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Disclosures is a website owned and operated by Whitestone & Co., LLC (“Whitestone”). By accessing the website, you agree to be bound by the Privacy Policy and Terms of Use.

Not an offer to sell securities

Whitestone and its affiliated companies are not registered broker-dealers or investment advisors and no communication from Whitestone through this website or otherwise is intended to be or should be construed as investment, tax, financial, accounting or legal advice. The information, products and investments discussed on this page, or otherwise advised by Whitestone have been prepared solely for purposes of information and should not be used or considered as an offer to sell or the invitation or solicitation of an offer to buy any product or service offered by Whitestone, including its affiliates and their directors, officers, advisors and employees. The information contained herein is not an offer to sell securities or the solicitation of an offer to purchase securities. Offers, solicitations and sales are not made in jurisdictions in which they are unlawful or prohibited.

Securities are not registered

The securities of Whitestone have not been registered under the Securities Act of 1933, as amended (the “Securities Act”), or any other applicable securities law. Whitestone’s securities have not been approved or disapproved by the U.S. Securities and Exchange Commission (the “SEC”), any other state securities commission or any other regulatory authority, nor have any of the foregoing passed upon the accuracy or adequacy of the information presented. Any representation to the contrary is a criminal offense.

The offering of Whitestone’s securities is made pursuant to an exemption from the registration requirements of the Securities Act and certain state securities laws. Whitestone, therefore, is not required to comply with the specific disclosure requirements that apply to securities sold under registration statements filed with the SEC, including the requirement to publicly file certain reports with the SEC, so there is minimal publicly available information about our business, assets, liabilities, results of operations and other information typically available regarding publicly traded securities.

Investment Company Act

Whitestone’s securities are not subject to the protections of the Investment Company Act of 1940, as amended.

Accredited investors only

Whitestone’s securities are only offered and sold to “accredited investors,” as defined under the U.S. securities laws, pursuant to Whitestone’s disclosure documents and related subscription documents for each investment. Individuals are accredited investors only if they meet certain minimum net worth or sustained annual income thresholds. Entities are accredited investors only if they hold sufficient assets or are completely owned by accredited investors. For more information on accredited investors please visit

Transfers restricted and no trading market

Transfers of Whitestone’s securities are restricted by federal and state securities laws and certain provisions of our organizational documents. There is no trading market for the shares and there can be no assurance that such a market will develop in the foreseeable future. Whitestone’s securities may not be transferred, resold or otherwise disposed of by an investor unless, in the opinion of counsel acceptable to us, registration under federal and applicable state securities laws is not required or compliance is made with the registration requirements of such laws.

This is not investment, financial, legal, or tax advice

Whitestone and its affiliated companies are not registered broker-dealers or investment advisors and no communication from Whitestone through this website or otherwise is intended to be or should be construed as investment, tax, financial, accounting or legal advice. Whitestone does not give any representation or warranty as to the accuracy, reliability, timeliness or completeness of the information, products or investments (the “Information”) discussed on this website nor as to the appropriateness of the Information for any use which any individual user may choose to make of it and accepts no responsibility for updating any part of the Information. Whitestone does not accept any liability for any error, omission or misrepresentation in relation to the Information or for any loss, damage, cost or expense (whether direct, indirect, consequential or otherwise) suffered by the individual user of this Information or any other person as a result of any use of the Website or reliance upon any information or statement of any kind contained herein. Whitestone highly encourages all potential investors to obtain financial and tax advice from licensed professionals and to conduct diligent investigation of the Information and material provided by Whitestone before making any decision to invest in any Whitestone securities.

Investments involve various risks

An investment in Whitestone’s securities involves various risks. Only investors who can bear this type of economic risk for an indefinite period of time; and, the risk of loss of their entire investment should invest in Whitestone’s securities. See the section entitled “Potential Risk Factors” in the Private Placement Memorandum of each investment for detailed risk disclosures.

No guarantee of future performance

Past performance is not a guarantee of future performance. The current and future performance of any Whitestone securities may be lower or higher than the past performance.

Anti-money laundering requirements

The USA Patriot Act requires all financial institutions to obtain, verify and record information that identifies each person who invests as a way of assisting the government in fighting the funding of terrorism and money laundering activities.

Whitestone and its affiliates have a set of sound Anti-Money Laundering (AML) procedures that allow Whitestone employees to make informed decisions as to whether a transaction with an investor may involve money laundering or may finance improper or illegal activities.

Based on the type of clients we engage with and the illiquidity and duration of most of our investment opportunities, it is our assessment that the risk of money laundering across our business is relatively low. Nonetheless, we are conscious of the need to be cautious and are aware of the obligations and challenges posed by money laundering. We have implemented due diligence procedures to ensure compliance with AML requirements.

When undertaking customer and beneficial owner due diligence, we will ask investors for their name, address, date of birth, social security number and other information that will allow us to identify them. We may require further due diligence to verify investors, such as a check against lists of suspected terrorists and an assessment of whether the amount invested in commensurate with the source of wealth and funds. AML procedures may be handled in-house or, where appropriate, outsourced to regulated service providers in the relevant jurisdiction.

Business Continuity

Whitestone is committed to providing timely service to our investors. We recognize the importance of preparing for various disaster scenarios that could hamper our ability to provide such service. Whitestone has taken steps to provide for business contingency and continuity planning under a variety of potential scenarios. We continue to upgrade our continuity plans and expand our resources in order to provide for the recovery and timely resumption of critical business operations to internal business units, third party business partners, intermediaries and our investors.

Business scenario preparedness

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our investors to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of any significant business disruption.

Our business continuity plan addresses: (i) data back-up and recovery; (ii) all mission critical systems; (iii) financial and operational assessments; (iv) alternative communications with investors and employees; and (v) alternate physical location of employees.

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Also, within each of these areas, the severity of the disruption can vary from minimal to severe. Disruptions to only our firm or our office building, we will transfer our operations to our employees’ homes when needed and expect to recover and resume business within one day. In a disruption affecting our business district, city or region, we will transfer our operations to a site outside of the affected area and recover and resume business within two days. In either situation, we plan to continue business and notify you through our website ( detailing how to contact us for urgent matters. If the significant business disruption is so severe that it prevents us from remaining in business, we will take the appropriate measures to ensure that we notify our investors and all investor accounts will be serviced by the appropriate personnel.

Contacting us

If after a significant business disruption, you cannot contact us as you usually do, please notify us through our website at


Please be aware that, while we have detailed plans in place, we cannot guarantee that we will be successful in achieving recovery in the times noted above. For example, we may not be able to implement a plan during a disaster as quickly or efficiently as we expect, or there may be severe disasters that we have been unable to anticipate and for which we have no plan. Additionally, if parts of our plan are dependent on third parties, we will have no control over the success or failure of the third party to respond appropriately to the challenges posted at the time of the disaster.

These plans are periodically updated and modified. If you have any questions, please direct inquiries to Gino Cozza at

Code of Ethics

At Whitestone, we recognize that in the industry in which we operate, trust and reputation are so important. Whitestone has worked hard to cultivate a culture of ethics and open and honest communication within our organization and in our interactions with investors. Our clients’ interests are always of upmost importance.

As required by Rule 204A-1 of the Investment Advisers Act of 1940, Whitestone has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all officers and employees of the firm. The Code of Ethics describes the firm’s fiduciary duties and obligations to investors and sets forth Whitestone’s practice of supervising the personal securities transactions of employees who maintain access to investor information.

All employees will follow the law and act with competence, dignity, integrity, and in an ethical manner, when dealing with investors, the public, prospects, third-party service providers and fellow employees. Employees must use reasonable care and exercise independent professional judgment when conducting investment analysis, promoting Whitestone’s products and services, and engaging in other professional activities.

We expect all employees to adhere to the highest standards with respect to any potential conflicts of interest with investors. As a fiduciary, Whitestone must act in its investors’ best interests at all times. Neither Whitestone, nor any employee shall benefit at the expense of any investor.

Whitestone collects and maintains records of securities holdings and transactions made by employees. The firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest.

Upon request, Whitestone will furnish investors with a copy of the Code of Ethics.

Risk Factors

As is the case with any type of investment, hedge funds and hedge fund investing can involve substantial risks. Below is a summary of certain risks involved in hedge fund investing, but by no means should this list be considered exhaustive.

Potential loss of investment

No guarantee or representation is made that our investment programs will be successful. Past performance is not indicative of future results. Hedge funds typically represent that their returns have a low correlation to the major market indices. Investors should be aware that hedge funds may incur losses both when major market indices are rising and falling.

Limited liquidity

Investors typically have limited rights to redeem and substantially limited rights to transfer hedge fund interests. In addition, there is generally no secondary market for interests in hedge funds and none is ever expected to develop. In addition, illiquidity of a hedge fund’s investments, held directly or indirectly, in the case of a fund of hedge funds, may prevent a fund’s management company from satisfying investor demand for redemptions.

Use of leverage and other speculative investment practices

Hedge funds may use leverage to invest which could increase any loss incurred. The more leverage employed, the more likely a substantial change will occur, either up or down, in the value of the investment. In addition, hedge funds, in general may engage in speculative investment practices, which may lead to losses.

Lack of regulatory oversight

Hedge funds are generally not registered under the Investment Company Act of 1940 (the “1940 Act”). Therefore, investors will not receive the protections of the 1940 Act afforded to investors in registered investment companies.

Tax risks

Investors in hedge funds are typically subject to pass-through tax treatment of their investment. Investors should consult with their tax advisors before investing.

Strategy risk

Strategy risk is associated with the failure or deterioration of an entire strategy. Many of the strategies employed by hedge funds are speculative and involve substantial risk of loss.