Fees and Compensation — Form ADV Part 2A (3/30/2026)
[Brochure]
Item 5. Fees and Compensation
Separate Accounts
The Adviser charges each separately managed account client an investment advisory fee based on the
market value of the account’s assets under management.
For managed account clients, the Adviser typically charges an advisory fee at an annual rate of up to
1.00%. The fee is charged each quarter based upon a percentage of the market value of the account’s
assets under management as of the last day of each quarter. Fees are billed in arrears, following the
end of the quarter for which services were rendered. Alternatively, the fee will be calculated on a pro-
rata basis in the event that the first or last quarter during which the agreement is in effect is less than a
complete calendar quarter or in those instances where there is a significant principal addition or
withdrawal during the quarter.
The Adviser reserves the right to determine the annual advisory fee rate and/or the manner of
payment with any managed account client or prospective managed account client. As a result, fees
may be negotiable under certain circumstances or for certain managed accounts. The Adviser bills
managed account clients and deducts the fee automatically from their accounts when agreed upon
with the clients. In the event of termination, the Adviser is entitled to fees earned through the effective
date of termination.
It should be noted that the Adviser’s fees are exclusive of brokerage commissions, transaction fees
and/or other related costs and expenses which may be incurred by the client. Clients may also incur
charges imposed by custodians, brokers and/or other third parties, such as: custodial fees, transfer
taxes, wire transfer and electronic fund fees.
Private Fund
The private fund for which the Adviser serves as investment manager generally pays a
management fee at an annual rate of 0.90% of the fund’s net assets as of month end. The
management fee is billed monthly in arrears and is debited from each investor’s capital account. More
detailed information about the fees and expenses related to the private fund may be found in the
governing documents of the private fund.
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 other investment advisers, individuals, family offices, registered
investment companies, private funds, pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations, and other business entities.
The Adviser typically requires its managed account clients to invest a minimum of $50 million, which
is subject to waiver by the Adviser, to open an account. The initial and additional subscription
minimums for the Adviser’s private fund are disclosed in the private placement memorandum for the
private fund.
Filed 2025-12-11 (D/A) · Exemption 3(c)(1), 506(b), 3(c) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
0
0.2
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
2
0.6
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
2
0.4
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
5
0.5
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.4
(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