Saratoga Capital Management LLC

Item 5: Fees & Compensation
Retail Clients
SCM normally charges Retail Clients a percentage of their assets under management (“AUM”) for advisory
services. Fees are based on the fee schedules below, though they are negotiable under certain
circumstances; negotiability is based on a range of factors including, but not limited to, account size,
service frequency, degree of customization, and family or multi-account structures. SCM’s fee schedules
use a blended calculation of its fee rates to determine the effective fee (e.g., a client in the Full Financial
Planning schedule with $2,000,000 in total AUM will have the first $1,000,000 in AUM billed at 1.00%
annually, and the next $1,000,000 in AUM billed at 0.90% annually, resulting in a blended total fee of 0.95%
annually). Fees are prorated and charged monthly in arrears, based on daily average AUM during the
month. Alternative billing frequencies, such as quarterly billing, are subject to negotiation.
SCM offers three standard fee schedules, generally dependent on the complexity of investment
management and financial planning associated with the account or Household Accounts, as defined
below in this section. Investment Management Only services are subject to a minimum monthly fee of
$75. Focused Financial Planning & Investment Management services are subject to a minimum monthly
fee of $125. Full Financial Planning & Investment Management services are subject to a minimum monthly
fee of $375. SCM, in its discretion, may choose to waive these minimum fees.
Investment Management Only (subject to minimum fee)
  Tier     Tier Minimum                             Tier Maximum               Annual Fee Rate
  1        $0                                       $1,000,000                 0.65%
  2        $1,000,001                               $2,500,000                 0.50%
  3        $2,500,001                               $5,000,000                 0.35%
  4        $5,000,001                               ∞                          0.20%

Focused Financial Planning & Investment Management (subject to minimum fee)
 Tier      Tier Minimum                     Tier Maximum                       Annual Fee Rate
 1         $0                               $1,000,000                         0.90%
 2         $1,000,001                       $2,500,000                         0.75%
 3         $2,500,001                       $5,000,000                         0.60%
 4         $5,000,001                       ∞                                  0.45%

SARATOGA CAPITAL MANAGEMENT, LLC | ADV PART 2A                                                                   7

Full Financial Planning & Investment Management (subject to minimum fee)
 Tier        Tier Minimum                   Tier Maximum                       Annual Fee Rate
 1           $0                             $1,000,000                         1.00%
 2           $1,000,001                     $2,500,000                         0.90%
 3           $2,500,001                     $5,000,000                         0.80%
 4           $5,000,001                     ∞                                  0.70%

SCM may provide certain of its services individually, or in various combinations, for a flat fee or alternative
AUM-based fee. In circumstances where the above fee schedules are not being applied, Client fees will be
clearly illustrated and memorialized prior to commencement of services.
Client may incur additional fees and expenses charged by third parties independent of SCM. These
include custodial fees, tax‑loss harvesting fees, model portfolio fees, fixed income fees, transaction costs,
account maintenance fees, wire or transfer fees, and the internal fees and expenses charged by mutual
funds and exchange‑traded funds held in Client’s account. These third‑party fees are not set or received
by SCM and will be deducted directly by the applicable service provider.

Household Accounts
For purposes of applying our asset‑based fee schedules, we may aggregate the assets of related client
accounts that we determine, in our discretion, are part of the same household (“Household Accounts”).
Household Accounts generally include accounts held by spouses or domestic partners and their
dependent children, including children under the age of 25, provided such individuals maintain a shared
primary residence or otherwise demonstrate a close familial or financial relationship.
The determination of whether accounts are treated as Household Accounts is made on a case‑by‑case
basis and may require reasonable documentation. We reserve the right to include or exclude accounts
from household aggregation at any time.

Plan Sponsors
SCM charges Plan Sponsors a percentage of their plan’s AUM for investment advisory services. Fees are
based on the fee schedule below, though they are negotiable under certain circumstances; negotiability is
based on a range of factors including, but not limited to, account size, service frequency, and degree of
customization. SCM’s fee schedules use a blended calculation of its fee rates to determine the effective
fee (e.g., a plan in the below schedule with $2,000,000 in total AUM will have the first $1,000,000 in AUM
billed at 0.50% annually, and the next $1,000,000 in AUM billed at 0.40% annually, resulting in a blended
total fee of 0.45%).
Fees are charged quarterly in arrears, based on the plan’s quarter-end AUM, and SCM’s services are
subject to a minimum quarterly fee of $500. SCM, in its discretion, may choose to waive this minimum
fee.
 Tier        Tier Minimum                         Tier Maximum                 Annual Fee Rate
 1           $0                                   $1,000,000                   0.50%
 2           $1,000,001                           $2,500,000                   0.40%
 3           $2,500,001                           $5,000,000                   0.30%
 4           $5,000,001                           ∞                            0.20%
...

Item 7: Types of Clients & Account Minimums
We offer advisory services to the following clients:
   •   Individuals, including high net worth individuals;
   •   Trusts, estates, and charitable organizations;
   •   Corporations or other business entities;
   •   Not for profit entities;
   •   Retirement plans;
   •   Registered Investment Companies; and
   •   Other investment advisors.
SCM does not have account minimums for Retail Clients or Plan Sponsors; while no formal account
minimum applies, SCM reserves the right to decline relationships where SCM believes the fee would be
uneconomical for the client or the firm.
Account minimums within the Trust generally range from $2,500 to $10,000, however exceptions exist.