Fees and Compensation
Our fees are ordinarily calculated as a percentage of the average capital in each client’s account
and are generally calculated quarterly in arrears.
Our current fee schedule for new accounts is as follows:
1.00% annually on the first $5 million
0.75% from $5 million to $15 million
0.50% from $15 million to $25 million
0.40% from $25 million to $45 million
0.35% from $45 million to $65 million
0.20% over $65 million
Client accounts are generally subject to a minimum annual fee of $25,000.
The management fee is deducted directly from the assets of each account as the fee becomes
payable or clients can request to be invoiced directly. Several of our private investment funds
also pay a performance allocation annually at December 31 or upon withdrawal of capital from
any investor’s account.
Clients can terminate our services upon three days notice to us. The pro rata portion of any fees
that have been prepaid will be refunded within 30 days after the date of termination or as soon as
practible. For certain contracts executed prior to July 26, 2002, a 30 day termination notice is
required. Upon termination of an account, any earned, unpaid fees will be due and payable to us.
Fees will be prorated based on the number of days that we manage each account.
In certain circumstances, the advisory fees payable to us by individual clients or by investors in
our private funds have been or may be negotiated. Investors and prospective investors in our
private funds should refer to the governing documents of the relevant fund for more complete
information on the advisory fees charged to each fund by R.H. Bluestein & Co.
Our clients are responsible for all costs and expenses incurred in connection with the investments
in their accounts, including brokerage commissions, custody fees and bank charges. Our private
investment funds also pay all of their operating costs, including administrative, legal, accounting
and auditing costs and expenses, as described in greater detail in the governing documents for
each private investment fund. Where relevant, expenses are allocated among participating
accounts in proportion to their participation in a particular investment, in proportion to their
respective net asset values, or in such other manner as R.H. Bluestein & Co. determines to be
equitable. Investments in mutual funds, ETFs, and closed-end funds are subject to the fees and
expenses of those funds in addition to the fees payable by clients to R.H. Bluestein & Co.
Neither R.H. Bluestein & Co. nor its supervised persons will receive any compensation with
respect to the purchase or sale of securities or other investment products by any client accounts.
Please see “Brokerage Practices” below for more information about brokerage commissions
payable by client accounts.
Performance-Based Fees and Side-by-Side Management
Two of our private funds, Atlantic Fund I, L.P. and Bluestein Capital Opportunities Fund, L.P.,
pay a performance-based special allocation of profits to their general partner, which is owned by
management persons of R.H. Bluestein & Co.
We provide advisory services simultaneously to clients that are not charged a performance-based
fee or allocation and to clients that are charged a performance-based fee or allocation.
Performance based compensation arrangements can create an incentive for us to recommend
investments that may be riskier or more speculative than would be recommended under a
different fee arrangement. Such arrangements can also create a conflict of interest with respect to
the allocation of investment opportunities, as we may have an incentive to direct the best
investment ideas to, or to allocate investments in favor of, the account that pays a performance
fee or allocation. To alleviate potential conflicts of interest, the allocation of investment
opportunities to each client account is made in accordance with our investment allocation policy,
which takes into account various criteria, including the specific objectives of each client, the size
and capital available for investment by each client, diversification needs, the size of the
investment opportunity, current and anticipated market conditions, specific investment
restrictions or guidelines applicable to each client, and relevant tax or regulatory considerations.