Fees and Compensation — Form ADV Part 2A (6/26/2026)
[Brochure]
Item 5. Fees and Compensation
Asset-Based Compensation
The Adviser generally charges each client an investment management fee based on the value of the
client’s assets under management that ranges from 1.5% to 2.0% per annum. Investment
management fees are generally charged each month in arrears based on the total market value of the
assets in the client account (including net unrealized appreciation or depreciation of investments and
cash, cash equivalents and accrued interest) on the last day of the month. If a new client account is
established during a month or a client makes an addition to its account during a month, the investment
management fee will be prorated for the number of days remaining in the month. If a client’s
investment management agreement is terminated during a month, the fee payable to the Adviser will
be calculated based on the value of the assets on the termination date and prorated for the number
of days during the month in which the investment management arrangement was in effect.
Generally, these fees are not negotiable.
Performance-Based Compensation
The Adviser may also be paid a performance-based fee, which is compensation that is based on a share
of capital gains on or capital appreciation of the assets of a client. This compensation may be paid to
the Adviser or to a related person of the Adviser and ranges from 15% to 20%, subject to a high
watermark.
Generally, these fees are not negotiable.
The Adviser receives the investment management fee from client accounts held by the client’s
custodian.
In addition to paying investment management fees and, if applicable, performance-based fees or
other compensation, client accounts will also be subject to other investment expenses such as,
without limitation, fees and expenses for legal, auditing and other professional services, registration
and filing fees and other expenses due to regulatory, supervisory and fiscal authorities or agencies in
various jurisdictions in relation to the obtaining and maintenance of authorizations, registrations or
stock exchange listings of the client or its securities or otherwise and all professional and other fees
and expenses in connection therewith and the cost of publication of the net asset value and other
fees, costs and expenses incurred in connection with the conduct of the client’s business, including
the payment of premiums for directors and officers liability insurance and such similar insurance and
the offering or promotion of the client’s securities. Client accounts will also be responsible for all
operating expenses and extraordinary expenses which may be incurred from time to time.
Account Minimums and Types of Clients — Form ADV Part 2A (6/26/2026)
[Brochure]
Item 7. Types of Clients
The Adviser’s clients consist of pooled investment vehicles. The initial and additional subscription
minimums for these clients are disclosed in their respective offering memoranda.
Filed 2023-03-30 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2021-04-19 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2021-09-16 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2020-07-10 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration One year or less · Revenue Decline to Disclose
Filed 2022-11-23 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Revenue Decline to Disclose
Filed 2025-04-11 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2019-09-06 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Revenue Decline to Disclose