Efficient Capital Management LLC

ITEM 5. FEES AND COMPENSATION
Given potential differences in each Client’s fee structure, a general summary of the primary types
of fees that Efficient may charge for its services are listed herein. Efficient is willing to negotiate
fees on a discretionary basis.

Efficient gets paid its fees either on a monthly, quarterly, semi-annual or annual basis. The specific
details relating to the percentage of fees charged by Efficient and the time period for which the
fees are calculated and paid are set forth in the applicable OM. Efficient does not offer or
participate in any products that offer wrap fees.

Efficient can receive compensation in the form of one or more of the following fees as set forth
below:

Platform / Administration Fee: A fee payable to Efficient for accessing investments through a
customized platform structure which is designed to give the investor the option of selecting single
manager or multi-manager options for investment purposes. Platform Fees may be based on a
percentage of Net Asset Value (“NAV”) or alternatively, “nominal assets”. The specified fee and
the method of calculation is described in each OM and can vary by Fund, class of shares/interests
and/or investor, as applicable. Please note the Platform Fee may also be referred to as the
“Administration Fee” in some of the OMs. This fee is distinct from the Management Fee described
below which can be charged in addition to, or in lieu of, this fee. This fee generally may range
from 0% to 2.0% per annum, payable monthly in arrears, although in certain instances may exceed
this range.
Management Fee: Efficient traditionally receives a Management Fee as the CPO or as the
Investment Manager of a Client. Management Fees may be based on a percentage of NAV or
alternatively, “nominal assets”. The specified fee and the method of calculation is described in
each OM of every Client Efficient manages and can vary by Fund, class of shares/interests and/or

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investor, as applicable. This fee generally may range from 0% to 2.0% per annum, payable monthly
in arrears, although in certain instances may exceed this range.

“Nominal assets” refer to the actual cash in the Clients’ accounts plus the agreed upon amount of
notional funding. See also ITEM 8 – METHODS OF ANALYSIS, INVESTMENT
STRATEGIES AND RISK OF LOSS – Nominal Assets and Notional Funding.

Incentive Fee: Efficient can also receive an Incentive Fee as the CPO or the Investment Manager
based on investment performance (i.e., “net new profits”, as defined in the applicable OM or other
governing document) over a certain measurement period. The specified fee and the method of
calculation is described in each OM of every Client Efficient manages and can vary by Fund, class
of shares/interests and/or investor, as applicable. Please note the Incentive Fee is also referred to
as the “Performance Fee” in some of the OMs. This fee generally may range from 0% to 20%
although in certain instances may exceed this range. The time period for measurement and payment
of Incentive Fees can be on a monthly basis, quarterly basis, semi-annual basis or annual basis.
For example, for certain Funds or investors, Incentive Fees may be determined and paid in full
each quarter, while for others a portion of the Incentive Fees may be determined and paid monthly,
with the remainder of the Incentive Fee subject to risk of loss and determined and paid at a later
date, if any.

The calculation methodologies of any of the fees shown above as well as the timing of the payment
of the fees are set forth in the OM for the Clients. If fees were to vary from that which is shown in
the OM, such fees generally would be memorialized in a side letter or other agreement.

Efficient has and may continue to negotiate fees with its Clients or investors in Clients through
side letters or other agreements. Fees charged by Efficient can vary. Certain investors may pay
reduced fees or receive fee waivers or rebates. A potential investor should request the specific OM
for the Fund for which they are interested in making an investment.

All the fees earned by Efficient are paid to Efficient by the Clients and are reflected in the Client’s
NAV on the statement sent to the investor by the third-party fund administrator. The external
administrator will calculate the fees owed to Efficient and will wire transfer such fees to Efficient
through a deduction from the Client’s account.

Fee Sharing: Efficient shares its fees with appropriately registered third parties who act as
placement agents for the offer and sale of interests in certain Funds. Efficient also participates in
fee sharing with certain Advisors that trade for the Clients (i.e., Efficient receives a portion of
those Advisors’ fees, which are referenced below). This fee sharing arrangement creates a conflict
of interest because Efficient has an incentive to select or recommend (as applicable) Advisors that
permit Efficient to participate in the sharing of the Advisors’ management or incentive fees, or
who are willing to share a greater proportion of their fees than other advisory firms.

Certain Clients also may feature a single fee structure (i.e., a management fee only, shared between
Efficient and the Advisors to the Client), which creates certain conflicts. In particular, since in
those situations Efficient and the Advisors share in the single management fee, Efficient may be
constrained from selecting certain advisory firms, given the fees certain firms may charge for their

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services. Efficient is incentivized to select Advisors who agree to be paid a smaller proportion of
the management fee than advisory firms who can command higher fees, even though such higher-
fee firms may be appropriate for the Client’s portfolio. The lower the Advisors’ share of the
management fee, the more of that fee that Efficient will retain.

Notwithstanding the foregoing, Efficient endeavors to select or recommend only Advisors that it
...

ITEM 7. TYPES OF CLIENTS
The types of Clients that Efficient currently services are Funds managed by Efficient.
Efficient’s Funds are domiciled in the United States and in the Cayman Islands or other offshore
jurisdictions. Other than the Registered Fund, the U.S.-domiciled Funds (“U.S. Funds”) only
accept investors that are “accredited investors” within the meaning of Regulation D under the
Securities Act of 1933, as amended, and “qualified eligible persons” as defined in Rule 4.7(a)
under the Commodity Exchange Act, as amended (“CEA”) and in the case of any private fund,
“qualified purchasers” as defined by Section 2(a)(51) of the Investment Company Act of 1940.
The offshore-domiciled Funds (“Offshore Funds”) are limited to investors that are U.S. persons
who are both accredited investors, qualified eligible persons (and qualified purchasers, if
applicable), or non-U.S. persons. Specific Funds may impose additional or different regulatory
eligibility standards for investors to invest, if applicable.
The minimum amount for investment into any of the U.S. Funds or Offshore Funds can range from
$100,000 to $1,000,000 and may be lower or higher depending on the factors relating to the level
of customization or based on waivers of such minimums with Efficient’s consent. The Registered
Fund’s minimum investment amounts are described in the Registered Fund’s prospectus.
Investors in the Funds typically include, but are not limited to, large institutional clients, such as
banks, insurance companies, investment companies, pooled investment vehicles, public and
private pensions and retirement funds, endowments and foundations, among other investors.