Fees and Compensation — Form ADV Part 2A (3/31/2020)
[Brochure]
Item 5: Fees and Compensation
A. Fee Schedule
Performance-Based Fees for Portfolio Management
Qualified clients pay an annual fee of 1.25% of assets under management along with an
incentive fee that is calculated as follows:
The incentive fee is 25% of the closing net asset value in excess of the greater of (a) a
noncumulative annualized hurdle rate of 5% per annum or (b) the High-Water Mark,
which is defined as the maximum adjusted closing net asset value of all prior incentive
fee calculation dates. The closing net asset value shall be defined as the net asset value of
the account having deducted payments of the management fee and any other expense
reimbursements. The adjusted closing net asset value shall be defined as the closing net
asset value having deducted payment of all incentive fees. The High-Water Mark will be
subject to reduction for withdrawals on a pro-rated basis.
B. Payment of Fees
Payment of Performance-Based Portfolio Management Fees
Performance-based portfolio management fees are withdrawn directly from the client's
accounts with client's written authorization on an annual basis, or may be invoiced and
billed directly to the client on an annual basis. Clients may select the method in which
they are billed. Fees are paid in arrears.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by KGL. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
KGL collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation For the Sale of Securities to Clients
Neither KGL nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2020)
[Brochure]
Item 7: Types of Clients
KGL generally provides advisory services to High-Net-Worth Individuals.
There is no account minimum for any of KGL’s services.
Filed 2015-07-23 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2015-07-23 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · 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)
4
28.9
(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