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| Gruenstein Investments LLC
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| CRD # | 298739 |
| SEC # | 801-114355 |
| CIK # | |
| AUM | 61.5 M (2026-04-30) |
| Employees | 1 (100% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 212-410-1800 |
| Address | |
| Source | [IAPD] [Website] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (4/8/2026) [Brochure] |
|---|
Item 5. Fees and Compensation
A. The Fund pays the Firm for its advisory services. The Fund will pay to the Firm or one of its
affiliates a special profits allocation equal to ten percent of the profits of the Fund, subject to
customary “high water mark” provisions. The Fund will also pay to the Firm or one of its affiliates
an annual management fee equal to one percent of the net asset value of the Fund on a capital
account by capital account basis. Further information on the fees and profits allocations paid by
the Fund is set forth in the PPM and LPA. The Fund waives or discounts fees and profit allocations
with respect to Friends & Family and other investors.
The Firm’s basic fee for Managed Accounts is one percent per annum of the total assets under
management of the Managed Accounts. This fee has been and remains subject to negotiation,
including that the client and the Firm may agree to change the structure of the fee from an annual
management fee to a performance-based fee, and the fee may be waived in whole or in part. The
Firm anticipates that the fees that it charges Managed Account clients will vary based upon, for
example, the historical relationship between the clients and the Principal and the particular services
provided by the Firm to various clients.
B. The Firm deducts management fees from client accounts quarterly in arrears and the profits
allocation annually or upon an earlier withdrawal. Alternatively, clients may elect to receive a bill
in respect of fees incurred and payable to the Firm.
C. In addition to the compensation payable to the Firm described above, our clients pay their
own ongoing direct investment and operating expenses. The list below details some of these
expenses but does not include every possible expense clients may incur.
• investment expenses such as brokerage commissions, dealer mark-ups, option payments,
other payments due under investment contracts and arrangements, research expenses,
including interest on margin accounts and other indebtedness;
• other expenses related to the purchase, sale or transmittal of assets;
• fees and expenses charged by mutual funds or other exchange traded funds in which clients
might invest, such as management fees and transaction costs;
• banking costs, custodial fees and currency conversion costs; and
• any other expenses which we reasonably determine to be directly related to the investment
of our clients’ assets.
The Firm has agreed with certain clients that the Firm will pay select expenses otherwise
allocated to such clients. Such arrangements will continue indefinitely or for a certain period,
as determined by the Firm and each such client. As a general matter, the Firm may, but is under
no obligation to, bear certain expenses on behalf of any or all of its clients from time to time.
D. Clients do not pay any management fees or profits allocations in advance.
E. Neither the Firm nor any of its principals or employees receives any compensation for the sale
of securities or other investment products, including charges or fees from the sale of mutual funds. |
| Account Minimums and Types of Clients — Form ADV Part 2A (4/8/2026) [Brochure] |
|---|
Item 7. Types of Clients
As noted in Item 4 above, the Firm provides advice to the Fund, a pooled investment vehicle, and
various Managed Accounts of high-net worth individuals and/or their families, related estate
planning vehicles and other entities including trusts. The Principal acts as trustee for trusts for the
benefit of certain families with which the Principal has an historical relationship. In order to avoid
potential conflicts that may arise in these cases, the Firm does not accept as clients or investors in
the Fund trusts for which the Principal serves as trustee (excluding trusts for the benefit of the
Principal’s family). At this time, there are no pre- set minimum account sizes. Rather, the Principal
will determine on a case-by-case basis whether the account size is adequate.
Item 8. Method of Analysis, Investment Strategies and Risk of Loss
A. The Principal seeks to use and adapt the analytic and fact-gathering skills he developed in his
career as a lawyer, and thereby to make investment decisions based on a personal process. In
addition, the Principal has been a long-time investor on behalf of his family and, following his
legal career, the Principal has been purchasing equity securities of publicly-listed companies.
(While practicing law at his former firm, the Principal was generally prohibited from investing in
individual publicly-listed companies.) While the Principal expects to make changes in his practices
over time, he expects to use the same basic method of analysis and investment strategies that he
employed (and continues to employ) investing for his own family.
In providing advisory services to clients, the Firm aims not to be limited by any fixed philosophy
or process, but rather to formulate advice and to manage accounts in the exercise of its discretion,
on a case-by-case basis, based on the facts and circumstances that the Firm deems pertinent. While
such broad discretion will be exercised, and the Firm seeks to take advantage of opportunities that
arise, the following summarizes how the Firm generally approaches investment decision-making
at present.
The Firm’s primary focus is the selection of equity investments, principally the common shares of
publicly-listed U.S.- domiciled companies and the common shares or ADRs of foreign companies in
developed markets listed on U.S. exchanges. The Firm identifies companies it expects to have long
runways for above-average growth, intending to hold them for long periods of time, provided the
long-term thesis for a company remains favorable, in order to take advantage of compounding
growth and lower the drag of capital gains taxes on post-tax returns. The Firm invests without
regard to market capitalization or industry sectors. This means, for example, that the Firm Manager
may at some times focus the Fund’s investments in specific market caps and specific industry
sectors and may at other times invest across several different market caps and industry sectors.
The Firm may invest in large cap, mid-cap, small cap, and micro cap companies. The Firm has
authority to employ leverage but does not anticipate using such authority to carry substantial
leverage, absent unusual circumstances or the client so requesting. Similarly, the Firm has authority
to purchase or sell options or derivatives but has used such authority only in unusual circumstances.
While the Firm takes concentration into account as one factor in investment decision-making, the
Firm is not bound by specific concentration limits, except as may be agreed with Managed Account
clients, and the Fund often has concentrated positions. The degree of concentration will vary
depending on the Firm’s assessment of a wide range of factors including the opportunity set and
the risk/reward characteristics of current investments and potential investments under
consideration, and the circumstances of the client. The Firm’s portfolio will often be concentrated
in a small number of stocks. This reflects, among other things, the Firm’s strategies of focusing
on best ideas, holding investments for the long-term, and avoiding the tax and other costs of
frequent trading.
The Firm invests generally for absolute returns with a long-term time horizon on a fully-netted
basis. Thus, the Firm seeks to achieve positive returns, independent of market benchmarks, in the
long-term in real terms on a fully-netted basis—i.e., after netting for all fees, expenses and costs,
including inflation and taxes.
While the reasons for individual investments vary, the Firm generally seeks to achieve absolute,
long-term, fully-netted returns by constructing a portfolio that attempts to achieve, and balance,
three objectives:
• The first objective (“Capital Preservation”) seeks preservation of capital on a fully-netted
basis. This requires growth in the portfolio in nominal terms sufficient to compensate for
all fees, expenses and other costs, including inflation and taxes, so that the portfolio can be
sold in the long run and generate the same buying power as the capital the client originally
invested.
• The second objective (“Spending Capacity”) seeks to enable the investor to withdraw a
reasonable annual return after a period of time, without impairing capital (consistent with
the Capital Preservation objective). This Spending Capacity objective too is defined on a
long-term, fully-netted basis. Thus, this Spending Capacity objective requires growth in
nominal terms sufficient to generate annual returns in the long-term that, net of all fees,
expenses and costs of any nature (including inflation and taxes), will constitute a reasonable
return on the original investment (while preserving the buying power of the original
investment). The Spending Capacity objective does not include a requirement for specific
annual returns. The Spending Capacity objective is expected to be met, at least in part, by
... |
| Type | Form D Funds | Date | Sold | AUM |
|---|---|---|---|---|
| HF | Gruenstein Partners LP | [2018-10-30] | 13.0 M | 20.5 M |
| Filed 2025-10-06 (D/A) · Exemption 506(b) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose | ||||
| AUM Breakdown | Accounts | AUM ($M) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 0 | 0.0 |
| (b) Individuals (high net worth individuals) | 4 | 41.0 |
| (c) Banking or thrift institutions | 0 | 0.0 |
| (d) Investment companies | 0 | 0.0 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 1 | 20.5 |
| (g) Pension and profit sharing plans | 0 | 0.0 |
| (h) Charitable organizations | 0 | 0.0 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 0 | 0.0 |
| (n) Other | 0 | 0.0 |
| Total | 6 | 61.5 |
| By Discretionary | ||
| Discretionary | 5 | 60.1 |
| Non-Discretionary | 1 | 1.4 |
| Total | 6 | 61.5 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 61.5 | |
| Total | 6 | 61.5 |
| Form D Directors | Role | # Filings | # Firms | 2011 - 2026 |
|---|---|---|---|---|
| Gruenstein Investments LLC | Executive Officer | 1 | 1 | |
| Gruenstein GP LLC | Executive Officer | 1 | 1 |
| Firm Profile (Form ADV) | |
|---|---|
| Serves | Institutional, Retail |
| Fund Types | Hedge Fund |
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