Fees and Compensation — Form ADV Part 2A (6/28/2016)
[Brochure]
Item 5. Fees and Compensation
The Company executes a written investment management agreement with each of its clients. All of our fees are
negotiable and once agreed are set forth in the client investment management agreement. We do not have a fee
standard schedule because each client is free to negotiate its own fees with us.
Types of Fees and Compensation
While we may agree with a client on any number of fee structures, the most common fee structures are as follows:
• Institutional clients – incentive fees based on realized returns as determined under generally accepted accounting
principles (“GAAP”). These fees may range from 5% - 25%. The measurement date for this type of fee is generally
the last day of each calendar quarter.
• Retail clients – a percentage of assets under management, which is typically 1.0% - 2%of your portfolio balance at
the end of prior quarter or any portion thereof (pro-rata for actual time services are provided). These fees are
charged quarterly in arrears.
• Retail & Institutional Clients – Trading transaction fees as commission overrides may be charged in addition to any
combination of fixed management fees and or incentive fees.
• Consulting clients - $350 per hour with a minimum retainer of $5,000. These fees are billed monthly and due
upon receipt of an invoice.
• Investment advisor representatives (“IAR(s)”), with the prior written consent of the Company, may recommend
that any suitable client invest in one or more alternative investment such as private investment pools or “hedge
funds”. In the case of a third party, the issuer of alternative investments often pays finder fees or commissions to
those who introduce clients that actually invest. These fees or commissions may be paid upon initial investment,
typically ranging from 1%-7% depending on the issuer, or in the form of a carried interest in the pools or funds
ranging from 1% - 30% of net income, as defined by the issuer. If the Company receives this type of compensation
with respect to a retail client, it waives that client’s fees which are based on a percentage of assets under
management. This practice may present a conflict of interest, we will discuss with you in advance, and give the
Company or its IAR(s) an incentive to recommend investment products based on compensation received, rather
than on a your needs.
Payment Method
Part 2 A of Form ADV: Firm Brochure 6 March 31, 2016
At the end of each quarter, we invoice you for the fees due. Invoices are prepared by our controller and sent to you
with a copy to the qualified custodian. When you become our client, you will give the qualified custodian written
instructions to deduct from your account the amount of the fee and credit our account with the custodian in the amount
of the fees. Fees are billed quarterly in arrears. We do not charge fees in advance. Fees are non-refundable.
Other Fees and Expenses
You may pay other fees and expenses such as custodian fees (account servicing fees, commission on trades, transaction
costs, wire fees, etc.). See Item 12 below for more details of brokerage fees.
As part of our investment advice, we may recommend or select mutual funds for you. In addition to our fees, mutual
funds may charge you various management and other fees for investments.
You have the option to purchase investment products that our IAR(s) recommend through other brokers or agents that
are not affiliated with the Company.
Account Minimums and Types of Clients — Form ADV Part 2A (6/28/2016)
[Brochure]
Item 7. Types of Clients
We offer services to accredited investors and qualified purchasers as defined by the federal securities laws. These may
include the following types of clients:
• High net worth individuals and family offices
• Operating businesses
• Private investment companies
• Small to mid-sized banks and credit unions
• Trusts
• Non-profit entities
• Non U.S. citizens
The minimum account size of any retail client is negotiable.
Part 2 A of Form ADV: Firm Brochure 7 March 31, 2016
For retail clients, accounts must be held at a qualified custodian designated for retail clients. The respective custodian
has its own account opening, maintenance and compliance requirements. Each account must be approved by the
respective custodian.
For institutional clients, the Company may be retained as an investment manager over a client account at a financial
institution which the Company may or may not have an existing relationship. The minimum account size for institutional
clients is negotiable.
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)
0
0.0
(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