Fees and Compensation — Form ADV Part 2A (3/2/2026)
[Brochure]
Item 5: Fees and Compensation
F. Important Disclosure – Custodian Investment Programs
Please be advised that the firm utilizes certain custodians/broker-dealers. Under these
arrangements we can access certain investment programs offered through such custodian(s)
that offer certain compensation and fee structures that create conflicts of interest of which
clients need to be aware. Please note the following:
Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain
programs in which we participate where a client’s investment options may be limited in certain
of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees
and other revenue sharing fee payments, and the client should be aware that the firm is not
selecting from among all mutual funds available in the marketplace when recommending
mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds:
Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and
generally, all things being equal, cause the fund to earn lower rates of return than those mutual
funds that do not pay revenue sharing fees. The client is under no obligation to utilize such
programs or mutual funds. Although many factors will influence the type of fund to be used, the
client should discuss with their investment adviser representative whether a share class from a
comparable mutual fund with a more favorable return to investors is available that does not
include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs
and priorities and anticipated transaction costs. In addition, the receipt of such fees can create
conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or
revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it
may elect to provide to the firm, even though such benefits may or may not benefit some or all
of the firm clients.
Part 2A of Form ADV: Orchard Capital Management, LLC Brochure
Account Minimums and Types of Clients — Form ADV Part 2A (3/2/2026)
[Brochure]
Item 7: Types of Clients
Orchard Capital offers its investment services to various types of clients including individuals,
high net worth individuals, trusts, corporations, partnerships, corporate pension and profit
sharing plans, foundations, and a UCITS fund.
Orchard Capital generally requires a minimum account size of $1 million. Account minimums
may be waived under the firm’s discretion due to asset mix, client guidelines/restrictions, or
relationship.
Part 2A of Form ADV: Orchard Capital Management, LLC Brochure