Fees and Compensation — Form ADV Part 2A (2/25/2022)
[Brochure]
Item 5 - Fees and Compensation
A. Below is a discussion of how the Adviser is compensated in connection with
providing advisory services to its Client. The Adviser may enter into different fee
arrangements on a Client by Client basis.
Management Fees. The fees and expenses associated with each Client account will be
negotiated with each Client and are described in detail in each Clients Offering
Documents. Generally, the Adviser will not be entitled to a management fee, but an
Expense Payment Amount will be allocated as provided to the Client in the respective
investment management agreement.
Performance Allocation. The Adviser is entitled to a performance-based profit
allocation at the end of each performance calculation period, equal to seventeen percent
(17%), based on net profits (the “Performance Allocation”).
Direct Client Expenses. Client(s) is responsible for all direct expenses related to its
operations and activities, including all of its expenses associated with its investment
portfolio, including brokerage commissions and other transaction costs. Client(s) bears
the full cost of expenses related to proxies, underwriting and private placements,
brokerage commissions, interest on debit balances or borrowings, custody fees and any
withholding or transfer taxes imposed on the Managed Account(s).
B. Performance Allocations from the Managed Account are deducted directly from the
Client’s capital and payable monthly in advance.
C. Client(s) will incur brokerage and other transaction costs. Item 12 of this brochure
discusses how the Adviser selects brokers and determines the reasonableness of their
compensation. The direct expenses borne by each Client are described in more full
detail in each Client’s Offering Documents.
D. As stated above, expense payments paid monthly in advance based on the Managed
Account percentage of the Adviser’s assets under management. Upon termination of an
advisory contract, a Managed Account shall pay a draw prorated through the end of the
foregoing notice period.
E. Other than as described above, neither the Adviser nor any of its supervised persons
receives any compensation from the sale of securities or other investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (2/25/2022)
[Brochure]
Item 7 - Types of Clients
As mentioned in Item 4, the Adviser provides investment advisory services and sub-advisory
services to one sub-advised account.
Acceptance of Client(s) and sub-advisory account relationships is determined on a case-by-case
basis.