Fees and Compensation — Form ADV Part 2A (4/28/2017)
[Brochure]
Item 5. Fees and Compensation
The Adviser charges each separately managed client account an investment advisory fee based on the
market value of the account’s assets under management. For managed account clients, the Adviser
typically charges an advisory fee at an annual rate of 1.0%. The fee is payable in quarterly installments
in advance on the first day of each calendar quarter and is based on the market value of the assets under
management in the account as of the close of business on the preceding business day. The fee will be
prorated for any partial quarter during which the account is established.
A managed account client may terminate the investment management agreement with the Adviser at
any time. Upon termination of an account during a quarter, advisory fees will be prorated and any
prepaid, unearned advisory fees will be promptly refunded.
The Adviser reserves the right to determine the annual advisory fee rate and/or the manner of payment
with any managed account client or prospective managed account client. As a result, fees may be
negotiable under certain circumstances or for certain managed account clients. The Adviser bills
managed account clients and deducts the fee automatically from their accounts when agreed upon with
the clients.
The fees charged for private funds which the Adviser manages, including any investment advisory fees
and performance-based fees, are described in the legal documentation for such private funds.
For Sequoia Fund, Inc. (“Sequoia”), the registered investment company for which the Adviser provides
advisory services, the Adviser receives an advisory fee at an annual rate of 1.0%, which is based on the
average daily net asset values of the Fund. The fee is accrued daily and paid monthly.
In addition to paying advisory fees to the Adviser, clients are subject to other expenses such as
brokerage commissions and costs associated with foreign exchange transactions. Client assets may be
invested in money market mutual funds or other registered or unregistered investment companies,
private funds or other investment entities. In these cases, the client bears its pro rata share of the
investment management fee and other fees of the fund in which the assets are invested. The
management and other fees of the fund in which assets are invested are described in the fund’s legal
documentation, and are in addition to the advisory fee paid to the Adviser. Please refer to Item 12 of
this Firm Brochure for a discussion of the Adviser’s brokerage practices.
Ruane, Cunniff & Goldfarb LLC (“RCGL”), a wholly-owned subsidiary of the Adviser and registered
broker-dealer, receives compensation in connection with the Adviser’s use of RCGL to execute client
securities transactions. Please refer to Item 10 of this Brochure for more information concerning this
compensation.
Account Minimums and Types of Clients — Form ADV Part 2A (4/28/2017)
[Brochure]
Item 7. Types of Clients
The Adviser’s clients consist of individuals, an investment company, pension and profit sharing plans,
trusts, estates, and charitable organizations, private funds, corporations and other business entities.
There are no minimum investment requirements for opening or maintaining a managed account. With
respect to Sequoia and any client that is a private fund, any initial and additional subscription
minimums are disclosed in the legal documents for such clients.
Filed 2026-03-13 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
0
0.0
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above