Fees and Compensation — Form ADV Part 2A (6/1/2022)
[Brochure]
Item 5 – Fees and Compensation
We do not charge management fees or performance-based compensation to the SMAs. However,
we provided non-discretionary investment advice to certain SMAs regarding an investment in a
private fund managed by a third-party manager (the “Third Party Manager”). According to one of
our related person’s agreement with the Third-Party Manager, we or our related persons receive a
portion of the asset-based fees and performance fees our clients would have otherwise been charged
directly from the Third-Party Manager with respect to their investments in the private funds it
manages.
Our SMAs have the ability to choose to be billed directly for fees incurred.
Account Minimums and Types of Clients — Form ADV Part 2A (6/1/2022)
[Brochure]
Item 7 – Types of Clients
Our clients are the SMAs. Owners of our SMAs are generally high net worth individuals,
corporations, personal trusts, and IRA accounts that qualify as “accredited investors” (as defined
in Rule 501 under the Securities Act of 1933, as amended) and “qualified clients” (as defined in
Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”)). We are
no longer accepting new SMAs.
Filed 2020-04-02 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2020-04-02 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
3
0.4
(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
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(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