Fees and Compensation — Form ADV Part 2A (3/3/2020)
[Brochure]
Item 5: Fees and Compensation
Item 5.A.
Gideon Capital is not paid a management fee. The Firm is compensated by each Fund through a pre-
negotiated monthly compensation draw. Additionally, the Funds will pay to Gideon Capital an annual
performance fee based on the net appreciation of the assets held by the client accounts. Please see Item 6
below for further detail.
Item 5.B.
Fees are not automatically deducted from the Funds. Gideon Capital bills the applicable Fund on a
monthly basis for fees incurred. The Firm is compensated pursuant to advisory agreements that were
individually negotiated with each Fund.
Item 5.C.
The Funds pay for all costs and expenses directly related to infrastructure, data and investment transactions,
including brokerage commissions, interest expenses and custody and transfer fees. The Funds would also be
responsible for fees and expenses directly related to any investment products utilized by Gideon Capital such
as Exchange Traded Funds (“ETFs”). Please see the disclosures in Item 12 as it relates to Gideon Capital’s
brokerage activities.
Item 5.D.
Any fees and expense draws are paid in arrears.
Item 5.E.
Gideon Capital and its supervised persons are not compensated by the Funds for the sale of securities or
other investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/3/2020)
[Brochure]
Item 7: Types of Clients
Gideon Capital provides portfolio advisory services to the Funds based on its investment objectives and
not based on the criteria or investment objective of any individual investor in the Funds. In the future,
Gideon Capital may provide advisory services to managed accounts or additional privately offered
investment funds.
Currently, Gideon Capital has no established minimum account size for clients or client accounts,
although its advisory clients would generally be sophisticated institutional investors, high net worth
individuals or family offices.