ITEM 5 Fees and Compensation
ANNUAL FEES FOR DIRECT ASSET MANAGEMENT SERVICES
SGIM is compensated for providing Direct Asset Management Services by charging Direct
Clients a fee based on the Direct Client’s total assets under management. The fees and billing
will be pre-determined in writing in the Investment Advisory Agreement executed by the Direct
Client and SGIM.
The below ranges are the standard fee ranges that are typically charged.
Asset Management Fee Schedule
Assets Under Management Annual Fee
$0 - $1,000,000 0.70%
$1,000,001 - $5,000,000 0.65%
$5,000,001- $10,000,000 0.60%
$10,000,000 + 0.50%
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ANNUAL FEES FOR TAMP SERVICES
SGIM is compensated for providing TAMP Services by charging a fee based on an Independent
RIA Client’s assets under management with SGIM. The fees and billing will be pre-determined in
writing in the Investment Advisory Agreement executed by the Independent RIA Client and SGIM.
For actively-managed portfolios incorporating individual stocks, SGIM generally charges an annual
fee up to 0.50% of the Independent RIA Client’s assets under management, and up to 0.25% for
passively-managed portfolios incorporating ETFs.
FEE BILLING & PAYMENT
Our asset management fees are annual fees, paid monthly in arrears, and may be negotiable.
Payments are due on the first day of each calendar month and are based on the account’s daily,
end of the day asset value from each day of the prior calendar month multiplied by the applicable
annual rate and divided by three hundred sixty-five (365) calendar days. The monthly fee is an
aggregate of the prior month’s daily end-of-day values and correponding calculation. The end
of the day account asset valuation is provided by the custodian.The fee for the prior month
is billed and payable within ten (10) days after the end of the prior month. We will deduct
our asset management fee only when in receipt of your written authorization by executing an
investment advisory agreement permitting the fees to be paid directly from your account. The
qualified custodian will deliver an account statement to you at least monthly, which will show all
disbursements from your account.
TERMINATION OF AGREEMENT
Either party may terminate the investment advisory agreement at any time. Upon termination of
any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees
will be due and payable up to and including the effective date of termination.
Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at
least 48 hours prior to you entering into any written or oral advisory contract with this us, then
you have the right to terminate the contract without penalty within five (5) business days after
entering into the contract.
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OTHER EXPENSES AND FEES
The fees discussed above include payment solely for the investment advisory services provided by
SGIM and are separate to certain fees or charges that are imposed by third parties in connection
with investments made on your behalf for your account. Third-party fees may include markdowns,
markups, other transaction costs.
All fees paid to SGIM for asset management services are separate from the expenses charged by
ETFs to their shareholders. These fees and expenses will be used to pay management fees for the
funds, other fund expenses, account administration, and a possible distribution fee. You should
review both the fees we charge and the fees charged by the ETFs to understand the total fees to
be paid fully.
FUND FEES
As the investment manager to the Fund, SGIM generally charges the Fund a management fee and
a performance fee that is negotiable on a case by case basis with the applicable limited partner
(investor) of the Fund.
OTHER COMPENSATION
The Adviser nor its principals receive other compensation.