Item 5 – Fees and Compensation
Fees are negotiable and may vary, but generally will be based on an annual percentage rate of
one to two percent (1-2%) of assets under management. A performance based-fee or carry, up
to 25% of profit attributable to an investor’s capital contributions to the partnership may also be
charged. Fees are payable quarterly at the beginning of each calendar quarter based on the
market value of the assets under management at the close of the prior quarter. Fees on
additions or withdrawals are pro-rated. A client may terminate an investment advisory
agreement on five (5) business days advance written notice. On termination, clients may
receive a refund of advisory fees on a pro-rated basis. Fees are generally deducted from client
accounts.
Registrant believes that its fees are competitive with fees charged by other investment advisers
for comparable services, but comparable services may be available from other sources for lower
fees than those charged by Registrant. Registrant’s fees for investment advisory services are
separate and distinct from fees charged by Registrant’s affiliated investment advisers or limited
partnerships.
Registrant’s fees for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds and exchange-traded funds (“ETFs”) to shareholders.
Clients invested in mutual funds or ETFs will pay advisory fees to Registrant and will pay
additional advisory, brokerage, custodial and administrative fees as a shareholder of the
applicable mutual fund or ETF. These mutual fund or ETF fees and expenses are described in
each fund’s prospectus. Registrant’s fees are also separate and distinct from custodial,
accounting, legal and other fees incurred by clients.
Mr. Mahdavi is a principal and officer of Registrant and is also a registered representative of
S.F. Sentry Securities, Inc., a registered broker-dealer. Ms. Meissner is a principal and officer
of Registrant and is also a registered representative and officer of S.F. Sentry Securities, Inc., a
registered broker-dealer. Registrant directs most of its advisory clients’ brokerage commissions
to S.F. Sentry Securities, Inc. Mr. Mahdavi may receive a portion of brokerage commissions
paid in connection with those transactions. These brokerage fees paid by advisory clients are in
addition to Registrant’s advisory fees.
This arrangement creates a conflict of interest in that Registrant, Mr. Mahdavi, has an incentive
to direct more client transactions to S.F. Sentry Securities, Inc. than Registrant might otherwise
direct. S.F. Sentry Securities, Inc. has indicated to Registrant that the brokerage fees paid by
Registrant’s clients will not exceed the fees paid by similar clients of S.F. Sentry Securities, Inc.
In all cases in which transactions are directed to S.F. Sentry Securities, Inc., or to any other
broker, Registrant will determine in good faith that the commissions charged in connection with
those transactions are reasonable in relation to the value of the brokerage, research and other
services provided by that broker, viewed in terms of either the specific transaction or
Registrant’s overall responsibilities to the portfolios over which Registrant exercises investment
authority. Registrant will regularly review the commission rates paid by its advisory clients to
determine that they are competitive with commissions paid by clients of investment advisors that
Sivia Capital Investments, LLC
Form ADV Part 2A Brochure
March 28, 2016
provide services similar to Registrant’s. Nevertheless, Registrant’s clients may be able to obtain
more favorable brokerage commission rates elsewhere particularly when one considers the
advisory fees being paid to Registrant. If a client so desires to use another unaffiliated
brokerage firm, the client may notify Registrant in writing. Clients who use a broker they have
selected may pay higher or lower commissions than those charged by S.F. Sentry Securities,
Inc. See Item 12 regarding brokerage practices.