Fees and Compensation — Form ADV Part 2A (4/2/2026)
[Brochure]
ITEM 5: FEES AND COMPENSATION
Financial Planning
Fees for financial planning are included in the fees for investment management services. You may cancel
our financial planning agreement at any time by providing written notice.
THALASSA would like its clients to know that there is a conflict of interest between it and them
regarding implementation of the financial plan. If you decide to have us help you implement the
recommendations in the financial plan, we will receive our standard fees as disclosed below. Clients are
under no obligation to implement the plan, or to use THALASSA for the implementation.
Investment Management Services
Advisory Fees & Billing Practices
Clients who participate in the Individual and Strategic Investment Management Services will pay a 1%
annual fee quarterly in advance, based on the value of their assets as of the last day of the preceding
quarter.
For the first quarter fees will be calculated using the asset value as of the effective inception date of the
account. First quarter fees will be adjusted proportionally based on the number of days remaining in the
quarter after the effective inception date of the account. There is no minimum fee.
When funds in the amount of $10,000 or more are added to or withdrawn from the account during a
quarter, the applicable fee will be adjusted on a pro-rata basis to reflect such addition or withdrawal.
You may provide authorization for us to deduct our fees directly from your investment account.
Important information about the deduction of management fees:
You must provide authorization for us to deduct fees by initialing the appropriate section of our
contract.
You will receive a detailed invoice each quarter which outlines our fees and how they are
calculated at the same time we request payment from the custodian.
You will receive a statement from your custodian which shows all transactions in your account,
including the deduction of our fee.
You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not
do so.
You may elect to pay by check rather than having payment deducted directly from your account.
Crystal Portfolios
In regards to investments in the Crystal Portfolios, clients will have an annual management and advisory
fee of 1.50% deducted quarterly in arrears from their accounts by Crystal Capital. THALASSA does not
receive fees for the assets that are placed at Crystal Portfolios. THALASSA will not select investments in
the Crystal Portfolios that would cause a client to pay a combined management fee (fee paid to Crystal
Portfolios and fee paid to the underlying fund adviser) that exceeds 3% of the invested assets.
Termination
You may end our advisory relationship by providing written notice. We will prorate the advisory fees
earned through the termination date and send you a refund of the prepaid, unearned portion of your fee, or
bill you for the due fee, as appropriate. We process refund payments, if any, within 30 days of the
termination date and will send you a check or refund your investment account. In all cases we will
provide a final invoice detailing the calculation of the fee and potential refund.
Other Costs Involved
In addition to our advisory fee shown above, you are responsible for paying fees associated with investing
for your account. These fees include:
mutual fund loads (if applicable). These charges are paid to brokers as a form of commission.
management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF
or mutual fund and are a portion of the expenses of the ETF or mutual fund.
brokerage costs and transaction fees for any securities or fixed income trades. These are
generally charged by your custodian and/or executing broker.
the Crystal Portfolios invest in hedge funds which are managed by unaffiliated advisers. The
underlying funds may be charged management fees and performance based fees that are in
addition to the fees charged by THALASSA and Crystal Capital.
Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.”
Neither THALASSA nor any of its affiliated persons receive an economic benefit from a non-client for
providing advisory services, other than the services it may receive from your custodian as described in
Account Minimums and Types of Clients — Form ADV Part 2A (4/2/2026)
[Brochure]
ITEM 7: TYPES OF CLIENTS
We provide investment advice to individual as well as institutional investors. Generally, we require that
clients maintain $250,000 under management with us. However, we may waive that minimum at our sole
discretion.
In order to participate in the Crystal Portfolios, clients need to meet the Qualified Investor standard, as
outlined in Rule 205-3 of the Investment Adviser’s Act of 1940. Typically, a client needs to meet one of
the following criteria:
• Have a net worth (or together with spouse have a net worth) of at least $2.1 million, excluding the
value of the primary residence.
• Have at least $1,000,000 invested in the Crystal Portfolios.
The full criteria are provided in the Crystal Capital sign-up documents.
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
32
6.7
(b) Individuals (high net worth individuals)
27
71.4
(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
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(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