Item 5 Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
If a client determines to engage the Registrant to provide discretionary or non-discretionary
investment advisory services on a fee-only basis, the Registrant’s standard annual investment
advisory fee is tiered and based on the market value of the assets placed under the Registrant’s
management as follows.
Market Value of Account Annual Fee %
On the first $1,000,000 1.00%
On the next $2,000,000 0.80%
On the next $2,000,000 0.70%
On the next $5,000,000 0.60%
On the balance 0.50%
The Registrant’s investment advisory fee is negotiable at Registrant’s discretion, depending upon
objective and subjective factors including but not limited to: the amount of assets to be managed;
portfolio composition; the scope and complexity of the engagement; the anticipated number of
meetings and servicing needs; related accounts; future earning capacity; anticipated future
additional assets; the professional(s) rendering the service(s); prior relationships with the Registrant
and/or its representatives, and negotiations with the client. Certain legacy clients may have also
accepted different pricing and may therefore receive services under different fee schedules than as
set forth above. Because of these factors, similarly situated clients could pay different fees, the
services to be provided by the Registrant to any particular client could be available from other
advisers at lower fees, and certain clients may have fees different than those specifically set forth
above.
FINANCIAL PLANNING, TAX ADVICE, CONSULTING AND TRUSTEE SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning, tax advice, and/or consulting services
(including investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Registrant’s planning and consulting fees are negotiated
in advance with clients and can be on a fixed fee or hourly rate basis, depending upon the level and
scope of the service(s) required and the professional(s) rendering the service(s). Additionally, on
occasion at the specific request of a client and in their individual capacity, employees or members
of the Registrant may serve as a trustee or co-trustee of a trust that the client may be the grantor of
or beneficiary. In such situations, an additional fee may be charged to the client and/or the account
for serving in such capacity. The client is under no obligation to utilize employees or members of
the Registrant as trustees.
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. The Registrant generally deducts fees and/or bills clients quarterly in advance,
based upon the market value of the assets on the last business day of the previous quarter, subject
to adjustment for inflows and outflows. In the event that there is insufficient cash in a client’s
account when the Registrant deducts its fees, the Registrant will generally sell securities to make
available enough cash for its fee. This could result in tax consequences. Certain clients are billed
on different schedules depending upon their particular situation and arrangement with the
Registrant.
C. As discussed below, unless the client directs otherwise or an individual client’s circumstances
require, the Registrant shall generally recommend that Charles Schwab and Co., Inc. (“Schwab”)
or Fidelity Investments (“Fidelity”) serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab and Fidelity charge transaction fees for
effecting certain securities transactions (i.e. transaction fees are charged for certain mutual funds
and mark-ups and mark-downs are charged for fixed income transactions). In addition, client
accounts may invest in mutual funds (including money market funds) and ETFs that have various
internal fees and expenses (i.e. management fees), which are paid by these funds but ultimately
borne by clients as a fund shareholder. These internal fees and expenses are in addition to the fees
charged by the Registrant. Also, if an independent investment manager is used, the independent
manager will charge fees to the client in addition to Registrant’s investment management fee.
D. Registrant's annual investment advisory fee shall be prorated and are generally paid quarterly, in
advance, based upon the market value of the assets on the last business day of the previous quarter,
subject to adjustment for inflows and outflows. Certain clients are billed on different schedules
depending upon their particular situation and arrangement with the Registrant. The Registrant does
not generally require an annual minimum fee, but generally requires a $1,000,000 minimum
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