Fees and Compensation — Form ADV Part 2A (3/31/2023)
[Brochure]
Item 5 – FEES AND COMPENSATION
Management Fees
Torshen Capital expects to receive a management fee from each Account payable quarterly in
advance at an annual rate of 2% of the market value of the assets in such Account and
collateralized securities as valued by the custodian selected by Client of the Account, which
management fee will be calculated as of the last business day of the immediately preceding
calendar quarter. The management fee will be prorated based on the number of calendar days in
any partial quarter, such as the partial calendar quarter in which the relevant Agreement is
terminated. Torshen Capital will refund any portion of the management fee attributable to the
calendar days on which it did not manage the Client’s capital. The management fee will be billed
to each Account by Torshen Capital on a quarterly basis.
Torshen Capital does not charge a management fee to any Affiliated Accounts.
Fees and Expenses
Client shall be solely responsible for all commissions and other transaction charges, and any charge
relating to the custody of securities in the Account. The Management Fee covers only the
investment management services provided by the Firm and does not include brokerage
commissions, mark‐ups and mark‐downs, data feeds, accounting, legal, dealer spreads or other
costs associated with the purchase and sale of securities, custodian fees, interest, withholding and
transfer taxes or any other taxes, or other Account expenses. Clients shall be solely responsible for
these expenses. Please see Item 12. Brokerage Practices for additional information relating to
brokerage practices and commissions. The Firm will invoice the custodian of a Client directly for
such expenses, and the Client will be responsible for instructing the custodian to pay such expenses
from the Account or the Client may elect to pay such additional expenses directly.
Torshen Capital may agree to charge a reduced, alternative or modified fee for large asset size
accounts.
Neither Torshen Capital nor any of its supervised persons accepts compensation for the sale of
securities or other investment products.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2023)
[Brochure]
Item 7 – TYPES OF CLIENTS
Torshen Capital currently provides investment management services with respect to individuals,
high net worth individuals and trusts, each of which is beneficially owned by the principals or
employees of the Firm or their respective family members.
Torshen Capital expects to manage the accounts of family offices, high net worth individuals and
their families, foundations, endowments, institutional investors and other investors pursuant to
the Option Strategy. Each Client must invest a minimum of $1,000,000 (in cash or collateral of
comparable value) unless otherwise agreed to by Torshen Capital.