Fees and Compensation — Form ADV Part 2A (2/20/2026)
[Brochure]
Item 5. Fees and Compensation
Acuitas charges a management fee based upon a percentage of assets under management.
Fees for separately managed accounts are negotiable and subject to a number of factors,
including, but not limited to, the amount of assets to be managed, asset class mandate,
complexity of the client relationship, complexity of the client’s investment objectives and
pre-existing contractual commitments. The specific fees charged by Acuitas are set forth
in either the client’s investment advisory agreement, the prospectus or the subscription
agreement. Acuitas will also accommodate client requests for performance-based fee
structures. See also the section of this brochure entitled "Performance-Based Fees and
Side-By-Side Management," which describes certain conflicts of interest inherent in
performance-based compensation arrangements.
Generally, for separate account clients the fees are as follows:
• Microcap – 1.10%
• Small Cap – 0.80%
• International Small Cap – 1.00%
• Emerging Markets Small Cap – 1.10%
Fees for the Private Funds are as follows:
• Long/Short – 0.5% annual rate with a 10% performance allocation
• Emerging Markets Small Cap – 0.8% annual rate
Advisory fees and expense-related information for the Mutual Fund and ETF can be found
in the current prospectus for each vehicle.
Fees for separate accounts will be billed in advance or arrears, as noted in the client
agreement, using custodian market values and will exclude any amounts known to be
invested in the Acuitas Mutual Fund or ETF. The separately managed accounts will be
invoiced directly. Any fees unearned will be either pro-rated or refunded in the event a
client terminates. Fees for the ETF, Private Funds and Mutual Fund are included in the
gross expenses and paid directly to the Adviser. The management fees paid to Acuitas
typically include the fee charged by the subadviser.
The Private Funds bear expenses associated with their investment activities and operations
and certain other expenses, which may include but are not limited to brokerage
commissions; banking and custody charges; interest and fees relating to borrowing;
withholding taxes; expenses of research and data collection and analysis; costs of
communicating with Limited Partners; legal, accounting, auditing, organizational expenses
(but not Acuitas’ organizational expenses); and expenses incurred in the offering and sale
of ownership interests in the Private Funds.
Acuitas bears organizational costs and overhead costs associated with operating the
investment advisory business, including office space, utilities and compensation of
personnel.
Investors within the Mutual Fund and ETF will be responsible for a portion of the operating
expenses of the Mutual Fund or ETF in which they are invested.
Clients may be charged fees in addition to the management fee paid to Acuitas. This can
include brokerage commissions and other custodian fees.
Account Minimums and Types of Clients — Form ADV Part 2A (2/20/2026)
[Brochure]
Item 7. Types of Clients
Acuitas provides investment management services to limited partnerships, mutual funds,
ETFs and separate account clients, including profit sharing plans and state and municipal
government entities.
The Private Funds’ PPMs specify investor eligibility requirements and minimum
investment levels for investors. The Private Funds presently require a minimum initial
investment of $250,000, though Acuitas has discretion to reduce this minimum for any
Limited Partner. Subsequent investments may be made in minimum amounts of $100,000.
In general, a Private Fund investor must be an "accredited investor" and a "qualified client,"
as those terms are defined in the SEC regulations specified in the PPMs. The Subscription
Agreement executed by each investor states in detail the several categories of "accredited
investor" and "qualified client" under those definitions and requires the investor to qualify
for both in order to invest.
For the Mutual Fund, clients can be individuals or institutions. Minimum initial
investments and additional investments for the Mutual Fund are $2,500 and $100 for
Investor Shares and $10,000 and $100 for Institutional Shares, respectively. Please note
that Acuitas is not currently offering Investor Shares for purchase although we may choose
to do so in the future.
There is no minimum for the ETF and it is traded daily on the NASDAQ exchange under
the ticker symbol AIMS. Investors will need to establish a brokerage account in order to
purchase the ETF.
The minimum for separately managed accounts is generally $10 million, but is negotiable
and considered on a case-by-case basis.
Filed 2025-04-04 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $250,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2011-02-17 (D) · Exemption 506, 3(c), 3(c)(1) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets No Aggregate Net Asset Value
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
0
0.0
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
1
103.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
2
4.8
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
1,372.8
(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