Fees and Compensation — Form ADV Part 2A (3/30/2026)
[Brochure]
Item 5. Fees and Compensation
Asset-Based Compensation
The Adviser may be paid a monthly asset-based investment management fee (“Management Fee”) at an
annual rate up to 2.0% of the value of each investor’s assets in the separately managed accounts.
The Management Fees will be calculated and paid in advance based on the total value of each investor’s
assets in the separately managed accounts on the first day of each month and will be prorated for any
capital contributions or withdrawals by an investor within a month.
These fees are generally not negotiable, however, the Adviser, in its sole discretion, may waive or modify
the Management Fee for certain investors. Such investors will be subject to other investment expenses
discussed below.
Performance-Based Compensation
The Adviser may also receive performance-based compensation, by way of an annual incentive fee, which
is 20% of the net profits, if any, during the fiscal year, attributable to a client’s assets, subject to a loss
carryforward provision. This incentive fee is paid to the Adviser.
This incentive fee is generally not negotiable; however, the Adviser, in its sole discretion, may waive or
modify the incentive fee for certain investors.. Such investors will be subject to other investment expenses
discussed below.
Other Fees and Expenses
In addition to paying Management Fees and performance-based fees, all investors may also be subject to
other investment expenses such as fund legal, fund compliance (including consultants’ fees), administrator,
audit and accounting expenses (including third party accounting services); investor reporting expenses;
organizational expenses; out-of-pocket expenses of members of the Review Committee; investment
expenses such as commissions, interest on margin accounts and other indebtedness; borrowing charges on
securities sold short; custodial fees; and bank service fees.
Please refer to Item 12 of this brochure for a discussion of the Adviser’s brokerage practices.
Neither the Adviser or any of its supervised persons accept compensation for the sale of securities or other
investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/30/2026)
[Brochure]
Item 7. Types of Clients
The Adviser’s Clients consist of separately managed accounts.