Item 5 Fees and Compensation
ADVISORY FEES
The following information describes how Carma Advisory is compensated for the advisory
services we provide to our clients. The specific manner in which fees are charged and the
compensation we receive may differ between clients depending upon the individual Engagement
Agreement with each client. Carma Advisory reserves the right to negotiate our compensation
with clients depending on the scope of our advisory relationship, and we may charge higher or
lower fees than are available from other firms for comparable services. Carma Advisory has the
general discretion to waive all or a portion of our fees, but typically only exercises this discretion
for our employees.
Investment Management Fees. In consideration for providing investment management services,
Carma Advisory receives compensation from clients based both on (i) a specified percentage of
the assets we manage, and (ii) performance achieved for the client’s account, as described below.
Pursuant to the terms of the Engagement Agreement with the client, Carma Advisory charges an
annual management fee of up to 2.00% based on the client’s assets under management (“AUM”),
billed monthly in arrears and, for certain qualified clients and if agreed upon in writing, an
additional annual performance-based profit allocation of up to 20% of each investor’s annual net
realized and unrealized profits. Our performance-based profit allocations are deducted from
each investor’s account at the end of each year or when an investor makes a withdrawal (pro-
rated based on the amount withdrawn). These fees are subject to specific negotiations with each
particular client.
Our performance-based profit allocations are deducted from each investor’s account at the end
of each year or when an investor makes a withdrawal (pro- rated based on the amount
withdrawn). These fees are subject to specific negotiations with each particular client.
If a client chooses, our investment management fees are deducted from the client’s account(s),
pursuant to the client’s written instructions to the broker/dealer holding the account (the
“qualified custodian”). Specifically, clients can elect to use Interactive Brokers’ automatic advisor
fee billing functionality, through which the client authorizes the qualified custodian in writing to
automatically deduct a certain amount of fees from their account(s) and remit the fees to us.
Clients specify the method by which our fees will be calculated as well as the timing of the
deductions (i.e., monthly, annually, etc.). This request may be made in the client’s account
application to the qualified custodian or at any time after that, and the client may change his
billing instructions to the qualified custodian at any time. Once this written request from the
client is processed, the qualified custodian will calculate the fees according to the method
specified by the client. Our firm does not have the authority to request that the qualified
Carma Advisory Società di Consulenza Finanziaria SRL 7
Form ADV Part 2A
custodian withdraw any fees from the client’s accounts or make any adjustments to clients’
predetermined fee calculation method (other than to reduce the fee).
Signal Provider Fees. The terms and conditions under which Carma Advisory provides its trading
signals are set forth in separate written agreements between Carma Advisory and the client.
Payment arrangements are determined on a case-by-case basis and will be detailed in the signed
engagement agreement.
Sub-Advisors. Carma Advisory may also provide investment management services as a sub-
adviser to certain accounts. In other words, an investor may engage an independent investment
adviser (the “primary adviser”) which, in turn engages Carma Advisory to provide portfolio
management services to all or part of such investor’s portfolio. In this situation, Carma Advisory
charges an annual asset-based fee up to 2% to the primary advisor based on the client’s assets
under management (“AUM”) as valued by the custodian and/or an annual performance-based
profit allocation of up to 20% of each investor’s annual net realized and unrealized profits.
As compensation for assistance provided by the Carma Advisory to the primary advisor in
connection with Carma Advisory’s performance of services with respect to such accounts, the
primary advisor may pay to Carma Advisory a portion of the fee it receives for such sub-advised
accounts.
Additional Fees and Expenses. Clients will incur transaction charges and/or brokerage fees when
purchasing or selling securities. These charges and fees are typically imposed by the broker-
dealer or qualified custodian through which account transactions are executed. For more
information on our brokerage practices, please refer to the “Brokerage Practices” section of this
Brochure.
The fees that clients pay to our firm for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds and/or exchange traded funds (described
in each fund’s prospectus) to their shareholders. The fees charged directly by mutual funds and
exchange traded funds will typically include a management fee and other fund expenses.
To fully understand the total costs associated with their investment portfolio, clients should
review all the fees charged by mutual funds, exchange traded funds, our firm and others.
Termination. The Engagement Agreement with our clients may be terminated by either party at
any time upon thirty (30) days written notice. Upon termination of our status as the client’s
investment adviser, Carma Advisory will not take any further action with respect to the client’s
account(s) unless specifically notified by the client in writing. Clients will be responsible for
instructing their custodian and monitoring their account for the final disposition of assets.
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