Legal
Fee disclosure
Draft — not yet in force — requires legal and compliance approval
This document is a placeholder drafted for internal review. It is not legal advice, is not final, and does not yet govern any relationship with Black Pool Capital. Final policies will be published before any service becomes available.
Purpose and status
This document is a framework draft prepared for internal review. It describes how Black Pool Capital intends to disclose the fees it would charge and the third-party costs a client could incur, if and when a regulated service exists. It is not final, is not in force, and requires legal and compliance approval. No fee model has been approved, no fees are payable, and no figures are stated in this draft.
Management fee framework
Any future fund could involve a management fee for managing the fund's portfolio. The basis on which such a fee would be calculated, charged and collected is not yet defined. No rate, share-class structure or minimum has been set.
Performance fee framework
Any future service could include a performance-related component. Whether a performance fee would apply, and if so how it would be structured, is not yet decided and is subject to regulatory and commercial approval.
High-water mark, hurdle rate and crystallisation
If a performance fee were used, it could incorporate mechanisms such as a high-water mark (so that a performance fee is charged only on gains above a previous peak), a hurdle rate (a threshold return below which no performance fee accrues), and a defined crystallisation frequency (when any accrued performance fee becomes payable). Whether and how any of these would apply is undetermined.
Brokerage and transaction costs
Executing transactions typically incurs brokerage commissions, spreads and related transaction costs charged by executing parties. These would depend on confirmed brokerage arrangements, which do not exist today.
Custody and administration costs
Holding fund assets typically incurs custody, safekeeping and administration charges levied by the fund's service providers. These would depend on service-provider arrangements, which do not exist today.
Foreign-exchange costs
Transactions or holdings in a currency other than the client's reference currency can incur foreign-exchange conversion costs and spreads. The basis and level of any such costs would depend on the arrangements ultimately in place and is not yet defined.
Market-data and product costs
Where investments involve collective or structured products, those products may carry their own internal costs borne indirectly by investors, and certain services may involve market-data charges. Any such costs would be identified once the product scope and arrangements are settled.
Taxes and duties
Investment activity can attract taxes and duties, such as transaction taxes and withholding taxes, which depend on jurisdiction and on the client's individual circumstances. Black Pool Capital would not provide tax advice. Applicable taxes are outside Black Pool Capital's control and are not quantified here.
Transfer and termination costs
Subscribing to or redeeming from a future fund could involve charges, such as subscription or redemption fees or third-party transfer costs. Any such costs would depend on the fund's terms and are not yet defined.
Worked-example framework
When a fee model is approved, Black Pool Capital intends to illustrate the total cost of the service with worked examples showing how charges accumulate over a period. Because no rates exist, no example is provided here. Any future example would use clearly labelled, approved figures and would not imply a particular outcome.
Missing factual inputs
The following remain undetermined and are required before this document could be finalised: the management-fee basis and level; whether any performance fee applies and its mechanics; the fund's operating costs and service-provider arrangements; applicable product and data costs; and the treatment of subscription and redemption charges. No figure may be assumed.
Status: draft placeholder. Last updated: not yet published.