Item 5: Fees and Compensation
Fees and other charges
Individually Managed Accounts:
Keelan Capital bases its fees on a percentage of assets under management per annum.
Fees for individually managed accounts are tier priced as follows:
Account Size Fee (Annual percentage)
$0 - $5,000,000 1.00%
$5,000,001 - $50,000,000 0.50%
$50,000,001+ Negotiable
The management fee will be based on the average daily balance for the preceding month as reported by
the custodian. All asset-based fees are deducted by the qualified custodian of record on a monthly basis
in arrears, or as otherwise indicated in the client agreement. For example, a client with $15,000,000
assets under management with Keelan Capital will be charged 1% (1%÷12) on the first $5 million, 0.5%
(.50%÷12) on the next $10 million at the end of the last business date of the month. Current clients of
Keelan Capital have been grandfathered into a previous fee schedule and billing cycle in which they are
charged based on the average daily balance for the preceding quarter, on a quarterly basis.
For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the agreement
is terminated, the fee for the final billing period is prorated through the effective date of the termination
and the unearned portion of the fee is charged to the client, as appropriate.
The Firm, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria
(e.g., historical relationship, types of assets, anticipated future additional assets, dollar amounts of assets
to be managed, related accounts, account composition, etc.).
• Sub-Adviser Fees
Keelan Capital bases its sub-adviser fees on a percentage of assets under management per annum. Fees
for sub-advised accounts are tier priced as follows:
Account Size Fee (Annual percentage)
First $25 million 0.20%
Next $25 million 0.15%
Next $25 million 0.10%
Next $25 million 0.08%
Over $100 million 0.05%
The management fee will be based on the average daily balance for the preceding quarter as reported by
the custodian. All asset-based fees are deducted by the qualified custodian of record on a quarterly basis
in arrears, or as otherwise indicated in the client agreement with the principal advisor.
Certain principal advisors have been grandfathered into a lower fee schedule and/or a quarterly flat fee
schedule. New clients engaging Keelan Capital for our sub-advisory services shall be charged according
to the above fee schedule. Certain sub-advised accounts are also grandfathered into a previous agreement
in which advisory fees are not passed on to the customer for payment. As of the date of this brochure,
Keelan Capital is no longer accepting new sub-advised accounts under the previous agreement.
Keelan Capital offers preferential advisory fees to sub-advised clients, however, sub-advised clients are
also paying an advisory fee to their main advisor.
• Third Party/ Custodian Fees
In addition to the advisory fees paid to Keelan Capital, clients also incur certain charges imposed by
other third parties, such as broker-dealers, custodians, trust companies, banks, private funds, and other
financial institutions (collectively “Financial Institutions”). These additional charges include securities
brokerage commissions, fund management fees, transaction fees, custodial fees, margin costs, fees
attributable to alternative assets utilized by the Independent Managers, reporting charges, fees charged
by the Independent Managers, charges imposed directly by a mutual fund or ETF in a client’s account,
as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred
sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees
and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are
described at length in Item 12, below.
Keelan Capital will provide investment advisory services and portfolio management services but will
not provide custodial or other administrative services. At no time will the Firm accept or maintain
custody of a client’s funds or securities except for authorized fee deduction. The Client may contact the
Custodian directly for disbursements, or account record changes, and may also do so in writing to the
custodian. The Firm may act at the client’s convenience to facilitate such written communications to the
Custodian, provided that such action is not construed to be custody of client assets.
Right of Cancellation
In addition to the right to terminate an agreement pursuant to its terms, a client may cancel an agreement
with Keelan Capital within five (5) business days of first receiving a copy of this disclosure brochure
and supplement without penalty or fee.
Commissionable Securities Sales
Our firm does not sell securities for a commission in advisory accounts.