O'Neil Global Advisors Inc

Item 5: Fees & Compensation
  A. Describe how you are compensated for your advisory services. Provide your fee schedule.
     Disclose whether the fees are negotiable.
         a. OGA charges both an asset-based management fee and receives performance-based
             incentive compensation on the performance of the Funds or SMAs that it advises.
             Depending on the characteristics of the account, fees are generally negotiable and may
             be different than what is stated herein. The specific fees charged to Funds and SMAs
             are set forth in the operating document for the Fund or the investment management
             agreement for the SMA. A brief summary of the fees OGA charges is provided below:

         b. Management Fee - OGA charges a fee for investment management services (the
             “Management Fee”) to the Funds. The Management Fee for a Fund is determined by
             the costs associated with implementing the strategy for the investor(s), the size of the
             account, and other factors. The Management Fee for SMAs generally range between
             0.00% to 2.00% per annum of Client assets under management. SMA fees and expenses
             are described in the SMA investment management agreement.

         c. Performance Incentive Compensation – OGA receives performance-based incentive
             compensation (the “Performance Fee”) for its services, which generally ranges from 10%
             to 40% of net realized and unrealized profits. Performance fees may be based on
             absolute or benchmark relative returns and may be subject to high water marks.

         d. OGA does not charge a performance fee for employees that invest in the Funds and for
             some accounts of OGA affiliates.

                                                                        Form ADV Part 2 – Firm Brochure

B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients
   may select either method, disclose this fact. Explain how often you bill clients or deduct your
   fees.
       a. For investors in SMAs, OGA generally bills investors for Management Fees on a monthly
          basis. Management Fees and Performance Fees for the Funds are deducted directly
          from the Fund’s assets.

        b. Management Fees are generally billed or deducted on a monthly basis and Performance
            Compensation is generally deducted on an annual or quarterly basis.

C. Describe any other types of fees or expenses clients may pay in connection with your advisory
   services, such as custodian fees or mutual fund expenses. Disclose that clients will incur
   brokerage and other transaction costs, and direct clients to the section(s) of your brochure
   that discuss brokerage.
       a. In addition to the Management Fee and Performance Compensation described above
           investors in OGA’s Funds and SMAs may incur other expenses and fees
                 i. Investment Expenses (such as without limitation transaction fees, brokerage
                    commissions, banking fees, interest, and custodial fees)
                ii. Research Expenses (such as without limitation computer software, cloud
                    computing services, data provider services, and licensing costs).
               iii. Administrative Expenses (such as, without limitation, legal, accounting,
                    auditing, account administration, and tax preparation expenses)
               iv. Startup Expenses (such as, without limitation, legal fees, fund organization
                    costs, and account setup charges)
                v. Regulatory Expenses (such as, without limitation, registration fees, tax
                    reporting fees, and compliance monitoring expenses).

        b. Please refer to Item 12 for a description of OGA’s brokerage policies.

D. If your clients either may or must pay your fees in advance, disclose this fact. Explain how a
   client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the
   end of the billing period. Explain how you will determine the amount of the refund.
        a. OGA’s Management Fee is generally billed and payable monthly in advance, based on
            the value of an investor’s account at the end of the previous month. If the investment is
            entered at any time other than the first day of a calendar month or terminated prior to
            the end of a calendar month, OGA fees will apply on a pro rata basis. Any prepaid but
            unearned fees will be refunded.

E. If you or any of your supervised persons accepts compensation for the sale of securities or
   other investment products, including asset-based sales charges or service fees from the sale of
   mutual funds .

                                                                          Form ADV Part 2 – Firm Brochure

          a. Neither OGA nor any of its supervised persons accepts compensation for the sale of
              securities or other investment products, including asset-based sales charges or service
              fees from the sale of mutual funds.

Item 7: Types of Clients
  A. Describe the types of clients to whom you generally provide investment advice, such as
     individuals, trusts, investment companies, or pension plans. If you have any requirements for

                                                                        Form ADV Part 2 – Firm Brochure

      opening or maintaining an account, such as a minimum account size, disclose the
      requirements.
          a. OGA manages Funds whose investors consist of high net worth individuals and
             institutions. OGA’s investors for its SMAs consist of corporations, trusts, and
             foundations.

          b. Generally, the minimum account size to open a SMA is USD $10,000,000 depending on
             the strategy employed and other factors.

          c. OGA reserves the right to waive investment minimums for particular investors at its
             discretion.