Fees and Compensation — Form ADV Part 2A (3/30/2026)
[Brochure]
Item 5 FEES AND COMPENSATION
A. Advisory Fees
3Sisters Sustainable Management earns its fees and compensation by providing advisory services.
1. Investment Management Services
3Sisters Sustainable Management offers three levels of advisory services to clients, which are described
below:
Regular Advisory Services. Our regular advisory services are designed for clients who are “qualified clients”
as defined by SEC regulations. Our regular advisory clients receive continuous and regular management of
their investments. The fee schedule is as follows:
ASSETS UNDER MANAGEMENT ANNUAL FEE PERCENTAGE
Assets up to $1 million 1.00%
$1 million to $5 million 0.75%
$5 million to $10 million 0.50%
$10 million and higher 0.25%
The annual fee is computed as a percentage of the total value of the assets under management (based upon a
formal valuation) at the end of each quarter. Fees are billed quarterly in arrears. Our fees are negotiable. Total
client fees will not exceed 3% of assets under management when a third-party investment adviser is used.
Fees charged by 3Sisters Sustainable Management do not include any brokerage commissions, any fees and
expenses charged by mutual funds or exchange traded funds, or any fees charged by 3Sisters Sustainable
Management to the Funds. Mutual fund fees and expenses are described in each fund's prospectus. Fund fees
will generally include a management fee, other fund expenses and a possible distribution fee. If a mutual fund
also imposes sales charges, a client may pay an initial or deferred sales charge. Clients could invest in a
mutual fund directly, without the services of 3Sisters Sustainable Management. In that case, the client would
not receive the services provided by 3Sisters Sustainable Management in determining which mutual funds are
most appropriate to the client's financial condition and objectives. Accordingly, the client should review both
the fees charged by mutual funds and the fees charged by 3Sisters Sustainable Management to fully
understand the total amount of fees to be paid and to thereby evaluate the advisory services being provided.
The fees that 3Sisters Sustainable Management charge the Funds are disclosed below.
Special advisory services: For special advisory services that require unusual time or capacity 3Sisters may
charge up to 2.00% of the assets under management. Such special advisory services are designed for clients
who are “qualified clients” as defined by SEC regulations. We may provide these clients with intensive
trading accounts based on a subset of proprietary holdings in Scarab Funds. There is a high degree of risk in
6 2026 ADV Brochure
such trading and therefore it is only recommended for clients with high risk/return expectations. We may also
charge such fees for intensive short-term consulting, including analysis of existing accounts and due diligence
on private investment opportunities under consideration by such clients. Our fee for this service is a flat
annual rate of 2% of the amount of funds in the account, calculated at the beginning of each calendar quarter
(or partial quarter for the beginning or end of this relationship) and billable at .50% for such quarter. This fee
is in addition to any costs incurred from Interactive Brokers, including commissions from trading. All of our
fees and the costs of Interactive Brokers will be paid out of account. No additional billable work will be
performed without the express consent of the client.
Fees charged by 3Sisters Sustainable Management do not include any brokerage commissions, any fees and
expenses charged by mutual funds or exchange traded funds. Fund fees will generally include a management
fee, other fund expenses and a possible distribution fee. If a mutual fund also imposes sales charges, a client
may pay an initial or deferred sales charge. Clients could invest in a mutual fund directly, without the services
of 3Sisters Sustainable Management. In that case, the client would not receive the services provided by
3Sisters Sustainable Management in determining which mutual funds are most appropriate to the client's
financial condition and objectives. Accordingly, the client should review both the fees charged by mutual
funds and the fees charged by 3Sisters Sustainable Management to fully understand the total amount of fees to
be paid and to thereby evaluate the advisory services being provided.
Fees charged by 3Sisters Sustainable Management do not include any brokerage commissions, any fees and
expenses charged by mutual funds or exchange traded funds. Fund fees will generally include a management
fee, other fund expenses and a possible distribution fee. If a mutual fund also imposes sales charges, a client
may pay an initial or deferred sales charge. Clients could invest in a mutual fund directly, without the services
of 3Sisters Sustainable Management. In that case, the client would not receive the services provided by
3Sisters Sustainable Management in determining which mutual funds are most appropriate to the client's
financial condition and objectives. Accordingly, the client should review both the fees charged by mutual
funds and the fees charged by 3Sisters Sustainable Management to fully understand the total amount of fees to
be paid and to thereby evaluate the advisory services being provided.
2. The Funds
The Funds compensate 3Sisters Sustainable Management in the form of management fees (the “Management
Fee”) for rendering advisory services to each Fund.
The Management Fee assessed to the Scarab Funds is paid monthly in arrears based on the capital account
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2026)
[Brochure]
Item 7 TYPES OF CLIENTS
3Sisters Sustainable Management provides investment advice to pooled investment vehicles and separate
accounts used by high-net-worth families, trusts, endowments, plan sponsors and other investment advisors.
The minimum investment requirement is $100,000 for the Funds, while the minimum for separate accounts is
$1 million. The minimum investment requirement is $1 million. Lower minimums can be negotiated at
3Sisters Sustainable Management’s discretion.