objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Under certain circumstances, the Advisor will accept or maintain custody of Client’s funds or securities. Please
see Item 15 – Custody for more information. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the investment management agreement. Please see Item 12 – Brokerage
Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
FINANCIAL CONSULTING SERVICES: The Advisor’s financial consulting services will typically involve
recommendations made to the Client based on the Client’s financial goals and objectives. Financial planning
consultations are not typically accompanied by a written summary of observations and recommendations, as
the Advisor’s process is less formal. Financial consulting may encompass investment and non-investment
related matters, including, but not limited to, estate planning, tax planning and insurance needs.
Corps Capital, when appropriate, will recommend the services of other non-advisory professionals for
implementation purposes (i.e., attorneys, accountants, brokers, insurance agents, etc.). The Client is under no
obligation to engage the services of any such recommended professional. The Client retains absolute discretion
over all such implementation decisions and is free to accept or reject any recommendation from Corps Capital
or its Advisory Persons.
Additionally, it remains the Client’s responsibility to promptly notify Corps Capital if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Corps
Capital’s previous recommendations and/or services. If Corps Capital has been engaged to provide non-
discretionary consulting
services relative to the Client's other unaffiliated investment professionals, including
investment assets for which Corps Capital does not maintain any trading authority (the “Excluded Assets”), the
Client and/or the Client's other investment professionals/advisors that maintain trading authority, and not Corps
Capital, shall be, and remain, exclusively responsible for the investment performance of the Excluded Assets.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
PRIVATE FUND ADVISOR SERVICES
The Advisor provides portfolio management services to Corps Capital Income Fund I, LLC, a pooled investment
vehicle (herein the “Fund”). These services are detailed in the offering documents for the Fund, which include as
applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements,
separate disclosure documents, and all amendments thereto (“Offering Documents”).
The Advisor manages the Fund based on the investment objectives, policies and guidelines as set forth in the
respective Offering Documents and not in accordance with the individual needs or objectives of any particular
investor therein. Each prospective investor interested in investing in the Fund is required to complete a subscription
agreement in which the prospective investor attests as to whether or not such prospective investor meets the
qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with
such an investment.
In general, investors in the Fund are not permitted to impose restrictions or limitations. However, the Advisor may
enter into side letter agreements with one or more investors that may alter, modify, or change the terms of interest
held by investors. Certain types of side letters creates a conflict of interest among the Advisor and investors, and/or
between investors themselves.
Please note, the Advisor is affiliated and under common control with Corps Capital Fund Management, LLC,
the General Partner of the Fund (“General Partner”). Due to the affiliation, the Advisor has an incentive to
recommend investments in the Fund as owners may benefit financially in their individual capacity through the
receipt of additional revenue. Additionally, the General Partner charges performance-based fees. Please see