ITEM 5: FEES AND COMPENSATION
Grow Funds, LLC March 30, 2026
Form ADV Part 2A
A. Compensation for Advisory Services
As described in greater detail below, GROW charges different types of fees, including fees based
on a percentage of assets under management and performance-based fees. The specific fees
charged by GROW for its services will be set forth in the Client’s Agreement.
Fees may be negotiable under certain circumstances at the sole discretion of GROW. In addition,
GROW has full discretion to reduce or waive its advisory fees in their entirety. Although GROW
believes its advisory fees are competitive, Clients should be aware that lower fees for
comparable services may be available from other sources.
1. Assets Under Management and Performance-Based Fees
a. Separately Managed Accounts
The Firm provides Investment Management and Pension Consulting Services to Clients for a fee
based upon a percentage of assets under management, including cash and cash equivalents, as of
the close of business on the last business day of the preceding calendar quarter. The Firm’s
portfolio management fees are calculated and assessed quarterly, in advance, based on a 1%
annual fee that is subject to negotiation on a case-by-case basis.
Investment management fees will be automatically deducted from the Client’s account by the
custodian as soon as practicable following the end of each applicable period. Should a Client
open an account during a quarter, the Firm’s management fee may be prorated based on the
number of days the account was open during the quarter. In the event the Firm’s services are
terminated mid-quarter, any paid, unearned fees will be promptly refunded to the Client. The
number of days the account was managed during the quarter until termination is used to
determine the percentage of the management fee earned (based on the total number of days in the
quarter) and the balance is refunded. Under some circumstances at the discretion of GROW,
fees may be waived until the first full quarter under management.
For purposes of calculating assets under management, GROW will consider all investment
management accounts which belong to familial Clients. Typically, a Client’s family members
consist of any spouse, parent, child, partner or sibling. Clients will be requested to notify GROW
of any such familial relationships as part of the Client Agreement.
Advisory fees are negotiable and arrangements with any particular Client may differ from those
described above. In addition, for family and friends of the Firm, the Firm may, in its sole
discretion, reduce or waive management fees in their entirety.
At times, if requested by the Client and in the sole discretion of the Firm, GROW will assess fees
for its Investment Management or Pension Consulting Services on an annual flat-fee basis. The
flat-fee will be determined by examining such factors as the aggregate amount of Client assets
managed by GROW, as well as the complexity of the Client’s affairs (which may reflect certain
services which the Client needs above and beyond normal investment management services such
as estate, tax and insurance planning as well as specially tailored Client services.). The Client’s
Grow Funds, LLC March 30, 2026
Form ADV Part 2A
exact fees, and how such fees are charged by GROW, shall be explicitly stated in the Client’s
Agreement or an attachment thereof prior to services being provided.
The Firm may amend its standard fee schedule at any time by giving thirty (30) days advanced
written notice to Clients. Should a client have more than one account managed by the Firm, then
GROW may elect at its sole discretion to aggregate the Client’s accounts for the purpose of
computing management fees.
Although GROW believes its fees are competitive, Clients are hereby advised that lower fees for
comparable services may be available from other sources.
b. Pooled Investment Vehicles
i. Management Fees
Under the Firm’s investment management agreement with the Funds, GROW will receive a
quarterly investment Management Fee payable in advance, of up to 1% of the Fund’s net assets
allocable to limited partners as of the opening of business on the first day of such calendar
quarter (1% annualized), and as fully outlined in the respective Fund’s Offering Memorandum.
GROW, in its discretion, may waive or reduce the management fee as to all or any of the
investors in the Fund or agree with an investor to waive or alter the management fee as to that
investor.
If an investor withdraws all or a portion of its account in the Fund on a date other than the end of
a calendar quarter, a prorated management fee may be deducted from the amount withdrawn for
the period from the preceding quarter-end to the date of withdrawal.
ii. Performance-Based Fees
In addition, GROW reserves the option to assess a performance-based fee in the form of a
special allocation of net profit (an “Incentive Allocation”) equal to 20% of the net profits
(including both realized and unrealized gains and losses) allocated to limited partners of the
Funds. The Incentive Allocation is calculated and made annually as soon as practicable
following the end of each calendar year of the Fund.
The performance fee is payable only if, and to the extent that, the net capital appreciation of the
Client’s capital account exceeds the high-water mark established previously (as adjusted for
additions and/or withdrawals of capital). Additionally, the Funds may also impose a “hurdle
rate” that must be exceeded, in addition to the high-water mark, in order for the Incentive
Allocation to apply. The Incentive Allocation is only chargeable to limited partners eligible to
be charged performance-based fees under Section 260.234 of the California Code of Regulations.
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