Fees and Compensation — Form ADV Part 2A (3/18/2026)
[Brochure]
Item 5 Fees and Compensation
Ativo’s fees for Portfolio Management Services are typically based upon a percentage of assets
under management. Upon agreement with a client or in other circumstances, we may also
charge performance-based fees exclusively or in addition to other types of fees. Please see
Item 6 below for more information about performance fees.
Fee Schedule for Separately-Managed Accounts
The following fee schedules are for separately-managed accounts investing in the noted
strategies.
International Developed - The Ativo International Developed strategy seeks to invest primarily
in undervalued companies domiciled in developed Non-US countries.
Mandate Size Fee Quote (bps)
First $50 million 50
Next $50 million 45
Next $100 million 40
Remaining Balance 35
International All Country ex US - The Ativo International All Country ex US strategy seeks to
invest primarily in undervalued companies domiciled in both developed and emerging Non-US
countries.
Mandate Size Fee Quote (bps)
First $50 million 55
Next $50 million 50
Next $100 million 45
Remaining Balance 40
International Small Cap All Country ex US - The International Small Cap All Country ex US
strategy seeks to invest primarily in undervalued companies with capitalizations of less than $5
billion that are domiciled in both developed and emerging Non-US countries.
Mandate Size Fee Quote (bps)
First $50 million 75
Next $50 million 70
Next $100 million 65
Remaining Balance 60
International Small Cap Developed - The International Small Cap Developed strategy seeks
to invest primarily in undervalued companies with capitalizations of less than $5 billion that are
domiciled in developed Non-US countries.
Mandate Size Fee Quote (bps)
First $50 million 70
Next $50 million 65
Next $100 million 60
Remaining Balance 55
International Small Cap Emerging - The International Small Cap Emerging strategy seeks to
invest primarily in undervalued companies with capitalizations of less than $5 billion that are
domiciled in emerging Non-US countries.
Mandate Size Fee Quote (bps)
First $50 million 80
Next $50 million 75
Next $100 million 70
Remaining Balance 65
Global Institutional - The Ativo Global Institutional strategy seeks to invest primarily in
undervalued companies globally.
Mandate Size Fee Quote (bps)
First $50 million 50
Next $50 million 45
Next $100 million 40
Remaining Balance 35
International ADR/International ADR Concentrated - The Ativo International ADR strategy
seeks to invest primarily in undervalued American Depositary Receipts (“ADR’s”) and other
foreign companies traded on American exchanges. The Ativo International ADR Concentrated
strategy is a subset of the Ativo International ADR strategy and holds approximately 20
securities. The Ativo International ADR Concentrated strategy is targeted for individual
investors. By focusing on the best ideas of the Ativo International ADR, we believe the Ativo
International ADR Concentrated strategy can maintain the risk/return trade-off while having
lower expected turnover. However, with fewer holdings, the concentrated strategy is not as
diversified from a country, sector, and industry perspective.
Mandate Size Fee Quote (bps)
First $50 million 50
Next $50 million 45
Next $100 million 40
Remaining Balance 35
Domestic Large Cap/Domestic Large Cap Concentrated - The Ativo Large Cap strategy
seeks to invest primarily in domestically traded, undervalued companies with market
capitalizations in excess of $20 billion. The Ativo Large Cap Concentrated strategy is a subset
of the Large Cap strategy and holds approximately 20 securities. The Ativo Large Cap
Concentrated strategy is targeted for individual investors. By focusing on the best ideas of the
Domestic Large Cap, we believe the Ativo Large Cap Concentrated strategy can maintain the
risk/return trade-off while having lower expected turnover. However, with fewer holdings, the
concentrated strategy is not as diversified from a sector and industry perspective.
Mandate Size Fee Quote (bps)
First $25 million 30
Next $100 million 25
Remaining Balance 20
Domestic Small Cap/Domestic Small Cap Concentrated - The Ativo Small Cap strategy
seeks to invest primarily in domestically traded, undervalued companies with market
capitalizations between $500 million and $5 billion. The Ativo Small Cap Concentrated strategy
is a subset of the Small Cap strategy and holds approximately 20 securities. The Ativo Small
Cap Concentrated strategy is targeted for individual investors. By focusing on the best ideas of
the Domestic Small Cap, we believe the Ativo Small Cap Concentrated strategy can maintain
the risk/return trade-off while having lower expected turnover. However, with fewer holdings,
the concentrated strategy is not as diversified from a sector and industry perspective.
Mandate Size Fee Quote (bps)
First $50 million 60
Next $50 million 55
Next $100 million 50
Remaining Balance 45
Domestic Smid Cap - The Ativo Smid Cap strategy seeks to invest primarily in domestically
traded, undervalued companies with market capitalizations between $500 million and $20
billion.
Mandate Size Fee Quote (bps)
First $50 million 50
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/18/2026)
[Brochure]
Item 7 Types of Clients
Ativo provides investment management services to the following types of clients:
• Corporate pension and profit-sharing plans (other than plan participants)
• Hospital or healthcare plans
• Public plans such as state or municipal government entities
• Endowments and foundations
• Outsourced CIO firms
• Taft-Hartley or multiemployer plans
• The Private Fund as well as other unregistered pooled investment vehicles
• Model-based unified managed account (UMA) platforms
• Individuals and high net worth individuals
Ativo’s current account minimum is $100,000. For client accounts with initial balances from
$100,000 to $5,000,000, Ativo generally requires the client to maintain the account at either
Goldman Sachs Custody Solutions (“GSCS”) or Charles Schwab, where GSCS and Charles
Schwab act as custodian and executes trade orders entered by Ativo. For client accounts with
initial balances above $5,000,000, a client can generally choose its own custodian and trades
are executed by one of Ativo’s approved brokers as described in Item 12 Trading/Brokerage
Practices. Ativo may accept clients below these minimums at its discretion. It is important to
note that only Ativo’s Concentrated Strategies are available for initial investment amounts under
$5,000,000.
Filed 2026-02-06 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $3,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2022-11-17 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $3,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
6
0.0
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
2
0.1
(g) Pension and profit sharing plans
0
0.1
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
9
0.7
(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