Item 5: Fees and Compensation
ACM primarily provides discretionary investment management services to individuals, trusts,
foundations, institutions, and limited partnerships, through a Small Company Growth strategy
investing in equities, fixed income securities and cash reserves.
Small Company Growth Separate Accounts:
ACM’s current fee schedule effective December 1, 2018 is stated as an annual percentage of
assets under management as follows:
First $25,000,000…………………………. 1.0%
Next $25,000,000…………………………. 0.95%
Next $50,000,000…………………………. 0.90%
Balance………………………………………… 0.85%
The above schedule is negotiable under certain circumstances. For client accounts established
prior to September 9, 2011, fees are adjusted on a pro rata basis for contributions and
withdrawals of $25,000 or more during a quarter. For accounts initiated after this date there
are no pro rations for contributions and withdrawals during a quarter.
Long-Term Durable Growth Separate Accounts:
As an extension of the Small Company Growth product, ACM has developed a strategy that
represents an accumulation of what ACM believes to have been the “best idea” stocks the firm
has managed for client accounts over the past forty plus years and may still be held in current
client small company growth accounts. Fees for this product follow the same fee schedule as
the Small Company Growth Separate Accounts.
Small Company Growth Limited Partnerships:
ACM is the investment adviser to Ashford Capital Partners, L.P. (ACP) and Anvil Investment
Associates, L.P. (Anvil), both Delaware limited partnerships, formed as investment partnerships
for sophisticated investors. ACM receives a management fee, billed in arrears, of 0.25 of 1%
per quarter on ACP’s net asset value, less the actual accrued expenses of the general partner,
Ashcap Corp. Effective December 31, 2023, Anvil Investment Associates, L.P. has liquidated
100% of the public securities and distributed the proceeds net of expenses to the remaining
limited partners. Effective January 1, 2024, the partnership will no longer charge a
management fee. As the illiquid private investments become liquid, the proceeds will be
distributed to retired partners. As of September 30, 2025, Anvil only holds two illiquid private
investments totaling approximately $346,000. These investments will be liquidated by
December 31, 2025, for all retired limited partners. The partnerships also contain performance-
based fees as mentioned in Item 6.
Ashford Institutional Growth Fund:
Effective September 1, 2018 ACM is the investment advisor to Ashford Institutional Growth
Fund (AIGF), a Delaware Limited Liability Company, formed as an investment LLC for
sophisticated investors. It is a small company growth fund generally for institutional investors.
ACM receives a management fee, billed in arrears, of 0.25 of 1% per quarter on AIGF’S net asset
value, less operating expenses (excluding fees paid to the custodian) in excess of 0.07% per
annum. When the Fund’s aggregate gross asset value is greater than $100 million the fund pays
100% of all operating expenses. Investors of this fund are required to be qualified purchasers
(persons with investments of not less than $5 million) and have an overall investment
relationship with ACM of $25 million (as defined in the Private Offering Memorandum). This
partnership does not contain performance-based fees.
Long-Term Value/Growth Limited Partnership:
ACM is the investment adviser to Osprey Investment Partners, L.P. (OIP), a Delaware limited
partnership, formed as an investment partnership for sophisticated investors. ACM receives a
management fee, billed in arrears, of 0.25 of 1.5% per quarter on OIP’s net asset value. This
partnership also contains a performance-based fee as mentioned in Item 6.
Asset Allocation Program:
ACM also provides discretionary investment management services to family offices, individuals,
trusts, foundations and institutions through an Asset Allocation Program investing in mutual
funds, fixed income securities, exchange traded funds, options and cash reserves. ACM’s fee
schedule under an existing group relationship for this product is stated as an annual percentage
of assets under management at an annual rate of 70/100ths of 1% of net asset value. For
accounts outside of this relationship the current fee rate is 85/100ths of 1% on the first $10
million of net asset value and 55/100ths of 1% on net asset value greater than $10 million. The
preceding fees are negotiable under specific circumstances. For client accounts established
prior to September 9, 2011 fees are adjusted on a pro rata basis for contributions and
withdrawals of $100,000 or more during a quarter. For accounts initiated after this date there
are no pro rations for contributions and withdrawals during a quarter.
Billing
Fees for separate accounts are generally billed and payable quarterly in advance. The limited
partnerships are billed in arrears. Clients may elect to be billed directly or to authorize ACM to
bill the custodian and have fees electronically transferred to ACM. All accounts initiated or
terminated during a calendar quarter will be charged a prorated fee. Contracts generally
provide for cancellation by either party upon 30-day’s notice. Upon termination any prepaid,
unearned fees will be refunded.
Other Fees/Expenses
ACM’s fees exclude brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. Clients will incur certain charges imposed by
custodians, brokers, third party consultants and other third parties, such as fees charged by
managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and security transactions. Mutual funds
and exchange traded funds may also charge internal management fees, which are disclosed in a
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