FEES AND COMPENSATION
A. Platform Fees
Guggenheim Fund Solutions will charge fees to each Fund that are based on a percentage of net assets
under management (“Platform Fees”). The Platform Fee charged to investors in each Fund may vary if
an investor invests more money in one or more Funds. Guggenheim Fund Solutions may, at its discretion,
waive or reduce such fees for large or strategic investors.
Additionally, in the event GFS retains a Portfolio Manager to manage a Fund, it is expected that such
Portfolio Manager will also charge a management fee (the “Management Fee”) and performance fee (the
“Performance Fee” to the Fund it manages.
B. Charging Fees
Guggenheim Fund Solutions calculates and deducts the Platform and the Management Fees from the
Funds. Such fees are charged daily, weekly or monthly, as described in more detail in each Fund’s
relevant governing documents. Accounts initiated or terminated during the relevant periods will be
charged a pro-rated fee. The Performance Fees are generally accrued monthly and paid quarterly or
annually.
In certain share classes of the Funds, the Platform and the Management Fee may be combined to provide
one asset-based fee for a particular investor or share class.
C. Other Fees and Expenses
Unless otherwise agreed, each Fund, directly or indirectly, also will pay out of its assets all of its ordinary
and extraordinary expenses which, depending on the nature of the Fund as well as the specific services
to be provided by GFS, may include, but are not limited to: (i) all investment expenses; (ii) all fees and
expenses of transactional, risk, market data and trade-related services and information feeds; (iii) all
administrative expenses; (iv) all of the charges and expenses of legal advisers, accountants and auditors;
(v) all brokers’ commissions, all fees for investment research and/or trade ideas, all borrowing charges
on securities sold short and any issue or transfer taxes or stamp duties chargeable in connection with
securities transactions; (vi) all taxes and corporate fees and levies payable to governments or agencies or
regulatory bodies and the costs of preparing tax returns; (vi) all trustee and directors expenses; (vii) all
interest on borrowings, including borrowings; (viii) the fees associated with all regulatory filings and the
costs of preparing such filings, including, without limitation, Form PF, CPO-PQR.; (ix) all of the costs
of insurance for the benefit of the directors and officers of GFS (if any); (x) all litigation and
indemnification expenses and extraordinary expenses not incurred in the ordinary course of business; (xi)
certain expenses that were incurred by Portfolio Managers on behalf of the Funds for purposes of
operating such Fund and managing its assets in accordance with the terms of the IMA; and (xi) all other
organizational and operating expenses, including, without limitation, internal and external legal costs
associated with the review of the Funds’ trading facilities and account documentation.
Each Fund may also reimburse GFS for its portion of organizational expenses associated with the creation
and launch of that new Fund.
D. Timing of Fee Payments
As described above, Platform and Management Fees are charged monthly, weekly or daily in arrears.
Accounts initiated or terminated during the relevant periods will be charged a pro-rated fee.
E. Payments to Supervised Persons
GFS has entered into a placement agreement with an affiliated entity, Guggenheim Investor Services, LLC
(“Guggenheim Investor Services” or “GIS”). GIS is a registered broker-dealer and certain employees of
Guggenheim Fund Solutions are also registered representatives of GIS. Although GIS does not charge
commissions, some of the discretionary year-end bonus compensation received by such employees may
be based upon the total amount of assets raised.
The practice of compensating employees or affiliates for soliciting investors to the Funds based upon the
amount of assets they raise for such Funds presents a conflict of interest, as it gives Guggenheim Investor
Services or Guggenheim Fund Solutions or their respective employees an incentive to recommend
investments based on the compensation received, rather than on an investor’s needs. Guggenheim Fund
Solutions generally seeks to minimize this conflict of interest by limiting the portion of an employee’s
compensation directly based upon assets under management. Moreover, each Fund’s prospectus contains
necessary disclosure of such conflicts.
GFS charges a Platform Fee (as defined in Item 5 above) to each Fund. GIS does not charge commission
fees. Therefore, GFS does not reduce its Platform Fees for commissions relating to the amount of assets
raised by shared employees of GFS and GIS. Although GFS and GIS do share employees, such employees
are not compensated for their placement agent or other broker-dealer activities through commissions, but
rather through a discretionary year-end bonus, as determined by GFS. Such discretionary bonus is not
charged to investors in any Funds.