Fees and Compensation — Form ADV Part 2A (4/1/2026)
[Brochure]
Item 5: Fees and Compensation
Advisory Fees
PMAM receives advisory fees based on contractually specified percentages of the assets in each client’s investment
portfolio. Fees for advisory services are negotiable. The Firm’s clients are generally large institutional investors or qualified
purchasers, as defined in Section 2(a)(51)(A) of the Investment Company Act of 1940.
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Fee Waivers and Reimbursements
From time to time, the Firm may waive all or a portion of its advisory fee or reimburse a client when deemed appropriate or
as negotiated in writing. The terms and conditions of any such waivers or reimbursements are disclosed in the applicable
client agreements.
Portfolio Valuation and Fee Billing
In valuing client portfolios for fee‑billing purposes, PMAM generally relies on pricing information provided by independent
pricing vendors (Pricing Vendors). When a Pricing Vendor does not provide a price for a particular security or when market
quotations are not readily available, the Firm may determine a “fair value” for that security or instrument based on
information the Firm believes reasonably reflects its value.
Valuation-Related Conflicts of Interest
This practice presents a potential conflict of interest because the Firm could have an incentive to assign a value that
increases fees or reported investment performance. To address this conflict, the Firm has adopted written valuation
policies and procedures designed to promote fair and consistent valuation of such securities or instruments.
Treatment of Cash Balances
Cash balances, whether held at a client’s custodian or invested in third‑party investment funds, may be treated as
investment portfolio assets for purposes of calculating and determining advisory fees.
Registered Investment Companies
PMAM provides investment supervisory services to affiliated registered investment companies in an advisory capacity. The
Firm manages these portfolios in accordance with the investment objectives and policies set forth in each fund’s
registration statement filed with the SEC. PMAM may also retain unaffiliated Sub-Advisers to provide investment
management services for all or a portion of an affiliated fund’s assets, consistent with the terms of the applicable advisory
and sub-advisory agreements.
Fees are payable to each investment portfolio at the end of each calendar month for services rendered during the month
and are calculated based on the portfolio’s average daily net assets. In cases when PMAM uses Sub Advisers, their fees
are paid by PMAM out of the advisory fee it receives from the fund.
Insurance Companies
PMAM provides investment management services to affiliated insurance companies, primarily with respect to the
management of insurance general account assets. Each affiliated insurance company pays advisory fees monthly in
arrears for services provided during the preceding month. Fees are calculated based on the net asset value of each
investment portfolio as of the last calendar day of the month. The applicable fee rate is expressed in basis points and is
applied to all assets held in the portfolio. For periods shorter than a full month, fees are prorated based on the actual
number of days services were provided.
Other Affiliated Portfolios
PMAM also provides investment management services to other affiliated entities. These affiliates pay advisory fees
monthly in arrears for services provided during the preceding month. Fees are calculated by applying an agreed-upon
basis-point rate to the net asset value of each investment portfolio as of the last calendar day of the month. The fee
calculation includes all assets held in the portfolio and is prorated for any period shorter than a full month.
Other Fees and Expenses
In addition to the advisory fees described above, clients may be responsible for other fees and expenses incurred in
connection with the advisory services provided. These may include fees charged by the custodian for the safekeeping of
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client assets, as well as brokerage commissions and other transaction-related costs associated with trades executed for
a client’s account. Such fees and expenses are separate from PMAM’s advisory fees and are typically charged or deducted
by the applicable service providers on a monthly basis.
Item 6: Side-by-Side Management and Conflicts
Multiple Portfolios and Potential Conflicts
PMAM manages multiple investment portfolios, including accounts with different fee structures and investment
objectives. Managing these portfolios side-by-side may create potential conflicts of interest. For example, differences in
fee arrangements could create an incentive to allocate investment opportunities or resources in a manner that favors
accounts paying higher fees, or to select investments that are riskier or more speculative for certain portfolios.
Conflict Mitigation Practices
PMAM seeks to mitigate these potential conflicts through policies and procedures designed to promote fair and equitable
treatment of all client accounts. These include oversight of investment decision-making, monitoring for consistency with
client mandates, and controls intended to ensure that investment professionals act in the best interests of clients rather
than PMAM’s financial interests.
Related Disclosure References
Additional information regarding trade allocation and related practices is provided in Item 12, Brokerage Practices.
Information regarding PMAM’s Code of Ethics and personal trading policies is provided in Item 11, Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
Account Minimums and Types of Clients — Form ADV Part 2A (4/1/2026)
[Brochure]
Item 7: Types of Clients
PMAM provides investment management services to its affiliated insurance company general accounts, separate
accounts, and other affiliated corporate entities. PMAM also qualifies as a Qualified Professional Asset Manager (QPAM)
under the Employee Retirement Income Security Act of 1974 (ERISA).
Filed 2025-04-28 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Over $100,000,000