1839 Asset Management LLC

Item 5: Fees and Compensation

Upon termination of any account, any unearned, prepaid fees will be promptly refunded and any
earned, unpaid fees will be immediately due and payable. The client has the right to terminate
an agreement without penalty within five business days after entering into the agreement.

C. Expenses Charged to Clients
1839 Asset Management’s clients may pay, in addition to Base Fees and Incentive Fees, such
other expenses as are agreed between 1839 Asset Management and the client in the Investment
Management Agreement. Such expenses may include, without limitation, fees, costs, and
expenses relating to the acquisition and disposition of assets, investment-related expenses,
indebtedness expenses, taxes, fees and other governmental charges, auditing and tax
preparation expenses, custodial expenses, professional fees, data service fees, fees and expenses
of accountants and counsel, litigation and indemnity costs, and other extraordinary expenses.
Although 1839 Asset Management does not generally use the services of broker-dealers for the
purpose of executing investments on behalf of its clients, in the event that it chooses to use a
broker-dealer for limited purposes relating to an investment on behalf of a client, such client will
incur brokerage and other transactional costs.
Supervised persons of 1839 may receive consulting and/or similar one-time fees from third
parties. Conflicts of interest may arise relating to client investments in third parties who have
paid such consulting fees.

D. External Compensation for the Sale of Securities to Clients
1839 Asset Management advisory professionals are compensated primarily through a salary and
bonus structure. 1839 Asset Management is not paid any sales, service or administrative fees for
the sale of mutual funds or any other investment products with respect to managed advisory
assets.
Although 1839 Asset Management is not paid any sales, service, or administrative fees for the
sale of mutual funds or any other investment products, the firm or its affiliates may be paid
management fees and performance-based fees. Such performance-based fees create an
economic incentive for the investment manager to take additional risks and allocate more time
and resources in the management of a client portfolio that may be in conflict with the client’s
current investment objectives and tolerance for risk. Please refer to Item 6 for more information
on performance-based fees.

                     Part 2A of Form ADV: 1839 Asset Management LLC Brochure

Item 7: Types of Clients
1839 Asset Management, on its own and as sub-advisor, provides investment services for
institutional third-party clients. Registrant’s client base is expected to include insurance
companies and other institutional clients in the near future.
In addition, the firm advises an affiliate private fund. The fund’s offering documents detail
investment minimums, investor qualifications, and other pertinent data the client should read
prior to investing.

                     Part 2A of Form ADV: 1839 Asset Management LLC Brochure