Fees and Compensation — Form ADV Part 2A (3/28/2023)
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Item 5 - Fees and Compensation
Funds
ACM’s management fees for SMAs are negotiated with each client, and consequently fees will
vary. Relevant factors in establishing any fee may include the complexity of the underlying
investment program and the amount of assets to be managed for the account.
Funds - Deduction of Management Fees
Management fees for all Funds and separately managed accounts are billed via invoice and are paid via wire to
ACM.
Funds - Other Fees or Expenses Charged to the Funds
Broker-dealers executing client trades generally charge a brokerage commission on equity securities and
a markup or markdown on fixed income securities. In addition, clients may pay custodian fees and financing
fees.
Other Fees or Expenses Charged to Separately Managed Accounts
SMAs are generally charged a brokerage commission or another form of transaction cost. For example,
equity securities are generally charged a brokerage commission while fixed income securities
incorporate a markup/markdown. In addition, clients may be subject to custodian fees, wire transfer
fees, and transaction fees by third party custodians, and all such fees are reflected on the client’s brokerage
account statements. For additional information regarding brokerage, clients should review Item 12 -
Account Minimums and Types of Clients — Form ADV Part 2A (3/28/2023)
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Item 7 - Types of Clients
ACM can have clients in the following categories: investment companies, business entities, high net worth
individuals, foundations, and trusts. This list is not all inclusive, as other categories may be added as ACM
grows.
• The minimum investment for a SMA is $5,000,000.
• ACM may waive the minimum account size.