Item 5 – Fees and Compensation
The fees applicable to each Fund are set forth in detail in each Fund’s offering documents. A brief
summary of such fees is provided below.
For certain Funds, the Adviser charges an investment management fee at an annual rate of from
1.5% to 2.00%, calculated and paid each month in advance (the “Management Fee”), depending
on the share-class of the Investor. If an investor is permitted to subscribe as of a date other than
the first day of a calendar month, the relevant Management Fee for such partial month will be
prorated. The Funds will not refund any portion of the Management Fee previously paid with
respect to any intra-month withdrawal.
The Adviser or the General Partner, may also receive a performance-based fee or allocation for the
management of certain of the Funds which is based on a share of capital gains or appreciation of
the assets of the Fund. Performance-based compensation ranges from 15% to 20%, subject to a loss
carry-forward provision and depending on the share-class the Investor subscribed for.
Performance-based compensation is generally taken at the end of each calendar year.
Note that as of the date of this Brochure, the share-class subject to a Management Fee of 1.5% per
annum, and a performance-based fee or allocation of 15%, are open to new Investors.
Neo Ivy, or the General Partner, in their sole discretion, may elect to reduce or waive the
performance-based fee or allocation, or the Management Fee with respect to any Investor,
including, without limitation, an Investor that is a partner, member or employee of the Adviser,
the General Partner, or such person’s family members and trusts, or other entities established for
the benefit of such person or his or her family members.
Management Fees and performance-based fees or allocations are described in greater detail in the
offering documents of the Funds.
The Investment Adviser and any affiliates each pay its own overhead and ordinarily recurring
operating expenses, such as rent, utilities, supplies, secretarial expenses, employee compensation
and benefits, including insurance, payroll, and other taxes and related costs, and charges for
furniture, fixtures, and equipment.
All other expenses are borne by the Funds and are allocated generally, in a pro-rata fashion, based
on asset size of each Fund to the extent an expense is incurred by multiple Funds. Expenses borne
by the Funds include: ordinary and extraordinary expenses, including (i) ordinary expenses, which
may include, without limitation, the initial organizational expenses of the Fund; the expenses of
the ongoing offering of Interests; filing fees, legal, bookkeeping, accounting, auditing,
recordkeeping, administration, computer and clerical expenses (including expenses incurred in
preparing reports and tax information to certain Investors and expenses for specialized
administrative services); Management Fees; regulatory compliance costs; costs and expenses of
any third party valuation agent; printing and duplication expenses; investment related travel
expenses; investment research; investment research related travel expenses; consulting and/or
statistical services expenses; market data, newswire and data processing expenses; software and
Neo Ivy Capital Management, LLC Form ADV Part 2A Brochure
connectivity charges; brokerage commissions, bank charges, custody fees and borrowing costs;
exchange, board of trade or other trading or execution facility members or participation expenses;
the cost of maintaining the Fund’s legal existence and expenses; liability insurance (including
errors & omissions insurance) costs; investment and operating expenses; and such other expenses
necessary to perform the operation of the Funds as determined by the Adviser or its affiliates; and
(ii) extraordinary expenses, which may include, without limitation, taxes, indemnification costs,
litigation costs, trade errors or damages. The Funds will also pay or reimburse the Adviser for the
Fund’s pro-rata portion of the regulatory and compliance costs of the Adviser arising out of the
Investment Adviser’s management of the Fund, such as legal, administrative, and filing costs and
expenses relating to the Adviser’s SEC Form ADV and Form PF, if applicable.
Neo Ivy may, in its sole discretion, bear any of the Funds’ expenses described above; provided
that, if Neo Ivy does pay any such expenses, it will not be required to continue to pay such expenses
and may thereafter cause the Funds to pay such expenses.
The allocation of expenses by the Adviser between it and any Fund and among Funds represents a
conflict of interest for the Adviser. Neo Ivy has adopted an expense allocation policy that is
designed to address this conflict. The Adviser allocates expenses to each Client in accordance with
the Client's arrangements with the Adviser. Neo Ivy seeks to allocate shared expenses for products
and services benefitting the Adviser and a Fund, and not covered in the Client's arrangements in a
fair and reasonable manner. The Adviser generally allocates common Fund expenses among
multiple Funds or Clients pro rata based on assets under management.
More detailed information regarding the fees and expenses paid by the Funds may be found in the
offering documents of the Funds.
Neither the Adviser nor its employees accept compensation, including sales charges or service
fees, from any person for the sale of securities or other investment products.
Neo Ivy Capital Management, LLC Form ADV Part 2A Brochure