ITEM 5 FEES AND COMPENSATION
A. Advisory Fees and Compensation
The Firm will charge each client an advisory fee (the “Advisory Fee”) based on the value of the client’s
assets under management, generally in accordance with the following schedule.
Account Size Annual Fee
Up to $500,000 1.25%
Next $1,500,000 1.00%
Next $3,000,000 0.80%
Next $5,000,000 0.60%
Next $15,000,000 0.50%
Over $25,000,000 Negotiable
The above fee schedule will apply to both discretionary and non-discretionary advisory accounts. If a client
is invested in a sub-advised strategy, sub-advisory fees could be paid directly by the client or be paid by
Polaris, generally as agreed between Polaris and the sub-adviser. If Polaris pays the sub-advisory fee, such
sub-advisory fee generally will not increase or be in addition to the Advisory Fee. As discussed below, if
Polaris does not pay the sub-advisory fee, the sub-advisory fee will represent an additional expense that the
client must bear.
As a result of an acquisition by Polaris of another investment adviser, legacy clients from that adviser may
pay higher investment management fees than those set forth above. Those clients receive full disclosure of
their fee schedule as part of the investment management agreement they execute with Polaris.
Advisory Fees are negotiable at the sole and absolute discretion of the Firm.
For existing accounts, Advisory Fees will be billed quarterly in arrears based on the total market value of
the assets in the client account (including net unrealized appreciation or depreciation of investments and
cash, cash equivalents and accrued interest) determined by us on the last trading day of the previous calendar
quarter. If a new client account is established during a quarter or a client makes an addition of $100,000 or
more to its account during a quarter, the Advisory Fee will be calculated as of the account start date or the
date of the additional contribution based on the value of the assets as of the applicable date and will be pro-
rated for the number of days remaining in the quarter. This pro-rated fee will be billed and due on the first
day of the next calendar quarter.
Polaris also offers sub-advisory services to other registered investment advisers. In return for its sub-
advisory services, Polaris generally receives a portion of the advisory fees paid to the adviser. The amount
or rate of such fee will be as agreed between Polaris and the adviser. Advisory fees charged to clients by
the adviser, as well as other expenses that are associated with that adviser’s services, are described in each
adviser’s brochure, and will vary by adviser.
B. Payment of Fees
Generally, clients authorize us under our agreement to deduct our Advisory Fee quarterly from their account
by instructing the client’s custodian. In certain limited circumstances, clients have the option to also pay
directly upon receipt of a billing invoice.
C. Other Fees and Expenses
In addition to paying Advisory Fees, client accounts will also be subject to other investment expenses such
as the fees and expenses charged by the custodian and the broker-dealer (which may be based on
transactions in your account or based on assets in your account). Client accounts are subject to interest
expenses; taxes, duties and other governmental charges; transfer and registration fees or similar expenses;
costs associated with foreign exchange transactions; costs associated with OTC (over the counter)
transactions; other portfolio expenses; and costs, expenses and fees (including, investment advisory and
other fees charged by investment advisers with, or funds in, which the client’s account invests) associated
with products or services that may be necessary or incidental to such investments or accounts. Client assets
may be invested in mutual funds, ETFs, or other registered investment companies. In these cases, the client
will bear its pro rata share of the investment management fee and other fees of the fund, which are in
addition to the investment Advisory Fee paid to the Firm.
All fees paid to the Firm for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described
in each mutual fund’s and ETF’s prospectus and potentially include a management fee, distribution fee (i.e.,
Rule 12b-1 fee), sales charge and other fund expenses. A client is able to invest in a mutual fund or an ETF
directly, without the services of the Firm. In that case, the client would not receive the services provided by
the Firm which are intended, among other things, to assist the client in determining which mutual fund(s)
or ETF(s) are most appropriate to each client’s financial condition and objectives. Accordingly, each client
should review both the fees charged by the mutual funds and the ETFs and the fees charged by the Firm to
fully understand the total amount of fees paid by the client and to thereby evaluate the advisory services
being provided.
The Firm generally limits its utilization of mutual funds in its investment strategies. To the extent a client’s
assets are invested in a mutual fund, however, the Firm would not receive any 12b-1 fees from that mutual
fund. Clients should also understand that while the Firm does not receive 12b-1 fees, a 12b-1 fee might still
be paid to a mutual fund distributor, depending on the mutual fund. These 12b-1 fees increase overall
expenses to the client.
D. Additional Compensation
The Firm does not accept compensation for the sale of securities or other investment products, including
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