Fees and Compensation — Form ADV Part 2A (3/13/2026)
[Brochure]
Item 5 - Fees and Compensation
The details of the fees charged to each Client can be found in the Client’s respective offering,
investment management and/or governing documents. As a general rule, WCA charges its
Clients both management and performance-based fees. Whetstone reserves the right to
reduce, waive, calculate differently or otherwise negotiate the fees it charges its Clients or
any of its Clients’ Fund Investors.
Any changes in fee calculation would be communicated to Clients at least 30 days in advance.
Clients would have the option to accept or reject the changes or terminate their agreement,
as outlined in the investment management and other governing documents.
Management Fees
Management fees are typically equal to 1% of each Fund Investor’s net asset value on an
annual basis. Management fees are typically calculated and paid monthly and may be
deducted automatically from a Fund Investor’s capital account or billed to a Client.
Management fees are often paid in advance. In the event that a Fund Investor who is billed
management fees in advance terminates their relationship with the Firm mid‐billing cycle,
WCA will prorate the management fee for the unused portion of the period and promptly
refund any unearned fees.
More information about management fees is included in each Client’s respective offering,
investment management and/or governing documents.
Performance-based Compensation
Whetstone Allocation, LLC, (“WC Allocation”) is a Kansas limited liability company that is
controlled by David Atterbury. WC Allocation typically receives a performance-based
allocation from Clients and Fund Investors. This allocation ranges from 10% to 15% of the
amount by which a Client or Fund Investor’s capital account exceeded its high-water mark
during the applicable time period. These allocations may be calculated and processed on a
quarterly or an annual basis and may be automatically deducted from a Fund Investor’s
capital account or billed to a Client. More information about performance-based
compensation is included in each Client’s respective offering, investment management
and/or governing documents.
Waivers, Reductions and Other
WCA and WC Allocation reserve the right to waive, reduce or otherwise negotiate any or all
fees for existing or future clients or Fund Investors in their sole discretion. Fund Investors
should consult the offering documents for each Client for more details on the calculation of
fees and expenses.
Because Clients and Fund Investors have different fee arrangements, WCA may have a
conflict of interest whereby WCA would have an incentive to allocate more profitable
trades to Clients that have a higher fee structure. WCA is aware of this conflict and seeks to
address it by allocating trades in a fair and equitable manor, as described in more detail in
Account Minimums and Types of Clients — Form ADV Part 2A (3/13/2026)
[Brochure]
Item 7 - Types of Clients
As noted above, we provide discretionary investment advisory services to private
investment vehicles (commonly referred to as “hedge funds” or “private funds”). These
private funds are offered to high net worth, financially sophisticated individuals and
institutional investors. Fund Investors must meet certain minimum suitability requirements
and have minimum contribution requirements as set forth in each Client’s offering and/or
governing documents.
WCA may, in its sole discretion, waive or modify any minimum investment requirement.
Whetstone may also have the right to waive or modify any provision of the governing or
offering documents of the Funds for existing or new Fund Investors. The terms of a Fund
Investor’s investment in a Client may be varied through side letters or otherwise.
Filed 2021-10-18 (D/A) · Exemption 3(c), 3(c)(7) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Commission $56,000 · Net Assets Decline to Disclose
Filed 2021-10-18 (D/A) · Exemption 3(c), 3(c)(7) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Commission $56,000 · Net Assets Decline to Disclose
Filed 2025-10-15 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $500,000 · Remaining Indefinite · Duration More than one year · Commission $152,537 · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
0
0.0
(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
3
415.1
(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