Fees and Compensation — Form ADV Part 2A (8/4/2026)
[Brochure]
Item #5 - Fees and Compensation
A. Advisory fees for separately managed accounts range from 0.4% to 2.0% per annum of assets under
management. Fees are negotiable based on account size, relationship, and strategy.
B. Fees are typically debited quarterly, in arrears, directly from the client’s custodial account. Clients
may elect to pay fees by check if they prefer.
C. Clients pay their proportionate share of expenses for any ETFs, mutual funds, or other investment
companies held in their accounts. Clients also incur brokerage and other transaction costs (see Item
12).
D. EFSAM does not require or accept payment of fees six or more months in advance exceeding $500
per client.
E. EFSAM and its supervised persons do not accept compensation for the sale of securities or other
investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (8/4/2026)
[Brochure]
Item #7 – Types of Clients
EFSAM primarily provides services to high-net-worth individuals. The Firm customarily requires a
minimum account size of $500,000 but may accept smaller accounts at its discretion.
Filed 2014-02-03 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $2,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose