Fees and Compensation — Form ADV Part 2A (3/24/2026)
[Brochure]
Item 5 – Fees and Compensation
ST Capital clients are billed in arrears based on a percentage of assets under management, using a fee
schedule clearly described in each client’s investment advisory contract.
ST Capital bills clients at the end of each quarter, based on the average market value of the assets for the
previous three months. The Firm will calculate the fee on a pro-rata basis if the first or last quarter during
which the agreement is in effect is a partial quarter. ST Capital has no authority to deduct fees.
ST Capital may combine related separate accounts for billing purposes when a client requests it for billing
convenience, or to achieve a fee break when a client’s assets in all accounts exceed $10 million.
In addition to ST Capital’s investment management fee, clients must pay custodian fees and all trading costs.
ST Capital might occasionally engage in a high level of trading activity, and the turnover of the portfolio could
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generate substantial transaction costs. See Item 12 Brokerage Practices for information describing the factors
considered in selecting broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions). Such charges, fees and commissions are in addition to ST Capital’s fee.
The Firm does not receive any portion of the commissions, custodian fees or trading costs.
ST Capital’s investment advisory contracts typically provide for termination with thirty day’s written notice
by the client or the Firm. ST Capital is entitled to the fees earned through the date of termination.
The Firm does not receive compensation for the sale of securities or other investment products. ST Capital
does not act as principal, buy securities for the Firm from any client or sell securities that the Firm owns to
any client. The Firm does not act as broker or agent to affect securities transactions for compensation.
ST Capital is the Manager of the ST Capital Group Value Fund (the “Fund”), and has an economic interest in
the Fund, as described under Item 10 Other Financial Industry Activities or Affiliations.
ST Capital’s fee schedule is as follows:
Separately Managed and Sub-Advisory Accounts opened prior to January 1, 2025
0.7% - first $10 million
0.5% - next $20 million
0.3% - next $20 million
0.2% on assets over $50 million
Separately Managed and Sub-Advisory Accounts opened on or after January 1, 2025:
0.7% - first $25 million
0.6% - next $25 million
0.5% on assets over $50 million
Commingled Accounts: the “Fund”
Assets invested in the Fund will be charged a 1% fee by the Fund.
The Fund pays ST Capital (as Manager) a maximum 1% annual fee payable in monthly installments,
calculated based on month-end market values of the Fund. ST Capital pays all fees and expenses,
except for brokerage fees, incurred by or on behalf of the Fund in the ordinary and usual course of
business.
Accounts primarily invested in the Fund will be charged an annual fee of 0.25% on assets managed
outside the Fund in the same manner as separately managed accounts.
Unified Managed Account Program: “UMA”
Fees for UMA programs may vary depending upon the size and complexity of the client relationship
and are negotiable at ST Capital’s discretion.
Account Minimums and Types of Clients — Form ADV Part 2A (3/24/2026)
[Brochure]
Item 7 – Types of Clients
ST Capital provides investment management services to:
Corporate pension & profit-sharing plans
Endowments & Foundations
Families and Family Offices
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Trust Companies
The minimum account size is $5 million for a separate account and $1 million for a commingled account.
Filed 2012-03-05 (D) · Exemption 3(c), 3(c)(1) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
3
13.0
(b) Individuals (high net worth individuals)
14
116.0
(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
1
111.0
(g) Pension and profit sharing plans
2
119.0
(h) Charitable organizations
9
106.0
(i) State or municipal government entities
1
4.0
(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