Avocet Capital Management LLC

Item 5: Fees and Compensation

F. Important Disclosure – Custodian Investment Programs
Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we
can access certain investment programs offered through such custodian(s) that offer certain
compensation and fee structures that create conflicts of interest of which clients need to be aware. Please
note the following:
Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain programs
in which we participate where a client’s investment options may be limited in certain of these programs to
those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee
payments, and the client should be aware that the firm is not selecting from among all mutual funds
available in the marketplace when recommending mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue
share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things
being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay
revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although
many factors will influence the type of fund to be used, the client should discuss with their investment
adviser representative whether a share class from a comparable mutual fund with a more favorable return
to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the
client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such
fees can create conflicts of interest in instances where the custodian receives the entirety of the 12b-1
and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it
may elect to provide to the firm, even though such benefits may or may not benefit some or all of the
firm clients.

                       Part 2A of Form ADV: Avocet Capital Management Brochure

Item 7: Types of Clients
Avocet offers its investment services to various types of clients, including individuals and high-net-worth
individuals, trusts and estates, corporations and other businesses.
Avocet requires a minimum account size of $500,000 for accounts it manages on a discretionary or non-
discretionary basis. Avocet, in its sole discretion, may waive the required minimum account size.
There is a minimum net worth of $500,000 for financial planning clients. Avocet, in its sole discretion, may
waive the required minimum account size.

                       Part 2A of Form ADV: Avocet Capital Management Brochure