Gargoyle Investment Advisor LLC

Item 5: Fees and Compensation
In consideration for Gargoyle’s advisory and other services, Gargoyle generally is entitled to receive management
fees, and may receive performance-based fees. While the fees and compensation applicable to each Client are
described in detail in the applicable governing documents and/or Management Agreements, an overview of
Gargoyle’s basic fee schedule is summarized below. A potential investor should read and review all governing
documents in their entirety before making any investment decisions.

Fee Schedules

Funds

        Management Fees: In consideration for its advisory services to the Funds, Gargoyle receive a “Management
        Fee” from each respective Fund. The specific payment terms and other conditions of the Management Fees
        available to Gargoyle are set forth in the applicable Fund’s governing documents, side letters and/or
        Management Agreements. The Management Fees are generally equal to one percent (1.00%) per annum of
        a Fund’s assets managed by Gargoyle, on the appraisal date. Management Fees are prorated and payable
        monthly in arrears. Management Fees are generally paid to Gargoyle by deducting such fees from the
        applicable Fund, as provided in the applicable Fund’s governing documents. Notwithstanding anything to
        the contrary preceding, the General Partner and any Fund investor who are affiliates of Gargoyle or the
        General Partner will be excluded from the calculation of, and will not be required to fund any portion of, the
        Management Fee.

        Gargoyle and its affiliates will benefit from Gargoyle’s relationship with and its receipt of Management Fees
        from the Funds. Such Management Fees and relationship will enhance the value of Gargoyle, and the Fund
        investors (other than those Fund investors holding direct or indirect interests in Gargoyle) will not participate
        in any increase in the value of Gargoyle.

        Performance-Based Compensation: Additionally, Gargoyle may receive “Performance-Based Fees” (e.g.,
        performance allocation or incentive fees) in connection with the management of each respective Fund. The
        specific payment terms and other conditions of the Performance-Based Fees available to Gargoyle or the
        General Partner are set forth in the applicable Fund’s governing documents, side letters and/or Management
        Agreements. The Performance-Based Fees are generally equal to twenty percent (20%) of a Fund investor’s
        net performance. However, new GEA Fund investors are charged a reduced Performance-Based Fees of
        fifteen percent (15%). Performance-Based Fees payable to Gargoyle or the General Partner are payable
        annually in arrears or upon redemption. All Performance-Based Fees payable to Gargoyle or the General
        Partner will be consistent with the requirements of Section 205 of the Advisers Act and Rule 205-3
        thereunder.

        Performance-Based Fees payable to Gargoyle on investment gains may create an incentive for Gargoyle to
        cause a Private Fund to make investments that are riskier or more speculative than would be the case if a
        performance-based compensation arrangement were not in effect. The Performance-Based Fees may create
        an incentive for Gargoyle to time investments, and the realization of investments, so as to maximize
        Performance-Based Fees rather than the returns of the Private Fund. See Item 6 – Performance-Based Fees
        and Side-By-Side Management of this Brochure for more information about Performance-Based Fees.

        As of the date of this Brochure, Gargoyle manages three (3) Funds for which it receives Management and

Item 7: Types of Clients
As discussed in Item 4 of this Brochure, Gargoyle provides discretionary portfolio management and investment
advisory services to high net worth individuals, large institutions, endowments and foundations, and family offices
mainly through privately-offered pooled investment vehicles and separately managed accounts.

Funds: Information about the Funds, and the particular investment objectives, strategies, restrictions, guidelines and
risks associated with an investment in a Fund, is described in the respective Fund’s governing documents, which are
made available to investors only through Gargoyle or another authorized party. Each Fund’s minimum investment
amount is stated in each respective Fund’s governing documents. Each Fund’s respective General Partner may waive
the applicable minimum at their discretion. In addition, Gargoyle reports its minimum investment limits required of
an investor for each Fund in Schedule D, Section 7.B.(1) – Private Fund Reporting of Part 1 Form ADV, which is
available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Gargoyle is
152525.

Generally, investors participating in the Funds are required to meet certain suitability and net worth qualifications,
such as being either (i) an “accredited investor” within the meaning of Rule 501(a)(1), (2), (3) or (7) of Regulation D
under the Securities Act and that, in each case, are also a “qualified purchaser” as defined in Section 2(a)(51) of
the1940 Act; or (ii) a non-U.S. person in accordance with the requirements of Regulation S under the Securities Act
and applicable eligibility requirements of the respective Fund; and (iii) in accordance with any other applicable law.
As such, the Funds, Gargoyle manages are exempt from registration as an investment company through the exemption
provided by Section 3(c)(7) of the 1940 Act.

To help the U.S. Government fight the funding of terrorism and money laundering activities, Gargoyle may seek to
obtain, verify, and record information that identifies each investor who invests in a Fund. In this regard, when an
investor seeks to open an account with Gargoyle or invest in a Fund managed by Gargoyle (including a separately
managed account), Gargoyle may ask for a completed Form W-8/W-9, as applicable, which includes the name,
address, Tax ID/Employer ID number (or any other registration number issued in the jurisdiction of location or
incorporation) and other reasonably required information that will allow Gargoyle to identify the investor. Gargoyle
may ask for information and documentation regarding source of funds to be invested. Gargoyle also reserves the
right to ask for more information regarding the individuals who are beneficial owners of the investor and/or exercise
control over the investor. Gargoyle may ask for the names of such beneficial owners and may also ask for address,
date of birth, and other information that will allow Gargoyle to identify such beneficial owners. Gargoyle may also
request such other information as may be necessary to comply with applicable law. Furthermore, Gargoyle may
verify any of the aforementioned information using third-party sources and may share that information as required
by applicable law or in connection with the execution of trades on behalf of that investor. For certain investors,
Gargoyle may rely on the investor’s broker-dealer, administrator, transfer agent, custodian or placement agent to
obtain, verify and record the required information.

Separate Accounts: As a condition for starting and maintaining an investment management relationship through an
Separate Account, Gargoyle generally imposes a minimum portfolio size of $50,000,000. Gargoyle, in its sole
discretion, may accept Clients with smaller portfolios based upon certain criteria, such as anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing client relationships, account retention and pro bono activities. Gargoyle only accepts
Separate Account Clients with less than the minimum portfolio size if, in the sole opinion of the Gargoyle, the smaller
portfolio size will not result in a substantial increase of investment risk beyond the Client’s identified risk tolerance.

Form ADV Part 2A Brochure | Gargoyle Investment Advisor L.L.C.                                        March 31, 2019