Gregory D. Schneiderman

Individual clients are charged an advisory fee that is based on the amount of assets we advise on (“Greshamadvised Assets”), subject to a minimum annual fee of $180,000. This asset-based fee is calculated as: 0.75% of the first $25,000,000, 0.50% for the next $25,000,000, and 0.30% for assets over $50,000,000. Individual clients are not charged a separate fee to invest in the Gresham Partnerships. However, investors in the Gresham Partnerships are subject to management fees and performance-based incentive allocations payable to the unaffiliated managers chosen by Gresham. Gresham can also charge an administrative services fee for consulting, reporting and other services provided for non-Gresham advised assets that is calculated at a discounted rate from the standard fee schedule or is an agreed-upon amount. The more Gresham-advised Assets that an investor has with Gresham or non-Gresham advised assets that receive other services from Gresham, the higher the fee that we will receive. Therefore, we have an incentive to encourage investors to increase the assets in these two categories.

Advisory and administrative services fees for Individual clients are typically collected quarterly in advance and are calculated as a percentage of the market value of assets advised on at the end of each calendar quarter. All fees are agreed upon with each Individual client and described in their Individual Client Financial Advisory Agreement. When determining the fee for an Individual client, Gresham will look at the current and potential Gresham-advised Assets, the number of households that will be provided investment and other services and the type and amount of those services, and adjustments may be made based on those considerations.

An Investment-Only client will be charged an annual management fee and has the option to choose to be charged an incentive fee through each Gresham Partnership in which they invest. Fees paid by an Investment-Only client, who may be a former Individual client, can be altered by mutual agreement between the General Partner and the client.

You will pay fees and other costs whether you make or lose money on your investments. Fees and other costs will reduce any amount you make on your investments over time. In addition, you may pay custodian fees and other transaction fees to other firms that are separate and in addition to the fees that are paid to Gresham. More information about our fees can be found in our Form ADV Part 2A. Please make sure you understand what fees and other costs you are paying.

When we act as your investment adviser, we have to act in your best interest and not put our interests ahead of yours. However, the way we invest may create some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. For example, we receive fees that reduce the value of your investments whether or not your investments increase in value.

Additional information on these topics can be found in our Form ADV Part 2A.

Our financial professionals are paid salaries as well as potential bonuses, with those who are members of our Investment Team having a portion of their bonus determined by the performance of the investments we manage for our clients. The 13 of our Financial Professionals who are the owners of the firm also share in the profits of the firm. Gresham derives all its compensation from fully disclosed fees paid by its clients, as described above. Gresham does not compensate any third party for client referrals, nor does Gresham receive any compensation from any third party in connection with the investment advice or other types of advice it provides its clients.