Fees and Compensation — Form ADV Part 2A (3/29/2024)
[Brochure]
Item 5: Fees and Compensation
The fees applicable to the Separately Managed Account is set forth in detail in the Separately
Managed Account’s Investment Management Agreement. A summary of such fees is
provided below.
Separately Managed Account
Management Fees to be paid by the Separately Managed Account will be agreed upon
between Ironsides and the Separately Managed Account client at a negotiated rate with
disclosure to the Investors. Any fees to be borne by the SMA will be deducted directly from
the SMA’s account. The SMA does not bear any performance-based fee or allocation.
The Client bears its own organizational and initial offering expenses as well as its investment
and operating expenses including, but not limited to, brokerage commissions and other
transaction costs; clearing and settlement charges; custodial fees; margin and interest
expense and commitment fees on debit balances or borrowings; borrowing charges on
securities sold short; due diligence, research and travel expenses related to the Client’s
potential and actual investments; consulting, legal and other professional fees relating to
potential and actual investments; expenses of professionals providing services to the Client,
including legal, audit, accounting, tax and administration; organizational expenses; costs of
any liability insurance obtained on behalf of the Client; costs of any litigation or investigation
involving the Client’s activities; indemnification expenses; regulatory costs; any issue or
transfer taxes chargeable in connection with any securities transactions; any entity level
taxes; regulatory filing and license fees; costs of reporting and providing information to
Investors; and any extraordinary expenses. For further details on the Firm’s brokerage
practices, please refer to Item 12 of this Brochure.
Neither Ironsides nor its supervised persons accept compensation, including sales charges or
Ironsides Partners LLC Form ADV Part 2A: Brochure
service fees, from any person for the sale of securities or other investment products, including
interests in the Client. When Ironsides’ employees serve as directors on the board of
investee companies, any board fees received are paid to the Client.
Account Minimums and Types of Clients — Form ADV Part 2A (3/29/2024)
[Brochure]
Item 7: Types of Clients
The Firm currently manages the SMA. The Client currently consists of an Investor that is a
high net worth individual but may also include endowments, fund of funds, family offices,
pension plans, and other institutional investors in the future.
Investors in the Client must each be (i) an “accredited investor,” as defined in Regulation D
under the U.S. Securities Act of 1933, as amended (the “Securities Act”), and (ii) a “qualified
purchaser,” as that term is defined in Section 2(a)(51) of the U.S. Investment Company Act of
1940, as amended (the “1940 Act”).
Offered $200,000,000 · Filed 2017-11-01 (D) · Exemption 506(b), 3(c)(7) · Remaining $159,000,000 · Duration One year or less · Revenue Decline to Disclose
Filed 2016-02-02 (D) · Exemption 506(b), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Offered $125,000,000 · Filed 2013-02-25 (D) · Exemption 506, 3(c)(7) · Minimum $5,000,000 · Remaining $50,700,000 · Duration One year or less · Net Assets Decline to Disclose
Filed 2015-02-25 (D/A) · Exemption 506(b), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2015-02-25 (D/A) · Exemption 506(b), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2015-02-25 (D/A) · Exemption 506(b), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2015-02-25 (D/A) · Exemption 506(b), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
1
28.6
(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