Item 5 - Fees and Compensation
Individually Managed Accounts
Management fees are based on the percentage of assets under management. The firm applies the
following fee schedules with respect to its managed Separate Accounts:
Conservative Account Fee Schedule
Asset Value Annual Fee
First $5 million 0.75% 1
Next $10 million 0.58%
Assets above $15 million 0.40%
Balanced Account Fee Schedule
Asset Value Annual Fee
First $5 million 0.80% 2
Next $10 million 0.60%
Assets above $15 million 0.40%
Equity Account Fee Schedule
Asset Value Annual Fee
First $5 million 1.00% 3
Next $10 million 0.75%
Assets above $15 million 0.50%
The minimum portfolio value is generally set at $1,000,000. At its discretion, the firm may make
exceptions and waive this requirement. Fees are generally not negotiable.
The management fee will be paid quarterly in advance or in arrears, based on the value of the
Separate Account at the end of the prior quarter, net of any position in the Partnership or the
Caldwell & Orkin Market Opportunity Fund. If a client terminates the investment management
agreement on a date other than the end of a calendar quarter, the management fee will be prorated
for assets held in the Account for less than a full quarter. With client authorization, fees are debited
directly from the Separate Account.
Fees paid to Adviser are exclusive of all custodial and transaction costs paid to the client’s
custodian, brokers or other third party consultants. Please see Item 12 – Brokerage Practices for
additional information. Fees paid to Adviser are also separate and distinct from the fees and
expenses charged by mutual funds, ETFs (exchange traded funds) or other investment pools to
1The management fee for a Conservative Account under $1 million in assets is
computed at an annual rate of 1.00%, subject to an annual cap of $7,500.
2 The management fee for a Balanced Account under $1 million in assets is
computed at an annual rate of 1.10%, subject to an annual cap of $8,000.
3 The management fee for an Equity Account under $1 million in assets is
computed at an annual rate of 1.25%, subject to an annual cap of $10,000.
their shareholders (generally including a management fee and fund expenses, as described in each
fund’s prospectus or offering materials). The client should review all fees charged by funds,
brokers, Adviser and others to fully understand the total amount of fees paid by the client for
investment and financial-related services.
Either Adviser or the client may terminate their Investment Management Agreement at any time,
subject to any written notice requirements in the agreement. In the event of termination, any paid
but unearned fees will be promptly refunded to the client, and any fees due to Adviser from the
client will be invoiced or deducted from the client’s account prior to termination.
Private Investment Funds
Under Adviser’s investment management agreement with the Partnership, Adviser will receive an
annual management fee. This fee is assessed quarterly in advance, and is calculated based on the
account balance of the Partnership on the first day of each calendar quarter. Each investor is
assessed his or her pro-rata portion of the fee monthly in arrears by deduction from each investor’s
account in the Partnership on the last business day of the calendar month. If an investor withdraws
all or a portion of its account in the Partnership on a date other than the last business day of the
calendar quarter, a prorated management fee will be deducted from the amount withdrawn for any
fees owed.
Under Adviser’s investment management agreement with the Partnership or the Partnership’s
charter documents, as applicable, Adviser will also receive annual performance-based fee in arrears
based on the net capital appreciation (i.e., capital appreciation less capital depreciation) of each
investor’s account in the Partnership. This performance-based fee is calculated based on each
investor’s value in the Partnership on December 31 of each year in which a performance-based fee
is earned. The performance-based fee is payable only if, and to the extent that, the net capital
appreciation of the investor’s account exceeds any net capital depreciation accumulated in prior
years (as adjusted for withdrawals of capital). Adviser, in its discretion, may waive or reduce the
performance-based fee as to all or any of the investors in the Partnership or agree with an investor
to waive or alter the performance-based fee as to that investor.
The performance-based fee is also paid by deduction from each investor’s account. If an investor
withdraws all or a portion of its account in the Partnership on a date other than December 31, a
performance-based fee will be made on the amount withdrawn for the period from the prior
January 1 to the date of withdrawal.