Cystein Management LLC

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Cystein Management LLC
CRD #290365
SEC #801-112087
CIK #
AUM 4.5 M (2026-03-30)
Employees 2 (50% Investors, 0% Brokers)
Fees
Minimum
Phone210-888-0986
Address
Source [IAPD] [Website]
Total AUM ($M)
6.04.83.62.41.20.02010201520212027
Fees and Compensation — Form ADV Part 2A (3/30/2026) [Brochure]
Item 5 - Fees and Compensation
Portfolio Management Services
Portfolio management services accounts are assessed an annualized asset-based fee of 0.45% (45 basis
points) that is paid monthly, in arrears. Advisory fees are not negotiable. The fee will be determined by the
reporting account value as of the last US market day of each month, and in consonance with the statement
the client receives from the custodian of record for the purpose of verifying the computation of the advisory
fee. In the rare absence of a reportable market value, our firm may seek a third-party opinion from a
recognized industry source (e.g., unaffiliated public accounting firm), and our clients may choose to
separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if
necessary. The fee is calculated by multiplying the quotient by the applicable number of basis points (one
basis point equals 1/100 of one percent). The result is then divided by 12 to determine the monthly fee.

The first billing cycle will begin once the client agreement is executed and account assets have settled into
the client’s separately identifiable account held by the custodian of record. Fees for partial month’s will be
prorated based on the remaining days in the reporting period in which the firm services the account. Fee
payments will generally be assessed within the first 10 days of each billing cycle.

The client’s written authorization is required in order for the custodian of record to deduct advisory fees
from an account. By signing the CYStein engagement agreement, as well as the custodian account opening
documents, the client will be authorizing the custodian to withdraw our firm’s advisory fees from their
account. The custodian will remit advisory fees directly to CYStein; we do not accommodate requests for

CYStein Management LLC
Form ADV Part 2A - 20260320

direct payment of advisory fees in lieu of the fee being withdrawn from the investment account. Deducted
fees will be noted on account statements that the client receives directly from the custodian of record.

Educational Seminars
While educational sessions are complimentary, we may require reimbursement of normal and customary
travel expenses which will be coordinated with the event sponsor in advance.

Additional Client Fees
Any transactional or service (“brokerage”) fees, account termination fees, or wire transfer fees will be borne
by the account holder per the separate fee schedule of the custodian of record. Certain fees may be reduced
or waived based on the size of the client’s account maintained at the custodian. CYStein will ensure that its
clients receive a copy of the firm’s recommended custodian fee schedule at the beginning of the
engagement, and clients will be notified of any future changes to these fees by the custodian of record.
Additional information about firm fees in relationship to brokerage and operational practices may be found
in Item 12 of this document.

Advisory fees paid to the firm for its advisory services are separate from any internal fees or charges a client
may pay for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other similar
investments.

External Compensation involving Securities
CYStein does not charge or receive a commission or a mark-up on securities transactions, nor will the firm or
an associate be paid a commission on the purchase of a securities holding that is recommended to a client.
The firm does not receive “trailer” or SEC Rule 12b-1 fees from a mutual fund company that may be
recommended to a client. Fees charged by such issuers are detailed in prospectuses or product descriptions
and interested investors are always encouraged to read these documents before investing. Our firm and its
associates receive none of these described or similar fees or charges. Clients retain the right to purchase
recommended or similar investments through a service provider of their own choice.

Termination of Firm Services
Either party may terminate the agreement at any time by communicating the intent to terminate in writing.
CYStein will not be responsible for investment allocation, advice or transactional services (except for limited
closing transactions) upon receipt of a termination notice. It will also be necessary that our firm inform the
custodian of record that the relationship between parties has been terminated.

If a client did not receive CYStein’s Form ADV Part 2 firm brochure at least 48 hours prior to entering into
our firm’s agreement, then that client will have the right to terminate the engagement without fee or
penalty within five business days after entering into the agreement. A client terminating their agreement
after the five business-day rescission period will be assessed fees on a prorated basis for services incurred
from either (i) as a new client, the date of the engagement to the date of the firm’s receipt of the written
notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s physical or
constructive receipt of written termination notice. CYStein will return any prepaid, unearned fees within 30
days of the firm’s receipt of termination notice via the account holder’s investment account held at the
custodian of record. If CYStein is unable to deduct its advisory fees from the account at the custodian of
record, then our earned fees will be due upon the client’s receipt of our invoice.

CYStein Management LLC
Form ADV Part 2A - 20260320
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2026) [Brochure]
Item 7 - Types of Clients
    Our firm provides advisory services to individuals and high net worth individuals, small businesses,
    foundations and charitable organizations. We do not require minimum income, minimum asset levels or
    other similar preconditions, but we do reserve the right to decline services to any prospective client for any
    nondiscriminatory reason.
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 15 1.8
(b) Individuals (high net worth individuals) 7 2.7
(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 0 0.0
(n) Other 0 0.0
Total 22 4.5
By Discretionary
Discretionary 22 4.5
Non-Discretionary 0 0.0
Total 22 4.5
By Non-United States Persons
Non-United States Persons 4.5
United States Persons 0.0
Total 22 4.5
Firm Profile (Form ADV)
ServesInstitutional, Retail, Research
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