ITEM 5: FEES AND COMPENSATION
Seven Locks fees vary based upon the Client, and in the case of Private Fund investors, the share class of
the fund in which they are invested.
Fees for Private Fund investors are more fully described in the Offering Documents for each Private
Fund. The General Fund and Enhanced Fund investors will pay the specific management fees and
incentive allocation described in their respective Offering Documents.
Fees for the Crown/Seven Locks managed account, for whom Seven Locks only serves as trading advisor,
will be charged to investors by their direct investment manager. In the case of the Crown/Seven Locks
managed account specifically, the fees are more fully described in the Crown Managed Accounts SPC
prospectus.
Seven Locks bears its own costs arising from providing certain administrative and management services
to Clients, including, but not limited to, salaries and fringe benefits of professional, administrative,
clerical, bookkeeping, secretarial and other personnel; rent; office equipment; newspapers and other mass-
market periodicals, computer equipment and services; data processing; fire and theft insurance; heat,
light, cleaning, power, water and other utilities of any office space maintained by Seven Locks on its own
behalf or on behalf of Clients; stationery; postage; office supplies for Seven Locks and Clients;
bookkeeping services; secretarial services; travel and entertainment; telephone (local and long distance);
and any other overhead-type expenses.
Each Client of Seven Locks is responsible for all other relevant operating and other expenses, such as, but
not limited to, management fees; organizational costs; indemnification expenses; commissions; clearing
fees; fees, interest and other costs on margin accounts or other financings or re-financings; accounting and
legal fees and disbursements (including legal fees related to the protection of the Client’s investments);
accounting, audit and tax preparation expenses; third-party administrator fees; borrowing charges on
securities sold short; custodial fees; bank service fees; expenses incurred in connection with the admission
of additional investments; investment and trading consultant expenses; research fees (including
publications and quotation services); risk management software fees; expenses in connection with
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proposed transactions (including transactions that fail to close); liability insurance premiums with respect
to Seven Locks and its affiliates; expenses related to the registered offices of the Clients, and any other
reasonable expenses related to the purchase, sale, holding or transmittal of the Clients' assets or the
Clients' liabilities. The trading and brokerage fees are further discussed in Item 12 - Brokerage Practices.
The expenses of the Clients may potentially be higher than those typically found in other investment
options.
The General Fund and the Enhanced Fund bear all costs and expenses incurred in connection with their
formation and organization (collectively, the “Organizational Costs”). Such Organizational Costs may be
amortized over the first 60 months of each Client’s operations. Amortization of such expenses over a
period that is up to 60 months is a divergence from U.S. Generally Accepted Accounting Principles, and
such divergence could, in certain circumstances, result in a qualification of the annual audited financial
statements.
Any and all statements contained in this Form ADV brochure with respect to fees charged to the Private
Fund Clients and the Managed Account Clients are subject in their entirety to the respective Offering
Documents of each.
Neither Seven Locks nor any of its supervised persons accepts compensation for the sale of securities or
other investment products.
The redemption of an investment in a Private Fund Client or a Managed Account Client is subject to
terms and limitations described in the applicable Private Fund’s Offering Documents. In relation to the
Private Fund Client’s, Seven Locks or one of its affiliates may:
(i) suspend redemption rights, in whole or in part;
(ii) postpone the date of payment of redemption proceeds; or
(iii) suspend the calculation of the net asset value of a Fund, for any period during which:
(a) any stock exchange or over-the-counter market on which a significant portion of the investments
owned (directly or indirectly) by the Fund are traded is closed or trading on any such exchange or
market is restricted or suspended;
(b) there exists a state of affairs that constitutes a state of emergency as a result of which disposal of
the investments owned by the Fund is not reasonably practicable or it is not reasonably practicable
to determine fairly the value of its assets;
(c) a breakdown occurs in any of the means normally employed in ascertaining the value of a
substantial part of the assets of the Fund or when for any other reason the value of such assets
cannot reasonably be ascertained;
(d) an event occurs that would cause the dissolution of the Fund; or
(e) there exist such other extraordinary circumstances, as determined in good faith by Seven Locks or
one of its affiliates that cause redemptions or such payments to be impracticable under existing
economic or market conditions or conditions relating to the Fund.
Certain Private Fund Clients may agree to allow certain investors to participate on different business
terms than other investors, including investing directly into the Master Funds, provided that Seven Locks
believes that doing so will not adversely affect such other investors. Seven Locks may consider a number
of other factors in determining whether to make different business terms available to a prospective
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