Item 5 Fees and Compensation
A.
INVESTMENT MANAGEMENT SERVICES
The Registrant annual investment advisory fee for discretionary investment advisory
services shall be based upon a percentage (%) of the market value of the assets placed under
the Registrant’s management, generally between 0.75% up to 1.25% as follows:
Assets Under Management Annualized Fee
First $500,000 1.25%
From $500,000 to $1,000,000 1.00%
From $1,000,000 to $2,000,000 0.85%
Above $2,000,000 0.75%
* The Registrant, at its sole discretion, may charge a lesser investment management fee.
As result, similarly situated clients could pay different fees. In addition, similar advisory
services may be available from other investment advisers for similar or lower fees.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Registrant’s planning and consulting fees are negotiable, but generally range from $1,500
to $15,000 on a fixed fee basis, and from $150 to $300 on an hourly rate basis, depending
upon the level and scope of the service(s) required and the professional(s) rendering the
service(s).
RETIREMENT PLAN CONSULTING
The Registrant’s pension consulting fee is based upon the market value of the assets in the
plan. Each client’s fee schedule is dependent upon services provided and is clearly detailed
in Retirement Plan Consulting Agreement executed by the client. However, the Registrant
typically charges up to 1.00% for pension consulting services.
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant's Investment Advisory Agreement and the custodial/clearing
agreement may authorize the custodian to debit the account for the amount of the
Registrant's investment advisory fee and to directly remit that management fee to the
Registrant in compliance with regulatory procedures. In the limited event that the
Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Fidelity Investments
(“Fidelity”) serve as the broker-dealer/custodian for client investment management assets.
Broker-dealers such as Fidelity charge brokerage commissions, transaction, and/or other
type fees for effecting certain types of securities transactions (i.e., including transaction
fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or
other type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian. While certain custodians, including Fidelity, generally (with the potential
exception for large orders) do not currently charge fees on individual equity transactions
(including ETFs), others do.
There can be no assurance that Fidelity will not change their transaction fee pricing in the
future.
Fidelity may also assess fees to clients who elect to receive trade confirmations and account
statements by regular mail rather than electronically.
Clients will incur, in addition to Registrant’s investment management fee, brokerage
commissions and/or transaction fees, and, relative to all mutual fund and exchange traded
fund purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses).
D. Registrant's annual investment advisory fee shall be prorated and paid quarterly, in
advance, based on the daily weighted average balance of the assets under management
during the previous quarter, including, to the extent applicable, any accrued interest or
dividends. The Registrant does not require a minimum asset level or impose a minimum
annual fee for investment advisory services.
To the extent that aggregate client deposits or withdrawals during a particular billing period
meet or exceed $50,000, a prorated adjustment will be added or subtracted from the
following quarter’s calculated fee to compensate for the change in the amount of client
assets under management during the previous quarter.
The Registrant utilizes Orion to calculate quarterly fees. Orion’s method for determining
account values differs from the method used by Fidelity. As a result, the fees charged to
accounts maintained at Fidelity may deviate slightly (higher or lower) than if the Registrant
relied on Fidelity’s method for determining account values. Because the Registrant charges
its fee based upon a daily weighted average balance, the Registrant believes any differences
shall be immaterial.
The advisory agreement between the Registrant and the client will continue in effect until
terminated by either party by written notice, or otherwise in accordance with the terms of
the Agreement. Upon termination, the Registrant shall refund the pro-rated portion of any
advanced advisory fee paid based upon the number of days remaining in the billing quarter.
E. Securities Commission Transactions. In the event that the client desires, the client can
engage Registrant’s representatives, in their individual capacities, as registered
representatives of Purshe Kaplan Sterling Investments (“PKS”), a FINRA member broker-
dealer, to implement investment recommendations on a commission basis. In the event the
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