Fees and Compensation
Description
Investment Management
Old West generally provides investment management services for a percentage of assets under management.
All fees are negotiable. Our standard investment advisory fee schedule is as follows:
Account Value Annual Fee Rate
On amounts up to the first $10 million: 1.00%
On amounts over $10 million up to $25 million: 0.75%
On amounts over $25 million up to $50 million: 0.65%
On amounts over $50 million up to $75 million: 0.55%
On amounts over $75 million up to $100 million: 0.50%
On amounts in excess of $100 million: 0.45%
For Old West Focused, Old West’s standard investment advisory fee (management fee) is a flat 2.00% on all
assets. For certain qualified clients at their option, Old West will charge a performance-based allocation with
a reduced management fee. Please see further discussion on the performance-based allocation below in the
Performance-Based Allocation and Side-by-Side Management section.
For limited partnerships, Old West charges a 1.00% management fee on all assets. Old West also receives
from Old West Investment Partners, LP (a long-short absolute return “hedge fund”), Old West Income
Fund, LP (an income-related return “hedge fund”) and Old West Opportunity Fund, LP (an opportunistic-
related return “hedge fund”) a performance-based allocation in addition to the management fee. Please see
further discussion on the performance-based allocation below in the Performance-Based Allocation and Side-by-Side
Management section.
Model Provider
Old West provides Model Provider services for an annual fee ranging from 0.40% to 0.50% of the assets
invested in the models. Fees are negotiable.
Fee Billing
Investment Management
Fees are payable quarterly in advance. Clients may negotiate to have quarterly fees paid in arrears rather than
in advance. Additionally, clients may negotiate to have fees invoiced rather than directly debited from the
account. For separately managed accounts that pay fees in advance, fees are calculated based on the market
value (including accrued interest) of each client’s assets under management at the close of business on the
last business day of the prior calendar quarter (normally 1:00 pm Pacific time). Fees are due no later than at
the close of the tenth business day of each calendar quarter. The Firm’s standard investment management
agreement provides that it may be terminated by either party upon 30 days’ written notice. For clients that
open or close accounts in the middle of a calendar quarter, fees will be prorated. For accounts billed in
advance, fees will be reimbursed to the client on a pro rata basis for the number of days in the quarter the
account was not under management. For those accounts that pay quarterly in arrears, any earned, unpaid
fees will be due and payable at the time the account is closed. Each client has the right to terminate an
investment management agreement without penalty within five business days after entering into the
agreement.
Model Provider
Fees are charged on a pro-rated quarterly basis in advance, determined by the market value of the assets
invested in the models as of the last day of the previous quarter. Envestnet will deduct the fees directly from
client accounts and remit the payment to Old West. For accounts that are opened or closed during a calendar
quarter, the fees will be prorated accordingly. For accounts billed in advance, fees will be reimbursed to the
client on a pro-rata basis for the number of days in the quarter the account was not invested in the model.
Other Fees
Clients will incur and are responsible for the fees and expenses in addition to Old West’s advisory fees,
including fees charged by the client’s custodians and imposed by broker-dealers. Such fees may include, but
are not limited to, custodial fees, transaction costs, fees for duplicate statements and transaction
confirmations, brokerage commissions, mutual fund expenses and fees for electronic data feeds and reports.
See the Brokerage Practices section for more information.
Performance-Based Fees & Side-by-Side
Management
Sharing of Capital Gains or Capital Appreciation
Old West is the general partner of Old West Investment Partners, LP (a long-short absolute return “hedge
fund”), Old West Income Fund, LP (an income-related return “hedge fund”) and Old West Opportunity
Fund, LP (an opportunistic-related return “hedge fund”). Fees for these Funds are described in each private
fund’s respective Private Placement Memorandum (“PPM”) and include brokerage commissions, as well as
other transaction and fund-related expenses. Old West Investment Partners, LP, Old West Income Fund, LP
and Old West Opportunity Fund, LP charge an asset-based fee investment advisory fee (management fee) of
1% as well as a performance-based allocation, which is based on the share of capital gains on or capital
appreciation of the assets of the Fund. The performance allocation is equal to 20% of the net capital
appreciation of each investor’s capital account in excess of the fund’s “preferred rate of return.” The
“preferred rate of return” for the Old West Investment Partners, LP and the Old West Income Fund, LP is
5% for each calendar year; the Old West Opportunity Fund, LP does not have a “preferred rate of return” or
rather the “preferred rate of return” is 0%. The performance allocation is payable only if, and to the extent
that, the net capital appreciation of the investor’s capital account exceeds any net capital depreciation
accumulated in prior years (as adjusted for withdrawals of capital). Old West, at its discretion, may waive all
or a portion of the performance allocation as to an investor, or may agree with an investor to other changes
to the performance allocation. Allocations based on performance will meet all requirements as specified
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