Item 5: Fees and Compensation
A. Adviser is compensated for its advisory services by flat fees charged based on a client’s assets
under management with Adviser. Fees are negotiable, and each client’s specific fee schedule is
included as part of the investment advisory agreement signed by Adviser and the client.
Adviser’s standard fee schedule is included below, subject to negotiation with a client:
Client Assets Under Management Annual Fee
(billed quarterly)
Less than $4,000,000 $5,000
From $4,000,000 to $7,500,000 $15,000
From $7,500,001 to $50,000,000 $25,000
From $50,000,001 to $75,000,000 $50,000
More than $75,000,000 $100,000
B. Fees are deducted in advance on a quarterly basis from clients’ assets, or clients may
alternatively elect to pay via check or ACH. Client family members (defined to include a client’s
spouse and children) shall have their respective managed assets aggregated for purposes of
calculating the applicable annual fee.
C. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs.
Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other
transaction-related practices. Clients will also typically incur additional fees and expenses
imposed by independent and unaffiliated third-parties, which can include qualified custodian fees,
mutual fund or exchange traded fund fees and expenses, mark-ups and mark-downs, spreads
paid to market makers, wire transfer fees, check-writing fees, early-redemption charges, certain
deferred sales charges on previously-purchased mutual funds, margin fees, charges or interest,
IRA and qualified retirement plan fees, and other fees and taxes on brokerage accounts and
securities transactions. Clients will also incur separate fees charged by any Third-Party Advisers
recommended or selected by Adviser, and such fees shall be memorialized in a separate written
agreement with such Third-Party Adviser. These additional charges are separate and apart from
the fees charged by Adviser.
D. If Adviser or client terminates the advisory agreement before the end of a quarterly billing period,
Adviser’s fees will be prorated through the effective date of the termination. The pro rata fees for
the remainder of the quarterly billing period after the termination will be refunded to the client.
E. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities
or other investment products.
Date of Brochure: February 1, 2024