Item 5 - Fees and Compensation
(a) Advisory Fees and Compensation
The Adviser generally receives from each client an asset-based fee based on a percentage of the net asset value of the
client’s account. The annual percentage rate of such fee is generally between 0 percent and 1.50 percent of the value
of the net assets under management. The Adviser or its affiliate also may receive a performance-based fee (or, in the
case of certain collective investment funds, a performance allocation to the funds’ general partner) of up to 25 percent
of net appreciation of client account assets, including both realized and unrealized gains and losses.
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In certain cases, a client or investor and the Adviser may negotiate a fee rate that is higher or lower than the amounts
in the preceding paragraph, depending in whole or in part on the amount of assets to be managed, the amount and
complexity of client-specific investment restrictions, special reporting, and other services agreed to with the client or
investor, and whether the client or investor would be paying a management fee, performance-based fee, or both.
The fees that the Adviser charges clients of platforms that use the Adviser’s investment strategy models are based on
written agreements between the Adviser and the respective platforms. These fees can either be asset-based or flat-rate
fees.
In connection with arrangements for financial planning clients, there is no standard schedule of fees. The Adviser does
generally charge a fee for such non-discretionary advice. Such fees are negotiated on a case-by-case-basis based upon
factors which may include: size of the assets involved in the arrangement, complexity of the services provided, and the
nature and number of such services, each of which may vary substantially from client to client. To the extent that such
non-discretionary advice results in a client investing in a discretionary product managed by the Adviser, provisions are
made to avoid the double-charging of fees. To the extent that such non-discretionary advice results in a client investing
in an unrelated product or strategy, the client may bear additional fees and expenses in connection with such
investments.
(b) Payment of Fees
The Adviser’s management fees are typically calculated and payable monthly or quarterly in arrears, and performance-
based fees are typically calculated annually in arrears. Management fees due from the Adviser’s privately offered
collective investment funds, however, are typically paid monthly in advance and are not refundable to an investor in
case of a partial or full redemption during any month. In either case, the Adviser deducts management fees from the
assets in the client’s account unless the Adviser agrees with the client to bill the client directly for fees incurred. Sub-
advisory fees from certain clients are calculated daily and paid monthly in arrears.
Performance-based fees may create an incentive for the Adviser to make more risky and speculative investments than
it might otherwise make. See “Item 6 - Performance-Based Fees and Side-by-Side Management,” below, for more
information.
(c) Other Fees and Expenses
Clients are responsible for the costs and expenses of maintaining an account, including fees for custody of account assets,
brokerage costs, income and other taxes relating to the client, the client account, and/or the client’s portfolio, and the
costs of verification of account assets if verification is required. For more information on the Adviser’s broker selection
process, see “Item 12 – Brokerage Practices,” below. Client accounts that are invested in mutual funds and/or ETFs pay,
indirectly, investment advisory fees to the managers of those funds, in addition to amounts paid directly to the Adviser.
Clients that are collective investment funds are also responsible for fund-related costs, such as fund administration,
transfer agency, audit, taxes, and preparation of tax returns, costs of communications with investors, government fees,
and legal services. The Adviser bears only its own operating costs and expenses.
The Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable
services. Comparable services may be available, however, from other sources for lower fees.
(d) Additional Compensation and Conflicts of Interest
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No supervised person of the Adviser accepts compensation for the sale of securities or other investment products,
including sales of interests in collective investment funds managed by the Adviser.