee for serving as adviser to the Altair Funds
or to the classes of the proprietary private fund in which clients invest. Altair charges a
management fee to other non-client classes of its proprietary private fund, as described within
the Confidential Private Placement Memorandum. Each Altair Fund’s prospectus and the
proprietary private fund’s Confidential Private Placement Memorandum describe the fee
structures. Altair created these vehicles for its clients to access investment managers or
unaffiliated private funds otherwise unobtainable to some clients because of account minimums.
Each Sub-Adviser’s management fee, as well as other expenses described within the
prospectus (legal, compliance and record-keeping), are charged directly to each applicable
Altair Fund, and such expenses are borne by all shareholders of that Altair Fund.
Each Underlying Fund assesses a management fee to the proprietary private fund. Rialta
charges the proprietary private fund a fee for general partner services it provides. Altair
encourages investors in the proprietary private fund to consider the Confidential Private
Placement Memorandum as the authoritative source regarding investor fees.
Altair includes client assets invested in the Altair Funds and the proprietary private fund in its fee
calculation for ongoing investment advisory services.
Project Fees
At times, fees are charged based on hourly rates, which vary from $200 to $500 per hour. At
other times, fees are charged on a project basis. Project fees generally apply to all types of
clients and will be negotiated for each unique engagement in advance of beginning project
work.
Valuation Practices
Altair uses market values for publicly-traded securities as provided by Altair clients’ custodians
to determine fees and investment performance returns. In determining the market value to use,
Altair ranks client custodians by total client assets held, and uses the prices provided by the
custodian with the largest amount of client assets held. If that custodian does not provide a
price, Altair defers to other custodians within the hierarchy until a custodian offers a price
deemed reasonable.
Altair handles the daily oversight of valuation matters for the proprietary private fund on behalf
of Rialta. The primary method for valuing a proprietary private fund is to value its investments
based on the net asset value (“NAV”) reported in the most recent independent statement
received from the administrator of each Underlying Fund. If an independent statement is not
available, or if Altair deems the NAV reported to be unreliable, each fund will value its
investments as the sum of capital contributions made, less any return of capital or distributions
received.
Altair will establish a value for portfolio companies purchased through co-investments based on
its knowledge of any factors deemed relevant. These factors can include financial statements
provided by the portfolio company, knowledge of the portfolio company and the industry in
which it operates, and general market conditions. Neither Altair, its proprietary private fund, nor
any of its employees currently take part in co-investments alongside private funds to purchase
portfolio companies.
For unaffiliated private funds, Altair obtains values of private funds deemed to be liquid from the
investment manager or the private funds’ administrators. Altair considers third-party private
funds to be liquid if the investor can routinely invest in or redeem from the fund subject to known
constraints identified within the private fund’s offering documents.
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As a matter of policy, Altair does not determine the prices of third-party private funds considered
to be illiquid in nature. Rather, Altair uses either; 1) capital balance statements provided by the
private fund’s investment manager once they are available (generally, after a few quarters
following the first capital call); or 2) the sum of capital calls prior to a capital balance statement
being made available by the investment manager. Given the inherent limitations associated with
receiving the necessary information from the investment manager, the values provided by the
unaffiliated investment manager often represent a lag of up to 150 days or more.
In the unlikely event an Altair pricing source outlined above is not able to, or does not, provide a
price for an asset held in client portfolios, Altair will value the asset via alternative sources
deemed reliable, including external pricing sources or determining a fair value for the asset with
input as appropriate from a Sub-Adviser or underlying private fund. In determining a fair value,
Altair will strive to value the asset at a price Altair deems clients could reasonably be expected
to receive upon sale of the asset.
Altair encounters inherent conflicts of interest when it participates in the valuation of client
accounts, as higher values of client holdings increase market values, thereby enhancing
performance results and increasing fees. Altair maintains various policies, procedures and
controls (including a valuation policy, segregation of duties and the use of an unaffiliated fund
administrator for its proprietary private fund) to mitigate such conflicts of interest.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
While Altair does not currently charge a performance-based fee (fees based on a share of
capital gains on or capital appreciation of the assets of a client), future non-client investors in
Altair’s proprietary private funds could pay a performance-based fee as carried interest. Altair’s
aim is to comply with the exceptions outlined within Rule 205-3 when charging performance-
based fees.
These performance-based fee arrangements would create an incentive for Altair to invest in a
different manner than in an account without a performance-based fee, with the aim of increasing
Altair’s compensation.
Other than limited investment opportunities described in Item 12, Altair does not presently
encounter side-by-side issues in managing client accounts.
ITEM 7 – TYPES OF CLIENTS
As described in Items 4 and 5, Altair provides portfolio management services to high net worth
individuals, families, foundations and endowments. In a few select cases where there is a direct
client connection, Altair provides investment advisory services for corporate pensions, profit
sharing plans and charitable organizations. Altair also serves as the investment adviser to its
proprietary private fund and the Altair Funds.
Altair has an initial investment minimum of $7 million and a minimum annual fee of $50,000 for
ongoing investment advisory services (which increases by 3% every four quarters). In certain
circumstances, exceptions to these minimums are made; for example, where the owner of the
account has a familial relationship with an existing client or where the prospective client is
expected to meet the initial investment minimum in the near future. In addition, certain long-time
clients are “grandfathered” under a prior fee arrangement. Third-party investment managers,
mutual funds, ETFs, private investments and derivatives impose investment minimums that will
likely impact the client’s investment selection process. Minimum investment requirements for
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investment in an Altair Fund are found in that Altair Fund’s prospectus. The proprietary private
fund's Confidential Private Placement Memorandum details the minimum investor account size.
Altair’s investment management agreement with the client determines the protocol the client or
Altair will follow in terminating accounts.
Altair and its personnel maintain separate relationships with certain clients and others, such as:
Select clients, vendors or other service providers used by firm clients are family members or
personal friends with firm personnel. As such, these clients maintain separate personal
relationships with firm personnel. At times, firm personnel will engage in personal business
dealings with these clients as a natural extension of their personal relationships.
Some clients are affiliated with entities which have a business relationship with the firm (such
as firm vendors or other service providers used by firm clients), and certain of these entities
have engaged us to manage their investment portfolios.
Subject to advanced clearance, Altair employees are permitted to invest in financial entities
affiliated with clients, such as venture capital or similar funds.
As noted within Item 11 below, Altair employees are permitted to accept gifts from certain
vendors deemed to be lower risk in nature.
To address these potential conflicts of interests, all relationships with vendors are designed to
be arms’ length in nature, and gifts received are determined to not impact Altair’s decision-
making processes. Altair also maintains policies and procedures designed to ensure clients are
treated fairly as summarized within this disclosure document. \Further, all client relationships
are managed following a team approach, with no single employee responsible for any individual
client’s account.
We have an incentive to encourage individual clients to rollover an employer retirement account
into an Altair-managed Individual Retirement Account (“IRA”). The decision of whether to roll
over an employer retirement account rests with the individual account owner, and we are
committed to providing information to help a client make a decision that is in that client’s overall
best interests.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of
Analysis
Rather than selecting individual stocks and bonds, Altair focuses on finding best-in-class
investment managers, including Sub-Advisers to manage the Altair Fund’s assets and
Underlying Funds for the proprietary private fund. The process of selecting investment
managers and funds is described below.
PROCESS FOR ALTAIR ASSETS (WHERE INVESTMENT CHOICES ARE NOT PRE-
DETERMINED E.G., CLIENT-DIRECTED OR LIMITED OPTIONS WITHIN A 401(K) OR
OTHER PLAN)
SETTING AN AGENDA
Altair’s Investment Committee begins by identifying and approving research projects for new or
existing asset classes and oversees full reviews of our currently recommended investment
managers, mutual funds, ETFs and private investments. A full review of each asset class is
done regularly, generally every three years.
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QUANTITATIVE SCREENS
Once a particular search is initiated, Altair’s research team pre-screens third-party databases to
examine those strategies that meet basic quantitative requirements. We have a preference for
investment managers, mutual funds, ETFs and private investments with relatively strong risk
adjusted returns and generally at least five years of return history.
QUALITATIVE SCREENING
We focus our efforts during this stage on the investment managers, mutual funds or private
investments to remove those that have undesirable attributes, such as holding too many
securities in their composite portfolio, poor historical after-tax returns, excessive assets relative
to the strategy or insufficient total firm assets under management.
Those that pass the general qualitative screens are then examined more thoroughly.
Considerations include the growth of the sponsoring firm’s total assets over time and the
fundamentals of the portfolio. These factors vary based on asset class. For example, when
examining an equity product, these include price-to-equity ratio, price-to-book ratio and
weighted-average market cap. A rolling returns-based style analysis is used to eliminate
investment managers, mutual funds, ETFs or private investments that have changed in
investing style over time. Then a detailed questionnaire is sent to potential candidates in order
to gather more information.
After reviewing all data and information, the Investment Committee selects the candidate firms
which it believes merits an onsite visit by an Altair investment professional. Ultimately, Altair’s
Investment Committee will be presented with finalists to be considered for potential inclusion on
our recommended list.
In addition to the above, when evaluating private investments, we will review the legal structure
of the investments, funding and withdrawal provisions. Altair uses an industry leading vendor in
the field of investigative due diligence to delve into the background of the principals of the
private investment firm. We also rely on the insights and opinions of consultants, appraisers,
accountants, lawyers, and industry sources as needed.
PROCESS FOR OUTSIDE ASSETS (WHERE INVESTMENT CHOICES ARE PRE-
DETERMINED E.G., CLIENT DIRECTION OR LIMITED OPTIONS WITHIN A 401(K) OR
OTHER PLAN)
Altair will assist clients with the selection of investment options where predetermined choices
are provided as follows:
We recommend any fund which is already subject to due diligence as described just
above in “Process for Altair assets (where investment choices are not pre-determined
e.g., client directed or limited options within a 401(k) or other plan)”.
If no investment choices exist which fulfill this requirement, then we will recommend
index funds which complement a client’s asset allocation.
If no investment choices exist which fulfill this requirement, we will review the investment
options and make a recommendation based on fit within the client’s overall asset
allocation strategy, historical performance and information known at the time about the
fund.
Altair does not offer extensive and ongoing due diligence on the universe of predetermined
options for each plan where we assist our clients by making an investment recommendation.
We rely on clients to provide updated information on the list of predetermined investment
options from time to time for review and recommendations. We include these outside assets in a
client’s performance report when a client agrees that these assets should be part of our
engagement. We will recommend a change to a different option within the allowable investment
choices when appropriate.
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Investment Strategies
Altair believes it is crucial to listen to clients and understand their goals and objectives prior to
making any investment recommendations. We then create an investment portfolio designed to
achieve those goals and objectives in a risk-controlled manner. When recommending a portfolio
strategy, we recognize the importance of asset allocation and diversification but also consider
the principles of behavioral finance and investor psychology. As historical events demonstrate
so vividly, it is imperative to understand the relationship between risk and return and to
understand the degree to which portfolio declines can be tolerated.
Altair’s investment process can be described as a strategic asset allocation approach with a
tactical overlay. We create and implement long-term strategic investment plans that are
appropriate for each client’s financial objectives, risk preference and constraints. However, on
an ongoing basis we will recommend overweights and underweights to certain asset classes
based on our proprietary research and valuation methodology. In other words, while we believe
strategic asset allocation works best over long periods of time, we also believe allocation
modifications are warranted under certain circumstances. Altair’s Investment Committee is
responsible for all investment recommendations with regard to both asset allocation and
investment managers. The Investment Committee currently consists of five members with, on
average, over 30 years of investment experience.
As described within the Confidential Private Placement Memorandum, the proprietary private
funds seek capital appreciation by investing in a variety of third-party private equity funds
focused on companies located primarily in the United States. Each Underlying Fund the
proprietary private fund invests in is managed by an investment team or manager. The
investment strategy of the proprietary private fund involves the disciplined selection of
Underlying Fund managers.
Altair does not advertise that it will manage accounts or invest in securities based on
Environmental, Social and Governance (“ESG”) criteria. However, Altair will consider prospect
or client-specific ESG guidelines or restrictions on a case-by-case basis.
Risk of Loss
Any investing involves risk of loss that clients should be prepared to bear. We do not offer any
products or services that guarantee rates of return on investments for any time period.
MUTUAL FUNDS AND EXCHANGE TRADED FUNDS
Mutual fund and ETF shareholders are subject to various inherent risks applicable to all
shareholders, including inherent risks associated with the individual issuers of each fund’s
underlying portfolio securities. Please see each fund’s prospectus for a more detailed
description of that particular fund’s risks.
While shares of ETFs generally trade on the market at or near their most recent NAV, certain
inefficiencies could cause ETF shares to trade at a premium or discount to the calculated NAV.
ETFs redeem shares which are aggregated as creation units comprised of a minimum number
of shares. As such, shareholders of ETFs would likely be limited in their ability to dispose of
shares held if a liquid secondary market ceases to exist for shares of a particular ETF.
Closed-end funds, unlike open-end mutual funds, trade on the market, generally at a premium
or discount to NAV based on various market factors. Purchasing shares of a closed-end mutual
fund at a discount does not guarantee a profit, as there can be no assurance the closed-end
mutual fund’s market price will subsequently revert to the fund’s calculated NAV.
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THIRD-PARTY INVESTMENT MANAGERS
While Altair conducts ongoing due diligence of third-party investment managers, the successful
implementation of a client’s objectives related to assets managed by a third-party investment
manager is dependent upon the third-party investment manager’s ability to successfully
implement its investment strategies. In addition, Altair is not an affiliate of any third-party
investment manager and, therefore, is not in a position to supervise the third-party investment
manager’s activities.
THIRD-PARTY PRIVATE POOLED INVESTMENT VEHICLES
Managers of third-party private funds and other private pooled investment vehicles (including
hedge funds and private equity funds) often have broad discretion in managing the portfolios,
and such private funds are generally not registered with the SEC. Private funds are invested in
a variety of financial instruments (including derivatives and other leveraged financial
instruments) following a variety of strategies (including trading on margin with no obligation to
diversify), resulting in potentially greater risks than publicly registered investment vehicles.
Investors in such private pooled investment vehicles are advised to refer to each fund’s offering
documents for a greater description of the fund’s risks. Altair is not an affiliate of any third-party
private fund and, therefore, is not in a position to supervise the third-party private fund’s
activities.
PROPRIETARY PRIVATE FUND
The Confidential Private Placement Memorandum of the proprietary private fund discusses the
risk factors investors should consider when making an investment in the proprietary private
fund.
EXCHANGE TRADED DERIVATIVES
The use of exchange traded derivatives for a client account might create additional investment
risk if the instrument does not correlate well with the index or if Altair's view of the market is
incorrect. In addition, the use of derivatives might expose the client to leverage risk, which
would likely magnify or otherwise increase the risk of investment losses.
ADARA SMALLER COMPANIES FUND AND AQUARIUS INTERNATIONAL FUND
Clients investing in an Altair Fund should carefully read each prospectus for risks specific to that
Altair Fund. Sub-Advisers will invest primarily in equities and equity-related instruments of small
and micro-cap companies for the Adara Smaller Companies Fund and international securities
for the Aquarius International Fund, including common stocks, preferred stocks, convertible
securities, sponsored and unsponsored depositary receipts, warrants and rights.
MARKET RISKS
The success of our recommendations depends to a great extent upon the future course of the
financial markets’ price movements of various investment vehicles, which are very much not
within our control.
ARTIFICIAL INTELLIGENCE RISKS
Altair uses artificial intelligence large language models (“LLMs”) and other tools to enhance the
efficiency of certain internal business processes. Select third-party investment managers
(including Sub-Advisers) use artificial intelligence tools in various fashions to improve their
investment management processes, subject to their internal policies and oversight. While these
tools enhance efficiency and provide valuable insights, they also present risks. Artificial
intelligence tools, such as LLMs, may produce outputs that are inaccurate, incomplete, or
biased because of their training on diverse datasets.
INFLATION RISKS
Inflation represents the increase of goods and services over time, and acts to decrease the real
value of your investments. We have no control over inflation, and there can be no assurance
client investment portfolios will keep pace with the rate of inflation.
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ITEM 9 – DISCIPLINARY INFORMATION
Altair has no events or information applicable to this Item.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
As described in Item 4 above, Altair serves as investment adviser to the Adara Smaller
Companies Fund and Aquarius International Fund of the RBB Fund, Inc. Altair also serves as
the investment adviser to its proprietary private fund, for which Altair’s wholly-owned affiliate,
Rialta, serves as the General Partner. Altair is not affiliated with other financial services entities.
Some Altair employees hold all shares of Zembra Investments LLC (“Zembra”). Zembra serves
no other purpose than to invest in units of Altair.
Select Altair employees serve on Limited Partner Advisory Committees (“LPACs”) for third-party
private funds, subject to advance approval and ongoing reporting obligations. Altair determined
that permitting select employees to serve on LPACs would be in the best interests of the firm, its
clients and the proprietary private fund’s investors as each employee’s LPAC involvement will
provide additional insight into the fund and its manager’s staff. Altair and Rialta reserve the right
to prohibit employees from serving on LPACs for any reason. When serving on an LPAC, the
employee’s fiduciary duty rests with Altair and its clients, and not with the third-party private fund
or its manager. In considering whether to approve the employee’s participation on an LPAC,
Altair considers, among other matters, whether the third-party fund manager’s compliance
program is adequate and effective to prevent the Altair employee from receiving proprietary
information about the fund manager’s current or planned trading activity. The employee also
does not receive compensation for participation on the LPAC, seeks indemnification for serving
on the LPAC, and abstains from voting or discussing matters where Rialta or Altair have a direct
conflict because of their involvement with the LPAC. Altair expects employees to resign from the
LPAC upon fund divestment.
With advance approval, select employees may serve on an advisory board for a third-party
adviser. These roles usually come with pay, and Altair works with the employee to determine
the percentage of compensation Altair will receive. Altair reviews each arrangement for potential
conflicts, including compensation, time commitment and competing duties. If Altair cannot
address these conflicts to its satisfaction, it will not approve the arrangement. The employee’s
advice to the third-party advisers follows the same standard of care Altair extends to its clients.
Compliance considers the employee’s role on an LPAC or advisory board when reviewing the
employee’s personal trading activity.
Altair at times receives reimbursement for employee travel costs from sponsors of conferences
at which Altair employees are featured speakers or panelists. Altair will accept offers of free
services and gifts from its vendors if Altair believes these offers will improve its business. For
example, Altair accepted an offer from a banking vendor to take part in a practice management
conference without charge.
ITEM 11 – CODE OF ETHICS
Altair invests in money market funds, mutual funds and ETFs within its corporate reserve
accounts to manage operating capital. Employees are eligible to (and do or plan to) invest with
the third-party investment managers, mutual funds (including the Adara Smaller Companies
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Fund and Aquarius International Fund), ETFs, private investments (including Altair’s proprietary
private fund) and derivatives which Altair also recommends to clients. Our recommendations are
not time sensitive and are intended to be durable in nature. We will recommend that clients who
implement portfolios at different times invest with similar investment managers, mutual funds,
ETFs and private investments. We are not concerned when an investment is made as we view
each recommended investment as beneficial to the portfolio over the long term. Thus, the timing
of an investment is not central to our recommendations or investment strategies. Though we will
recommend underweighting and overweighting various asset classes from time to time, the
underlying recommendation of investment managers, mutual funds, ETFs and private
investments is relatively consistent across time.
Altair recommends investment opportunities with a limited supply, such as unaffiliated private
investment funds available to qualified purchasers. As noted in Item 12, Altair maintains a policy
of providing eligible clients with the option to invest in these limited investment opportunities. If
the investment opportunity has sufficient supply remaining after offering the opportunity to
eligible clients, eligible Altair employees (owners and directors) may purchase the unaffiliated
private investment fund subject to advance clearance. These Altair employees are not subject to
the same minimum investment Altair imposes on client accounts when investing in these funds.
Altair designed the third-party private fund investment minimums to protect the client’s portfolio.
Altair offers eligible clients the opportunity to invest ahead of Altair employees, and to redeem
no later than employees if Altair recommends clients liquidate holdings of the investment.
Owners and directors often invest in unaffiliated private investment funds alongside clients.
Altair’s “Knowledgeable Employees”, as defined by Rule 3c-5 under the Investment Company
Act of 1940, may invest in Altair’s proprietary private fund without being a qualified investor,
subject to advance approval. These “Knowledgeable Employees” include executive officers,
directors and employees who, in connection with their regular functions or duties, take part in
the investment activities of the proprietary private fund or Altair Funds. Altair permits other
employees who are qualified investors to invest in the proprietary private fund. Altair offers
eligible clients the opportunity to invest in its proprietary private fund ahead of employees, and
to redeem their investment no later than employees when Altair recommends redeeming client
investments from a private fund. For example, Altair doesn’t permit employees to invest in the
initial close of a proprietary private fund to help ensure clients have access to the fund first.
Altair has adopted a written Code of Ethics that governs the personal securities transactions of
employees and officers. The Code of Ethics permits Altair's employees to engage in other
securities transactions. Thus, officers and employees purchase individual securities which at
times are also purchased by the independent, third-party investment managers retained by
Altair's clients (including Sub-Advisers to the Altair Funds).
Since our advice is not time-sensitive but intended to be durable and long-term in nature, Altair
employees are permitted to purchase or sell any publicly-traded securities for their own
accounts prior to, simultaneously with, or subsequent to any action taken in a client portfolio or
in an investment manager account. Officers and employees, including members of the
Investment Committee, are also permitted to invest their personal holdings in a manner which is
not consistent with Altair’s advice provided to clients. Further, Altair employees have no
advanced knowledge of third-party investment manager trading activity. Since we are not
portfolio managers in the traditional sense of buying and selling publicly-traded securities for
client accounts and we do not have knowledge of trades placed by third-party investment
managers until after they occur, we do not believe the personal investing activities of our officers
and employees in publicly-traded securities create a conflict of interest with our clients.
Altair's Code of Ethics requires individuals to report required personal securities transactions on
a quarterly basis to Altair's compliance personnel. Altair does not require employees to report
transactions in certain types of investments, including direct obligations of the United States
Government, accounts over which the employee has no discretionary authority, direct
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obligations of the United States Government, short-term instruments, automatic investment
plans and direct investments in currency (including cryptocurrency).
Altair’s inherent business model results in Altair employees periodically receiving material
nonpublic information from clients regarding their employers. Altair’s Code of Ethics restricts
trading by employees in securities where clients are insiders.
As described in Item 4 above, Altair serves as the investment adviser to the Altair Funds and
recommends most clients to invest in the Altair Funds.
Our Code outlines the standards of conduct we expect of Altair employees and includes
limitations on outside business activities of employees and giving/receiving gifts. Outside
Business Activities are generally prohibited; any exception requires advanced approval by
Compliance.
While we believe the proper use of business entertainment and gifts creates goodwill and aids
in the development of strong working relationships, as a matter of policy, we strive to not offer
nor receive business entertainment or gifts which could be viewed as influencing the recipient’s
investment decision-making process or making the recipient feel beholden to any client,
prospective client, broker, third-party manager, or investment management-focused vendor.
We maintain a policy which prohibits employees from receiving gifts from investment
management-focused vendors or suppliers, clients, prospective clients, brokers or third-party
investment managers, except those extended as a customary courtesy. Altair employees are
permitted to accept gifts from vendors or suppliers who are not investment management-
focused so long as the nature of the gift is not viewed as being: 1) overly generous; or 2) aimed
at making the employee feel beholden to the entity. Our policy also prohibits employees from
soliciting gifts, benefits or gratuities, and places limitations on our employees’ abilities to give
gifts to those with whom Altair has a business relationship.
A copy of the Code of Ethics will be furnished to any client or prospective client upon request.
ITEM 12 – BROKERAGE PRACTICES
For clients that have provided Altair with trading authorization, we generally process
transactions for the sale and/or purchase of securities and other investments in the client's
account solely through the client's custodian-affiliated broker. Under these circumstances, Altair
does not have any obligation to seek better execution services or prices from other possible
brokers or dealers.
Altair generally does not aggregate client transactions for execution, which might cause the
client to incur higher fees than they otherwise would have incurred if the trade had been
affected in aggregation with other clients. However, Altair at times will choose to aggregate (or
“block”) trades within client accounts of the same family when aggregating trades is deemed to
be in the best interest of participating clients. All accounts participating in the aggregated order
receive an average share price with transaction costs shared pro rata based on each account’s
participation in the transaction.
Altair views each recommended investment as beneficial to the portfolio over the long term and,
as such, the timing of an investment is not central to our recommendations or investment
strategies. Altair arranges the execution of the investment decisions for non-discretionary clients
only after it receives authorization to do so from the client. As such, non-discretionary client
accounts will generally trade the same security after discretionary client accounts, and non-
discretionary clients will likely pay more or less than other discretionary clients for the same
security, due to market trading activity.
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Principals of the firm often recommend that clients retain those custodians or brokers that have
agreed to preferred pricing arrangements for Altair clients such that all negotiated terms directly
benefit the client through enhanced services or reduced fees. Recommended brokers or
custodians are not necessarily the lowest-cost provider, but are those that Altair believes are
competitively priced for the level of service provided. Not all advisers recommend custodians or
brokers to their clients. However, a client is free to retain any custodian or broker dealer they
choose. While Altair is able to realize operational efficiencies by having its clients’ assets reside
with a limited number of custodians, Altair-recommended brokers or custodians are selected
based on Altair's consideration of the broker or custodian's general reputation, level of services
provided, competitiveness of fees or special expertise.
Altair generally recommends custodians to clients that have demonstrated the ability to provide
our clients with discounted transaction charges, preferred access to certain mutual funds,
including lower sales charges than for direct purchases and lower minimum purchase amounts,
and the ability to custody and safeguard derivative investments. These same benefits are made
available to Altair's principals and employees. The benefits to Altair and its principals and
employees are not a material factor in determining which brokers to recommend; rather, the
primary considerations are the services provided to the client. Altair does not expect that clients
will pay commissions to the custodian-affiliated brokers we recommend that are higher than
those obtainable from other brokers for comparable client services, although there can be no
assurance that clients will pay the lowest possible commissions available.
While we do not receive cash compensation or research (typically referred to as “soft dollar”
payments) from custodian-affiliated brokers we recommend to clients, we receive other services
from these entities, including:
Complimentary admittance for our employees to attend seminars and conferences (though
we do not receive travel or reimbursement for other expenses related to attending these
conferences);
Practice management consulting services paid for by the custodian (such as consulting firms
which track client experiences); and
Practice management communications generally available to advisers with clients on the
custodian’s platform.
On occasion, Altair has received (and in the future may receive) additional payments from such
custodians solely to reimburse Altair for the costs that Altair has incurred (or will incur) directly
resulting from the custodian’s internal systems changes or updates that directly impacted (or will
impact) Altair’s systems and its ability to service its client(s) that have selected that custodian.
Such one-time payments do not impact Altair’s analyses as to whether to recommend (or not)
that a client retain that custodian.
Altair will consider allocating eligible third-party private equity investment funds to its proprietary
private fund first. If the Investment Committee determines the limited investment opportunity is
not suitable for its proprietary private funds or if supply remains after Altair allocates the limited
investment opportunity to its proprietary private funds, Altair will make the opportunity available
to eligible clients through a randomized process to determine which eligible clients will receive
allocations of the limited investment opportunity.
Altair maintains a policy to allocate these limited investment opportunities without regard to
factors that solely benefit Altair, such as future proprietary private fund’s performance-based fee
arrangements described within Item 6.
In the event Altair identifies a transaction error has occurred in a client’s account, Altair will work
with the custodian promptly to correct, limit or mitigate the effect of the transaction error, with
the objective of making the client whole. If necessary, Altair will reimburse clients following a
transaction error committed by Altair, often by reducing or waiving future fees to be paid to
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Altair. Altair will pay former clients any remaining balance due upon termination of the client
relationship. At other times, Altair will work with the client’s custodian to adjust the trades to the
correct transaction error in the client account, with Altair settling any difference with the
custodian outside of the client’s account.
Altair generally considers a “transaction error” to be the execution of a trade or transaction by
Altair on behalf of a client on terms other than those intended by Altair or the client, as
applicable. Altair faces an inherent conflict in addressing transaction errors, as transaction
errors are often detected by Altair personnel who have an inherent incentive to mitigate such
transaction errors in Altair’s favor, to the detriment of the clients. To address this risk, Altair logs
and Altair management reviews all transaction errors. Altair believes these controls, along with
Altair’s periodic employee training program, function to mitigate these inherent risks.
ITEM 13 – REVIEW OF ACCOUNTS
Directors of Altair are responsible for reviewing the strategic investment plan, the client's overall
financial situation and the performance of the client's portfolio. The number of clients assigned
to each Director and Managing Director varies according to the complexities of each individual
client account.
Accounts are reviewed on a quarterly basis, which includes the delivery of written performance
reports to clients. These reports provide a review of the client's investment portfolio, including a
review of asset allocation, performance comparisons for the client's investment managers and
commentary on general market conditions.
Generally, each account is reviewed with the client at least semi-annually.
Altair, along with the Altair Funds’ third-party service providers that provide compliance,
administration and accounting services, actively monitors transactions and holdings for
compliance with the Altair Funds’ investment restrictions.
Altair’s Investment Committee monitors the proprietary private fund on an ongoing basis.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Other than as described in Item 5, the sharing of advisory board compensation with employees
as described in Item 10, and the limited benefits received from client custodians disclosed in
Item 12 above, Altair does not receive cash compensation or other economic benefits in
connection with providing advice to clients.
We maintain relationships with various third parties (both individuals and entities such as
attorneys or accountants), and we at times receive referrals from these third parties. We also
periodically refer clients to other service providers when we believe a service provider would
add value to the client and/or when a client requests such a referral. We have no compensation
arrangement in place with these third parties. We at times provide relatively small gifts to the
individual or entity as a sign of appreciation (such as a meal, gift certificate or a bottle of wine)
for an introduction made to us.
We typically entertain or are entertained by these third parties as a natural extension of our
ongoing business relationship. Any level of entertainment we provide or receive is designed to
foster our broader relationship with the individual or entity, and not to compensate others for
entrusting us with referrals made. We want to make you aware of the inherent conflict of interest
15
that exists from our relationship with these individuals or entities, as these introductions are
generally borne out of a larger relationship.
As disclosed in the Altair Funds’ offering documents, the Altair Funds pay fees to broker-dealers
and other financial institutions to include the Altair Funds on their distribution platforms.
Rialta, the General Partner to Altair’s proprietary private funds, receives a fee for general
partner services it provides, including administration of the proprietary private fund, oversight of
service providers, and the management of books and records. The fee provides payment for
services rendered, at cost, based on the salaries and benefits of personnel responsible for the
proprietary private fund’s operations and books and records. The proprietary private fund’s
Confidential Private Placement Memorandum describes this fee.
Altair employees are compensated by the firm based on new business attributed to the
employee’s efforts. Clients do not pay additional fees to compensate the Altair employee for
his/her new business efforts; rather, this compensation is addressed through Altair’s general
operating budget.
All professionals (including investment and research professionals) are paid a base salary and a
bonus based on firm profitability. Senior Client Service team members are eligible to earn an
additional one-time bonus based on the size of new client assets reflecting their role in securing
a new client relationship. All employees are eligible to receive a bonus for an introduction to a
client, which is calculated as a percentage of the first year of fees generated. Research employees
are paid a bonus based on the long-term performance of funds and managers used by Altair
clients. These compensation arrangements incent our employees to increase our assets under
management which thereby increases our revenue generated. We feel our policies and
procedures designed to ensure all clients are treated fairly help to mitigate this inherent conflict.
Also, all client portfolios are managed following a team approach, with no single employee
responsible for any individual client’s portfolio.
ITEM 15 – CUSTODY
Clients receive statements at least semi-annually from the broker dealer, bank or other qualified
custodian that holds and maintains each client’s investment assets. Altair urges clients to
carefully review and compare these custodial records and statements to the reports that we
provide. Our reports will at times vary from custodial statements based on accounting
procedures, reporting dates, trade/settlement dates or valuation methodologies of certain
securities.
Altair deducts advisory fees directly from clients’ accounts held at custodians and maintains
constructive custody over some accounts of its clients since it can access their custodial
accounts (either directly or indirectly via a third-party vendor) to perform services requested by
the clients. Subject to approval by Altair’s Board of Managers and Compliance Committee, Altair
also permits employees to serve as a trustee or similar role over certain client accounts. Finally,
Altair has access to some clients’ third-party accounts. These arrangements result in Altair
having custody over those accounts. Altair maintains strict controls for any account over which it
believes it has custody, including limiting access to those individuals who are required to have
such access to perform their jobs, active oversight by Altair management and engagement of an
independent accountant to perform routine audits of the accounts.
Altair owners will serve as trustee over other Altair owner’s personal accounts. Some of these
Altair owners’ accounts are managed by Altair.
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The Altair Funds’ assets are maintained with a qualified custodian, as disclosed in each Altair
Fund’s prospectus.
Altair’s wholly owned affiliate, Rialta, serves as the General Partner of Altair’s proprietary private
fund. This results in Altair having custody of the proprietary private fund’s assets. An
independent accountant registered with the Public Company Accounting Oversight Board audits
the proprietary private fund. Altair will send copies of the audited financial statements to the
proprietary private fund’s investors within 180 days of the fiscal year end.
ITEM 16 – INVESTMENT DISCRETION
At the inception of the client engagement, Altair documents its discretionary authority in a
written engagement contract for those clients who choose to give Altair investment discretion.
Altair is directly responsible for making investment decisions on behalf of discretionary clients
following an overall strategy documented in a written Investment Policy Statement, signed by
the client, that includes investment guidelines and restrictions. In all cases, however, such
discretion is exercised in a manner consistent with the stated investment objectives for the
particular client account.
ITEM 17 – VOTING CLIENT SECURITIES
Altair does not vote proxies for securities on behalf of our clients, but third-party investment
managers will vote proxies for client accounts as agreed upon between the third-party
investment manager and client. With respect to the Altair Funds, each Sub-Adviser is authorized
to vote proxies for securities on behalf of the Altair Funds, subject to the Altair Funds’ proxy
voting policies.
ITEM 18 – FINANCIAL INFORMATION
Altair has no known financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
ITEM 19 – OTHER INFORMATION
DUAL ROLES
Altair’s Chief Compliance Officer, Rebekah Kohmescher, also serves as Altair’s Chief Executive
Officer. Her other firm responsibilities will at times create an inherent conflict with Ms.
Kohmescher’s compliance responsibilities. Altair management is aware of such inherent
conflicts, and strives to maintain a strong compliance culture combined with appropriate
processes and controls designed to ensure Ms. Kohmescher’s firm responsibilities do not
impact her obligations as Altair’s Chief Compliance Officer.
LEGAL LITIGATION
Altair periodically receives notifications of pending class action or similar legal litigation involving
securities held within client accounts. As a matter of policy, we do not elect to participate in such
lawsuits or other settlements on behalf of our clients; rather, we provide an option for the client
to utilize a third party (Chicago Clearing Corporation) to investigate and make elections on the
clients’ behalf. The client makes a determination of whether to utilize Chicago Clearing
Corporation within Altair’s engagement letter, which discloses that Chicago Clearing
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Corporation keep a percentage of the recovered proceeds as compensation. Altair is not
responsible for class action or similar legal litigation matters related to the Altair Funds.
DISASTER RECOVERY
Altair maintains a Disaster Recovery Plan designed to reasonably ensure the essential business
functions of Altair are promptly restored in the event of a disaster event. While Altair strives to
establish and maintain comprehensive processes supporting this Disaster Recovery Plan, Altair
cannot ensure it will be able to continue business operations during every disaster event, given
the unknown nature and scope of future events. Such events could include acts of war,
terrorism, accidents and sabotage. If there were to be an actual disaster event, Altair will make
reasonable attempts to notify clients of the impact of the event on Altair and its clients.
CYBERSECURITY
Information security concerns impact every user of the internet, and investment advisers such
as Altair are no exception. Altair recognizes the importance of protecting clients' personal
information as well as the confidential and proprietary information of Altair and its employees,
and has established a Cybersecurity Program designed to protect this information. The
Cybersecurity Program incorporates routine employee education, identification and monitoring
of information security risks, the use of third-party vendors to combat such risks and an
established Incident Response Plan. While Altair employs resources (both internal and external)
it deems reasonable relative to its size and complexity to protect this information, Altair cannot
guarantee the protection of all such information, nor can Altair assure against all related losses,
in consideration of the real and evolving cybersecurity risks in existence (now or in the future).
Altair believes clearly communicated information represents a critical control to identifying and
managing cybersecurity risks, and has encouraged employees to communicate early and often
regarding any potential cybersecurity risk. As such, Altair encourages all clients to communicate
any information security risk or breach they have detected to their Altair consultant immediately.
IDENTITY THEFT
Altair recognizes the inherent risk all individuals face with respect to identity theft. Altair has
created an Identity Theft Identification Program, primarily designed to help employees identify
potential red flags indicating a client’s identity may have been stolen. In addition to identifying
potential red flags, this Identity Theft Identification Program outlines the actions employees and
Altair will take in the event they believe a client’s identity may have been stolen. Altair requests
any client who suspects his/her identity has been compromised to immediately notify their Altair
consultant, thereby permitting Altair to consider implementing additional controls around the
client’s account.
DIMINISHED CAPACITY
We are mindful that cognitive capacities can diminish over time, though not always as a result of
age. We take our fiduciary responsibilities to our clients seriously, and have implemented policies
to help guide our employees when they suspect a client is experiencing diminished capacity, as
these clients could through no fault of their own be susceptible to making decisions which are not
in their long-term best interests. As generally requested by the custodian, we encourage all clients
to name a trusted contact with whom we could speak if we identify a potential diminished capacity
concern.
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Brochure Supplement
Part 2B of Form ADV
Steven B. Weinstein
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Steven B. Weinstein that supplements the
Altair Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst® (CFA®), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst®, (CAIA®), Certified Public Accountant
(CPA)), as well as meet certain ongoing requirements, including participation in continuing
education programs and experience in providing personal financial planning and investment
advisory services.
TO RECEIVE THE CFA® DESIGNATION, CANDIDATES MUST ATTAIN THE FOLLOWING:
1. Have at least four years of professional investment experience.
2. Pass three rigorous six-hour exams
3. Commit to abiding by CFA Institute's Code of Ethics and Standards of Professional Conduct.
For more information on the CFA® designation, please visit
http://cfainstitute.org/ethics/Documents/pw_sec.pdf
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer, Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher, (312) 429-3035.
Steven B. Weinstein, CFA, CFP®
CHAIRMAN
312-429-3013 sweinstein@altairadvisers.com
Steven B. Weinstein founded the independent wealth advisory firm of Altair Advisers in
June of 2002, and served as President and Chief Investment Officer until being named to the
new position of Chairman in January 2018. Steve has been counseling wealthy families,
business owners, and senior executives on their investment, tax, retirement and estate
planning matters for over 40 years. In his role as Chairman, Steve serves clients as well as
provides strategic guidance and senior advisory leadership on Altair’s Board and Investment
Committee.
Prior to starting Altair, Steve spent nearly two decades with Arthur Andersen, where he was
instrumental in designing, establishing and growing its Investment Advisory Services and
Personal Financial Planning practices, both in Chicago and nationwide.
As an industry leader, Steve has served as a member of the Board of Governors of the Certified
Financial Planner Board of Standards and the CCH Financial and Estate Planning Advisory
Board. He is currently active in the CFA Society of Chicago and the Chicago Estate Planning
Council. He is a CFA charterholder and a CERTIFIED FINANCIAL PLANNER™ certificant. He
is a member of the Illinois and California bars.
Steve graduated with Distinction in Political Science and Communication from Stanford
University in 1974, where he was elected a member of Phi Beta Kappa, and earned both his
MBA and JD degrees, with Distinction, from Northwestern University in 1978.
Steve is active on the Gift Planning Advisory Committee of the Art Institute of Chicago, the
Northwestern Memorial Foundation’s Professional Council for Philanthropy, and the Pete
Henderson Society of the Kellogg Alumni Council. He also serves as a board member of the
Ravinia Festival, the Chicago Youth Centers and the Chicago Chapter of the American Jewish
Committee and is a member of The Economic Club of Chicago.
EDUCATION
PROFESSIONALDESIGNATIONS
YEAR OF
BIRTH
BUSINESS
BACKGROUND
05/27/1952
2002 - to date,
Altair Advisers LLC
1983 - 2002,
Arthur Andersen LLP
BA, Stanford University,
Stanford, CA
JD/MBA, Northwestern
University, Evanston &
Chicago, IL
2002 – NASD Series 7
1996 – Chartered Financial Analyst®
1995 – NASD Series 2
1995 – NASD Series 63
1994 – NASD Series 65
1989 – CERTIFIED FINANCIAL
PLANNER™
1979 – California Bar
1978 – Illinois Bar
Brochure Supplement
Part 2B of Form ADV
Rebekah L. Kohmescher
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Rebekah L. Kohmescher that
supplements the Altair Advisers LLC brochure. You should have received a copy of that
brochure. Please contact info@altairadvisers.com or (312) 429-3000 if you did not receive Altair
Advisers LLC brochure or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst (CFA), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst, (CAIA), Certified Public Accountant (CPA)),
as well as meet certain ongoing requirements, including participation in continuing education
programs and experience in providing personal financial planning and investment advisory
services.
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
TO USE THE CPA DESIGNATION IN ILLINOIS, PROFESSIONALS MUST DO THE
FOLLOWING:
1. Hold an Illinois CPA certificate issues by the Illinois Board of Examiners which requires
undergraduate hours of accounting as well as completion of a rigorous exam
2. At least one year of relevant experience
3. Those not currently practicing must hold a Registration license issued by Illinois Department of
Financial and Professional Regulation which much be renewed every three years. Registration is
renewable every three years
For more information on the CPA designation, please visit
http://www.aicpa.org/InterestAreas/PersonalFinancialPlanning/Membership/DownloadableDocuments/ADV%20
Part%202B%20Brochure%20Supplement.docx
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer, Jason Laurie (312) 429-3030 and our Board of Managers
chaired by Steven B. Weinstein (312) 429-3013.
Rebekah L. Kohmescher, CFP®, CPA
CHIEF EXECUTIVE OFFICER & CHIEF COMPLIANCE OFFICER
312-429-3035 rkohmescher@altairadvisers.com
A founding partner of Altair at just 25 years old, Rebekah ‘Beka’ accepted the newly created
position of Chief Executive Officer (CEO) on January 1, 2018, with responsibility for the overall
management of the firm. Prior to becoming CEO, Beka spent her first eight years in a client
service role, then shifted to an operational role, serving as Altair’s Chief Operating Officer
(COO) since 2011. Under her leadership, the firm has redesigned entire aspects of the
investment reporting processes, expanded online accessibility to account information for
clients, and restructured internal workflows to best meet client needs and improve internal
efficiencies.
Additionally, Beka serves as the head of compliance for the firm, assisting with creating policies
and filing annual reports with the SEC. She is also the direct supervisor for managers of the
consulting, investment operation, client reporting and office administration teams.
Before Altair’s formation, Beka was a consultant in Arthur Andersen’s Private Client Services
practice.
Beyond her work at Altair, Beka has been a mentor to young women pursuing finance and
accounting majors and has been an industry advocate for bringing more women into the
financial advisory field.
Beka is on the Board of Directors and the Finance Committee of Community Health, a free clinic that
provides high-quality health care to more than 9,000 uninsured people annually. She was the 2015
recipient of Community Health’s Visionary Award, an annual honor that recognizes those that exemplify
the importance of making quality health care available to Chicago’s most underserved residents. She
also serves on the board of governors for the Investment Adviser Association, which provides advocacy
for the RIA industry. She serves on the Senior Advisory Board of the L.E.A.D.S. (Leadership,
Empowerment, Action, Development and Service) program at Benedictine University, is a member of
The Chicago Network and mentor through its Executive Women’s Mentorship Initiative program and
serves on the Advisory Board and Finance Committee of the St. Benedict Preparatory School on the
north side of Chicago.
EDUCATION
YEAR OF
BIRTH
BUSINESS
BACKGROUND
PROFESSIONAL
DESIGNATIONS
10/29/1976
BA, Xavier
University,
Cincinnati, OH
2005 – CERTIFIED FINANCIAL
PLANNER™
2002 – NASD Series 65
1999 – Certified Public Accountant
2002 to date, Altair Advisers
LLC
1999 - 2002, Arthur Andersen
LLP
Brochure Supplement
Part 2B of Form ADV
Jason M. Laurie
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Jason M. Laurie that supplements the
Altair Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst® (CFA®), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst®, (CAIA®), Certified Public Accountant
(CPA)), as well as meet certain ongoing requirements, including participation in continuing
education programs and experience in providing personal financial planning and investment
advisory services.
TO RECEIVE THE CFA® DESIGNATION, CANDIDATES MUST ATTAIN THE FOLLOWING:
1. Have at least four years of professional investment experience.
2. Pass three rigorous six-hour exams
3. Commit to abiding by CFA Institute's Code of Ethics and Standards of Professional Conduct.
For more information on the CFA® designation, please visit
https://www.cfainstitute.org/ethics/Documents/pw_sec.pdf
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Board of Managers chaired by Steven B. Weinstein (312) 429-3013 and our Chief
Executive Officer, Rebekah Kohmescher (312) 429-3035.
Jason M. Laurie, CFA, CFP®
MANAGING DIRECTOR & CHIEF INVESTMENT OFFICER
jlaurie@altairadvisers.com
312-429-3030
A founding partner and managing director, Jason has chaired Altair’s Investment Committee
since 2011 and succeeded Steve Weinstein as the firm’s Chief Investment Officer (CIO) in
January 2018. As CIO, he is responsible for leading the strategic direction of the firm’s
investment advice in collaboration with Altair’s Research Team. Jason also serves as the lead
consultant on numerous client engagements.
Jason helps clients achieve their long-term financial goals through the integration of investment
management and financial planning. He works in close collaboration with his clients’ broader
team of professional advisers to create customized investment strategies that maximize wealth
preservation while also taking advantage of wealth creation opportunities. With 20 years of
client portfolio experience, he is particularly skilled at helping clients navigate transitional life
events such as the sale of a business, the distribution of a trust, retirement or divorce.
Jason has lectured before several professional groups including the World Presidents’
Organization and is quoted in both the local and national media.
Prior to forming Altair, Jason was a manager in Arthur Andersen’s Private Client Services
practice. He oversaw engagements that coordinated investment advisory services with other
wealth planning strategies. In addition to his work with high-net-worth individuals, Jason
developed and conducted retirement investment planning seminars for employees of leading
Chicago corporations. Prior to Andersen, Jason worked at the investment research firm
Ibbotson Associates where he was in the group that developed and maintained asset allocation
software.
Jason is a CFA charterholder and a CERTIFIED FINANCIAL PLANNER™ certificant. He is a
member of the CFA Society of Chicago. Jason graduated cum laude from the University of
Notre Dame, with a BBA degree in finance and concentration in computer applications.
EDUCATION
BUSINESS BACKGROUND
YEAR OF
BIRTH
PROFESSIONAL
DESIGNATIONS
4/28/1974
BBA, University of
Notre Dame,
SouthBend, IN
2002 to date, Altair Advisers LLC
1997 - 2002, Arthur Andersen LLP
1996 - 1997, Ibbotson
Associates
2006 – Certified Financial
Planner™
2000 – Chartered Financial
Analyst®
1998 – NASD Series 65
Brochure Supplement
Part 2B of Form ADV
Bryan R. Malis
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Bryan R. Malis that supplements the Altair
Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst® (CFA®), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst®, (CAIA®), Certified Public Accountant
(CPA)), as well as meet certain ongoing requirements, including participation in continuing
education programs and experience in providing personal financial planning and investment
advisory services.
TO RECEIVE THE CFA® DESIGNATION, CANDIDATES MUST ATTAIN THE FOLLOWING:
1. Have at least four years of professional investment experience.
2. Pass three rigorous six-hour exams
3. Commit to abiding by CFA Institute's Code of Ethics and Standards of Professional Conduct.
For more information on the CFA® designation, please visit
http://cfainstitute.org/ethics/Documents/pw_sec.pdf
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher (312) 429-3035.
Bryan R. Malis, CFA, CFP®
MANAGING DIRECTOR
312-429-3024
bmalis@altairadvisers.com
Bryan is a founding partner and Managing Director of Altair Advisers. For thirty years, he has
worked with high-net-worth clients to provide financial planning, investment advice and fiscal
peace of mind to his clients, which include current and former business owners, corporate
executives, professionals and other people of wealth. Drawing upon his years of technical
knowledge and advisory experience, Bryan is particularly skilled at guiding his clients through a
complex maze of alternatives to provide practical solutions that fit each client’s particular needs,
empowering his clients to make better decisions about their wealth.
In addition to his work with clients, Bryan has been a leader within the firm since its founding,
having served for over sixteen years on Altair’s Board of Managers, which has responsibility for
oversight of firm policy, strategy, and operations. He also serves on Altair’s Investment
Committee, the central decision-making body which approves recommended managers and
determines tactical allocation changes.
Prior to founding Altair, Bryan held a senior position in the investment consulting practice Arthur
Andersen, which he joined after several years in the financial counseling and investment
consulting groups of Deloitte and Touche. His earlier experience came while at Mesirow
Financial and Takaki Close & Associates.
Bryan is a CFA charterholder and a CERTIFIED FINANCIAL PLANNER™ certificant. He is a
member of the CFA Society of Chicago. He is also a member Chicago Estate Planning Council
where he served a long tenure on its board concluding as its president. Bryan received his
bachelor’s degree in accountancy and finance from the University of Illinois at Urbana-
Champaign.
Bryan’s philanthropic involvement includes a long tenure on the Board of Trustees of the Kohl
Children’s Museum of Greater Chicago, where he is Treasurer, a member of the Executive
Committee and Chairman of the Finance Committee.
EDUCATION
BUSINESS BACKGROUND
YEAR OF
BIRTH
PROFESSIONAL
DESIGNATIONS
05/24/1964
BS, University of
Illinois, Urbana, IL
2004 – Chartered Financial Analyst®
1997 – NASD Series 65
1991, 1997 – NASD Series 63
1990 – CERTIFIED FINANCIAL
PLANNER™
1988 – NASD Series 7
2002 to date, Altair Advisers LLC
1999 - 2002, Arthur Andersen LLP
1995 - 1999, Deloitte & Touche LLP
1993 - 1995, Takaki Close &
Associates, Ltd.
1988 - 1993, Mesirow Financial
Corp.
Brochure Supplement
Part 2B of Form ADV
Michael J. Murray
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Michael J. Murray that supplements the
Altair Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst® (CFA®), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst®, (CAIA®), Certified Public Accountant
(CPA)), as well as meet certain ongoing requirements, including participation in continuing
education programs and experience in providing personal financial planning and investment
advisory services.
TO RECEIVE THE CFA® DESIGNATION, CANDIDATES MUST ATTAIN THE FOLLOWING:
1. Have at least four years of professional investment experience.
2. Pass three rigorous six-hour exams
3. Commit to abiding by CFA Institute's Code of Ethics and Standards of Professional Conduct.
For more information on the CFA® designation, please visit
http://cfainstitute.org/ethics/Documents/pw_sec.pdf
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
4. Pass the comprehensive CFP® Certification Examination
5. Pass CFP Board's Fitness Standards for Candidates and Registrants
6. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
7. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
8. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
TO USE THE CAIA® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass a self-directed, comprehensive course of study on risk-return attributes of institutional
quality alternative assets and
2. Complete both the Level I and Level II CAIA® examinations.
3. Meet the prerequisites of at least one year of professional experience and a U.S. bachelor's
degree or its equivalent, or four years of professional experience. Professional experience
includes full-time employment in a professional capacity within the regulatory, banking, financial,
or related fields.
For more information on the CAIA® designation, please visit
http://caia.org/media-center/news/caia-designation-secform-adv-brochure-supplement
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher (312) 429-3035.
Michael J. Murray, CFA, CFP®, CAIA®
MANAGING DIRECTOR
312-429-3007 mmurray@altairadvisers.com
Michael J. Murray helps clients achieve their long-term financial goals through investment
advice that is integrated with all other aspects of their financial planning. He works in close
collaboration with his clients’ broader team of professional advisers to create customized
investment strategies that maximize wealth preservation while also taking advantage of wealth
creation opportunities.
Mike enjoys finding creative solutions to complex financial situations. With more than 20 years
of client portfolio experience, he is particularly skilled at helping clients navigate and make
decisions during transitional life events such as the sale of a business, the distribution of a trust,
retirement or divorce.
While he works with a broad array of clients, Mike’s personal experience as a business owner
and firm leader gives him a unique ability to relate to the needs of entrepreneurs and c-suite
executives. Prior to becoming a founding partner of Altair Advisers in 2002, he was a senior
consultant in the Private Client Services practice at Arthur Andersen’s Chicago office. In his
tenure there, Mike was assigned to Arthur Andersen’s London office to help lead the launch of
the firm’s investment consulting practice for the United Kingdom.
Mike was elected to serve on Altair’s Board of Managers where he provides operational
leadership for the firm.
Mike holds a BBA in accounting and finance from the University of Wisconsin – Madison in
addition to multiple professional designations. He is a member of the CFA Society of Chicago
and the University of Wisconsin School of Business Dean’s Advisory Board. He is an active
board member of Summer of a Lifetime, a Noble Network of Charter Schools Program that
enables high achieving, low-income students from across Chicago to participate in university-
sponsored academic enrichment programs.
EDUCATION
PROFESSIONAL DESIGNATIONS
YEAR OF
BIRTH
BUSINESS
BACKGROUND
10/31/1974
BBA, University of
Wisconsin, Madison,
WI
2002 to date, Altair Advisers
LLC
1998 - 2002, Arthur Andersen
LLP
2009 – Chartered Alternative Investment
Analyst®
2005 – CERTIFIED FINANCIAL PLANNER™
2004 – Chartered Financial Analyst®
2000 – NASD Series 65
Brochure Supplement
Part 2B of Form ADV
Donald J. Sorota
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Donald J. Sorota that supplements the
Altair Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst® (CFA®), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst®, (CAIA®), Certified Public Accountant
(CPA)), as well as meet certain ongoing requirements, including participation in continuing
education programs and experience in providing personal financial planning and investment
advisory services.
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which
puts clients' interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients
should be able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours
on the Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
TO USE THE CPA DESIGNATION IN ILLINOIS, PROFESSIONALS MUST DO THE FOLLOWING:
6. Hold an Illinois CPA certificate issues by the Illinois Board of Examiners which requires
undergraduate hours of accounting as well as completion of a rigorous exam
7. At least one year of relevant experience
8. Those not currently practicing must hold a Registration license issued by Illinois Department of
Financial and Professional Regulation which must be renewed every three years. Registration is
renewable every three years.
For more information on the CPA designation, please visit
http://www.aicpa.org/InterestAreas/PersonalFinancialPlanning/Membership/DownloadableDocuments/ADV%20
Part%202B%20Brochure%20Supplement.docx
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher (312) 429-3035.
Donald J. Sorota, CFP®, CPA
MANAGING DIRECTOR
312-429-3040 dsorota@altairadvisers.com
Donald J. Sorota has extensive experience in a broad range of wealth management areas.
Since 1996, Don has been providing investment counsel to high-net-worth individuals, corporate
executives and family business owners. In consulting clients on their investment portfolios, Don
takes into consideration their retirement, tax and estate planning goals. Don is exceptionally
skilled at helping clients with transitional life events such as the sale of a business, retirement,
divorce or the distribution of a trust.
As a Founding Partner of Altair Advisers, Don serves as the lead consultant on client
engagements. Don had the additional responsibility of serving as Altair’s Finance Director for
our first three years due to his tax expertise as a CPA and outstanding analytical skills. He is
also a member of Altair’s Investment Committee, the central decision-making body which sets
investment direction, approves recommended managers and determines tactical allocation
changes.
Prior to forming Altair, Don was a manager in Arthur Andersen’s Private Client Services
practice, serving as an investment counselor and financial planner.
Don graduated with honors in Accounting from DePaul University and is a member of DePaul
University's Ledger & Quill Board.
EDUCATION
YEAR OF
BIRTH
BUSINESS
BACKGROUND
PROFESSIONAL
DESIGNATIONS
08/02/1974
BA, DePaul University,
Chicago, IL
2002 to date,
Altair Advisers LLC
1996 -2002,
Arthur Andersen LLP
2003 – CERTIFIED FINANCIAL
PLANNER™
1998 – NASD Series 65
Certified Public Accountant
Brochure Supplement
Part 2B of Form ADV
Timothy G. French
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Timothy G. French that supplements the
Altair Advisers LLC brochure. You should have received a copy of that brochure. Please contact
info@altairadvisers.com or (312) 429-3000 if you did not receive Altair Advisers LLC brochure
or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst (CFA), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst, (CAIA), Certified Public Accountant (CPA)),
as well as meet certain ongoing requirements, including participation in continuing education
programs and experience in providing personal financial planning and investment advisory
services.
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
TO USE THE CPA DESIGNATION IN ILLINOIS, PROFESSIONALS MUST DO THE FOLLOWING:
:
1. Hold an Illinois CPA certificate issues by the Illinois Board of Examiners which requires
undergraduate hours of accounting as well as completion of a rigorous exam
2. At least one year of relevant experience
3. Those not currently practicing must hold a Registration license issued by Illinois Department of
Financial and Professional Regulation which much be renewed every three years. Registration is
renewable every three years
For more information on the CPA designation, please visit
http://www.aicpa.org/InterestAreas/PersonalFinancialPlanning/Membership/DownloadableDocuments/ADV%20
Part%202B%20Brochure%20Supplement.docx
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher (312) 429-3035.
Timothy G. French, CFP®, CPA
MANAGING DIRECTOR & CHIEF CLIENT OFFICER
312-429-3018 tfrench@altairadvisers.com
Timothy G. French provides investment advice to wealthy individuals, families and foundations. In
addition to his client-facing responsibilities, Tim serves as Altair’s Chief Client Officer. In this role, Tim
supervises Altair’s Client Service professionals, and he works with the firm’s Chief Executive Officer and
Chief Investment Officer to ensure decisions made across the firm are in clients’ best interests.
Tim has extensive experience in the areas of investment advisory, personal financial planning,
individual, trust, estate and gift taxation, and estate planning. Prior to joining Altair, Tim was a
manager in the Personal Financial Services group of PwC.
Tim is a Certified Public Accountant with a Personal Financial Specialist
(PFS™) designation and a CERTIFIED FINANCIAL PLANNER ™ certificant. Tim received
his bachelor’s degree in accountancy and master’s degree in accountancy (taxation) from
the University of Illinois, where he graduated with highest honors.
Outside of Altair, Tim serves on the finance committee at his church and his children’s
school and on the development committee at a full-scholarship elementary school in
Chicago’s Austin neighborhood.
.
EDUCATION
BUSINESS BACKGROUND
YEAR
OF BIRTH
PROFESSIONAL
DESIGNATIONS
03/03/1983
2013 to date, Altair Advisers LLC
2006-2013,
PricewaterhouseCoopers
2009 – CERTIFIED FINANCIAL
PLANNER™
2006 – Certified Public Accountant
BS, MS,
Accountancy,
University of Illinois
Brochure Supplement
Part 2B of Form ADV
Rachael Halstuk Mangoubi
Altair Advisers LLC
225 W. Washington Street, Suite 2400
Chicago, Illinois 60606
312.429.3000
www.altairadvisers.com
10/31/2025
This brochure supplement provides information about Rachael Halstuk Mangoubi that
supplements the Altair Advisers LLC brochure. You should have received a copy of that
brochure. Please contact info@altairadvisers.com or (312) 429-3000 if you did not receive Altair
Advisers LLC brochure or if you have any questions about the contents of this supplement.
Item 2 - Educational Background and Business Experience
In general, investment advice will only be provided by principals and senior employees of Altair
who have a minimum of a college education combined with either an advanced degree and/or
financial designation (i.e., Chartered Financial Analyst (CFA), Certified Financial Planner™
(CFP®), Chartered Alternative Investment Analyst, (CAIA), Certified Public Accountant (CPA)),
as well as meet certain ongoing requirements, including participation in continuing education
programs and experience in providing personal financial planning and investment advisory
services.
TO USE THE CFP® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Pass the comprehensive CFP® Certification Examination
2. Pass CFP Board's Fitness Standards for Candidates and Registrants
3. Agree to abide by CFP Board's Code of Ethics and Professional Responsibility which puts clients'
interests first
4. Comply with the Financial Planning Practice Standards which spell out what clients should be
able to reasonably expect from the financial planning engagement.
5. Complete 30 hours of continuing education hours every two years, including two hours on the
Code of Ethics and other parts of the Standards of Professional Conduct
For more information on the CFP® designation, please visit
http://www.cfp.net/certificants/ADVexplanation.asp
TO USE THE CPWA® DESIGNATION, CERTIFICANTS MUST DO THE FOLLOWING:
1. Meet initial and on-going experience, ethical, education, and examination requirements for
the professional designation, which is centered on private wealth management topics and
strategies for high-net-worth clients.
2. Bachelor’s degree from an accredited college or university or one of the following
designations or licenses: CIMA®, CIMC ®, CFA®, CFP®, ChFC®, or CPA license; have an
acceptable regulatory history and five years of experience in financial services or delivering
services to high-net-worth clients.
3. Report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the
certification. The designation is administered through the Investments & Wealth Institute.
For more information on the CPWA® designation, please visit
https://investmentsandwealth.org/certifications/
Item 3 – Disciplinary Information
No information is applicable to this Item.
Item 4 – Other Business Activities
No information is applicable to this Item.
Item 5 – Additional Compensation
The supervised person listed in this supplement participates in a bonus plan where they are
compensated based on the amount of additional assets and revenue that their efforts generate
for Altair.
Item 6 – Supervision
The supervised person listed in this supplement delivers advice to clients under the supervision
of our Chief Investment Officer Jason Laurie (312) 429-3030 and our Chief Executive Officer,
Rebekah Kohmescher (312) 429-3035.
Rachael Halstuk Mangoubi, CFP®, CPWA®
MANAGING DIRECTOR
312-429-3022 rmangoubi@altairadvisers.com
Rachael Halstuk Mangoubi works closely with her clients to identify their wealth goals and
develop customized plans for meeting their long-term objectives as well as current lifestyle
needs. Her ongoing monitoring and guidance enables clients to effectively evaluate their full
financial picture and make more confident wealth decisions.
Rachael has been in the advisory industry since 2003. Prior to joining Altair, she provided
wealth planning services to families and individuals at Mesirow Financial. She began her career
in the investment banking field, providing mergers and acquisitions advice to family-owned,
private-equity owned and public companies at Mesirow Financial and Raymond James.
Rachael’s experience working with executives of public and private companies in both mergers
and acquisitions and wealth management gives her a deep knowledge of the complexities that
her clients face. Rachael’s colleagues elected her to serve on Altair’s Board of Managers,
allowing her to serve in a strategic leadership role at the firm.
Rachael is on the Board of Directors of The Alliance Française de Chicago. Rachael is a
member of the Duke Alumni Association Board of Directors, the former chair of the Duke Club
of Chicago, and the co-founder of the Duke Women’s Forum of Chicago. She holds a BA in
Mathematics and Spanish from Duke University. Rachael is a CERTIFIED FINANCIAL
professional.
PLANNER™ professional as well as a Certified Private Wealth Advisor
℠
EDUCATION
YEAR
OF BIRTH
BUSINESS
BACKGROUND
PROFESSIONAL
DESIGNATIONS
08/07/1981
BA, Mathematics and
Spanish, Duke University
2016 to date, Altair Advisers
LLC
2004-2016 Mesirow Financial
2003-2004 Raymond James
2017 – CERTIFIED PRIVATE
WEALTH ADVISOR®
2014 – CERTIFIED FINANCIAL
PLANNER™