SWS Capital Management LLC

Item 5 Fees and Compensation
The Adviser is compensated on a percentage of assets managed basis.

Separate Account Client
Depending on the investment strategy, fees for separate account clients are expected to
range from 0.20% to 0.35% of average net assets for assets up to $25 million, 0.15% to
0.30% from $50 to $100 million and 0.10% to 0.25% over $100 million. Fees generally
are payable quarterly in arrears. During negotiations for opening a separate account, the
Adviser presents the standard fee schedule. Fees are negotiable to all potential clients. With
existing client contracted mandates in place, fees are already established.
Clear Vision
Subject to certain reductions described in Clear Vision’s partnership agreement, Clear
Vision pays SWSCM an annual management fee of one- and one-half percent (1.50%),
which shall be reduced to three quarters of a percent (.75%), payable in advance on a
quarterly basis. If Clear Vision is wound down before the end of a billing period, SWSCM
will determine how pre-paid fees may be refunded and will likely return the portion of fees
proportionate to the amount of time remaining in the period.
Clear Vision reimburses its general partner for certain Clear Vision organizational and
startup expenses, including without limitation, legal, accounting, filing, printing, travel and
other out-of-pocket expenses. Clear Vision is responsible for all costs and expenses that
are not paid or reimbursed in connection with Clear Vision’s business pursuant to its
governing documents.
Greater detail regarding fees and expenses, as well as other important information
regarding an investment in Clear Vision is more fully set forth in its governing documents.
NYSECIF
NYSECIF pays certain fees and reimburses certain expenses in accordance with the
relevant limited partnership agreement.
Other Fees or Expenses in Connection with Advisory Services
Depending on the arrangements with the Adviser and third-party service providers,
separate accounts may pay for administrative and custodial services and brokerage and
other transaction costs.
Please also see “Brokerage Practices” in Item 12 below.
Compensation from the Sale of Securities or Other Investment Products
The Adviser and the Adviser’s supervised persons who manage client assets day-to-day do
not accept compensation from the sale of securities or other investment products.
As noted below in Item 10, SWSCM’s CEO, Christopher J. Williams, is a registered
representative of Siebert Williams Shank & Co., LLC (CRD#: 42568/SEC#: 8-49877), a
registered broker-dealer (“SWS”). SWS is under common control with SWSCM. Through
his work for SWS, Mr. Williams is effectively compensated for the sale of securities or
other investment products. SWSCM does not view this as a conflict of interest since Mr.
Williams is not involved with the day-to-day investment advisory or trading activities of
the Adviser. Generally, as a matter of policy, the Adviser does not effect client portfolio
transactions with SWS. The Adviser, however, may in some instances do so, but only on
an agency basis and based on the Adviser’s duty to seek best execution.

Item 7 Types of Clients
The Adviser provides discretionary fixed-income investment advisory services to
institutional clients through separate accounts. The adviser negotiates separately with each
separate account client regarding minimum acceptable account size. Normally, the
minimum account size is $15 million.
As mentioned in Item 4, SWSCM serves as fund manager of the Funds pursuant to their
relevant investment management agreements. Clear Vision and NYSECIF are closed and
no longer accepting any new investors.