Fees and Compensation — Form ADV Part 2A (3/31/2021)
[Brochure]
ITEM 5. FEES AND COMPENSATION
We receive compensation from our clients in the form of fees which may be based on a
percentage of assets under management, typically between 0.40% and 1.00% based on the
aggregate invested capital, subject to negotiation. Applicable account level fees will be
automatically deducted quarterly in arrears. Clients will also indirectly bear all fees
applicable under the governing documents of each underlying fund or investment vehicle.
Underlying Affiliated Funds are also subject to other transaction fees, asset-based fees, and
potentially performance fees and allocation, or other compensation in favor of affiliates of the
Registrant, in each case as disclosed in Item 11 under the heading “Conflicts of Interest” and
in the governing documents of the applicable underlying fund or investment vehicle.
See the disclosure in “Item 4 – Advisory Business” regarding the conflict of interest posed by
collecting fees at both the client level and the level of the funds we recommend. We also have
an incentive to recommend the funds for which we are paid higher fees relative to other
advised funds, but we attempt to mitigate the conflict by developing programs to allocate
among a mix of our funds.
Tradeaway/Custodian Fees: Relative to its discretionary investment management services,
when beneficial to the client, individual equity and/or fixed income transactions may be
effected through broker-dealers other than the account custodian, in which event, the client
generally will incur both the fee (commission, mark-up/mark-down) charged by the executing
broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account
custodian.
Separate Fees: All private investment funds and mutual funds (and exchange traded fund)
impose fees at the fund level (e.g. management fees and other fund expenses). These fees are
separate from, and in addition to, Registrant’s wealth management fee.
Fee Schedule: Clients pay tiered management fees quarterly in arrears based on their
aggregate account balance as of the commencement of each quarter. For purposes of
illustration, if a client has an aggregate balance of $10 million it would pay 1.00% on the first
$2 million, 0.80% on the next $3 million, and 0.60% on the remainder of its account balance.
Client Assets Under Management % of Assets
$0-2 million 1.00%, or a minimum of $7,500
$2-5 million 0.80%
$5-10 million 0.60%
More than $10 million Negotiable
Notwithstanding the foregoing, we generally waive the first quarter of fees for new accounts
and may waive other fees from time to time in our sole discretion without the obligation to
make any such waivers available to our clients generally.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2021)
[Brochure]
ITEM 7. TYPES OF CLIENTS
The Registrant’s clients generally include high net worth individuals, pension and profit-
sharing plans, business entities, trusts, estates and charitable organizations. The Registrant
generally requires a minimum asset base of $1,000,000.00 for investment advisory services.
The Registrant, in its sole discretion, may charge a lower investment management fee and/or
waive or reduce its minimum asset requirement based upon certain criteria (i.e., anticipated
future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, negotiations with client, etc.).
As result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower fees.
AUM Breakdown
Accounts
AUM ($k)
By Client Type
(a) Individuals (other than high net worth individuals)
2
250.9
(b) Individuals (high net worth individuals)
1
631.6
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(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