Registrant holds a limited power of attorney to act on a discretionary basis with funds of the individually managed accounts. Client funds are deposited in either a brokerage firm or a bank custodian account.
Compensation provided to Registrant is negotiable and varies, but typically consists of the following components. Registrant charges each individually managed account either (a) an annual fee between 1% and 2.5% of assets under management, which amount is payable in quarterly installments at the beginning or end (depending on the provisions of each client’s account agreement) of each calendar quarter based on the net market value of the client’s account on the date the fee accrues and becomes payable or (b) a performance fee equal to 10% of net profits of the account (including both realized and unrealized gains and losses). Performance fees are assessed in arrears on a quarterly or annual basis, and are only applied to profits that exceed the cumulative losses previously incurred by or allocated to the respective clients. Registrant complies with Rule 205-3 under the Investment Advisers Act of 1940, as amended, to the extent required by applicable law. Client accounts that invest in mutual funds also will pay, indirectly, investment advisory fees to the managers of those mutual funds. Registrant believes that its fees are competitive with fees charged by other investment advisers for comparable services. Comparable services may be available, however, from other sources for lower fees than those charged by Registrant.
Registrant generally requires a minimum of $1,000,000 to open an individually managed account, but reserves the right to waive this minimum.
Except as may be otherwise negotiated in particular cases, a client may terminate an individually managed account by giving 30 days’ written notice. Expenses, a pro rata portion of the annual fee and the performance fee through the date of termination are charged to the client. All prepaid but unearned advisory fees are refunded to the client on termination of an account.