Arbalpha Capital LLC

Item 5: Fees and Compensation

Item 5.A.
Compensation for Client Account management is negotiable and will vary, but typically
consists of a percentage of assets under management. ArbAlpha will typically be entitled to
receive a fee quarterly in the amount of one-fourth of 1.25% (0.3125%) of the net asset value

ArbAlpha Capital LLC                                 Form ADV Part 2A (Brochure)

of each Client Account (the “Management Fee”). ArbAlpha, in its discretion, may waive,
discount or negotiate fees for certain Clients based on factors such as assets under
management or complexity of accounts managed. Additionally, ArbAlpha retains the right to
waive or discount fees for employees and family members. Neither ArbAlpha, nor its
supervised persons, will be compensated for the sale of securities or other investment
products, including asset-based sales charges or service fees from mutual funds.

Item 5.B.
Initially, management fees will be based upon the date the account is accepted for management
by execution of the Investment Management Agreement or when the assets are transferred
to the recommended custodian. Thereafter, fees will be charged quarterly, will be based on
the market value of the account on the last day of the calendar quarter and will cover the
period from the first day of the current calendar quarter through the last day of the current
calendar quarter. The market value will be determined as reported by the custodian. Fees
are generally assessed on all assets under management, including securities, cash and money
market balances. Fees are deducted from Client Accounts quarterly. Clients may terminate
the relationship with ArbAlpha without penalty at any time by providing ArbAlpha with written
notice and a pro rata refund of any fees paid in advance.

Item 5.C.
In addition to the fees outlined above, Clients will also be responsible for third-party fees
and/or expenses, which may include custodial fees, brokerage commissions (see Item 12
– Brokerage Practices), transaction fees, odd lot differentials, transfer taxes, wire transfer
and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.

Mutual funds, ETFs and private funds will charge their own investment management fees
and will incur their own transaction costs which are in addition to any fees charged by
ArbAlpha. Detailed information on these costs can be found in the mutual funds’ or ETFs’
prospectuses which will be provided to Clients prior to or at the time of investment.

Item 5.D.
ArbAlpha does not charge fees in advance.

Item 5.E.
ArbAlpha and its supervised persons are not compensated for the sale of any securities,
including by any of the mutual fund or ETF companies recommended for Client
investment. Clients have the option to purchase investment products recommended by
ArbAlpha through other brokers or agents that are not affiliated with ArbAlpha. Clients
can avoid ArbAlpha management fees by purchasing funds directly from the mutual fund
companies.

Item 7: Types of Clients

ArbAlpha will generally provide wealth management to the following types of Clients:
 ▪     Individuals
 ▪     High-Net-Worth Individuals
 ▪     Trusts

ArbAlpha Capital LLC                                Form ADV Part 2A (Brochure)

 ▪      Estates
 ▪      Charitable Organizations
 ▪      Small businesses

Minimum Account Size
ArbAlpha will have an account minimum of $100,000. However, the Firm may accept
Clients under such minimum on a case-by-case basis.