Item 5 - Fees and Compensation
Asset Management Services
Fees are negotiable and are not based on a share of capital gains, or capital appreciation of the funds or any portion of
the funds.
Bell Rock’s advisory fees will be charged in advance on a calendar quarterly basis based upon the market value of your
portfolio (including cash and cash equivalents) on the last business day of the calendar quarter. The advisory fee may
exceed the money market yield. Accounts managed for a part of the quarter will be charged a prorated portion of the
advisory fees for the quarter. The initial fee will be based on the value of the account upon account establishment and
prorated for the remaining days in the current calendar quarter and billed at the end of the first quarter following the
opening of the account.
Bell Rock can deduct its fees directly from your account provided you have given Bell Rock written authorization by
signing the Investment Management Agreement and custodial application. Written authorization to have advisory fees
deducted directly from your account is granted in the management agreement executed between you and Bell Rock.
The advisory fees may be payable by invoice, upon request, for of management services and paid directly by you upon
receipt of the invoice from Bell Rock. You will be provided with at least quarterly statements directly from the account
custodian reflecting the deduction of Bell Rock’s fees from your account. If your account does not contain sufficient
funds to pay advisory fees, Bell Rock has the authority to sell or redeem securities in sufficient amounts to pay its
advisory fees. You may reimburse the account for advisory fees paid to Bell Rock, except for ERISA and IRA accounts.
You may make additional deposits and partial withdrawals to the account. Additional deposits to the account and
partial withdrawals from the account impacts Bell Rock’s management of the account, particularly partial withdrawals
from the account. Prorated fee adjustments will be charged to you for additional deposits to the account, and a
prorated credit of fees will be issued for partial withdrawals from the account. No fee adjustments will be made for
Account appreciation or depreciation due to market performance.
Account Size Maximum Annual Fee
$0 to $1,000,000 249 basis points
$1,000,000 to $5,000,000 179 basis points
$5,000,000 and above 140 basis points
Fixed Income Only (any $ amount) 100 basis points
We may negotiate a lower advisory fee, charge a flat fee or have the right to waive fees. Fees may vary based on the
size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us
and the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. If you have
multiple accounts under management with Bell Rock, all of your managed accounts will be aggregated together to
determine the fee.
The quarterly fee formula is as follows and will be adjusted for inflows or outflows of funds during the previous quarter.
End of quarter account value x quarterly fee (i.e. annual fee /4) = quarterly fee
Fee adjustments for inflow and outflows are calculated as follows.
# of days/days in the calendar quarter x quarterly fee = fee adjustment
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Bell Rock Capital | February 2023
In addition to the advisory fees above, you will pay transaction fees for securities transactions executed in your account
in accordance with the custodian’s transaction fee schedule. Additionally, you will pay fees for custodial services,
account maintenance fees, transaction fees, and other fees associated with maintaining the account. You will pay your
proportionate share of the internal fund’s management and administrative fees and sales charges imposed by any
mutual fund or ETF held in your account. Such fees are not shared with Bell Rock and are compensation to the fund-
manager. You should read the fund’s prospectus prior to investing. Many custodians are no longer charging fees for
trading in certain securities such as exchange-traded equities and ETF’s.
Bell Rock may change the above fee schedule upon 30-days prior written notice to you.
Bell Rock, in its sole discretion, may charge a lesser investment management fee based upon certain criteria (i.e.
anticipated future earning capacity, personal relationship, anticipated future additional assets, dollar amount of assets
to be managed, related accounts, industry fee compression, account composition, negotiations with client, etc.). As
result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees.
Bell Rock charges an annual $100 administrative fee. This fee is in addition to the investment advisory fee described
above and under certain circumstances may be waived. This fee is for the increased cost of technology used to manage
your account.
ANY QUESTIONS: Bell Rock’s Chief Compliance Officer remains available to address any questions that a client or
prospective client has regarding the above.
Termination Provisions
Either party may terminate management services by telephone or confirmed in writing. The management fee will be
pro-rated to the date of termination, for the quarter in which the termination notice was given, and the unearned fee
refunded to your account, or mailed to you, as indicated in your Agreement. Upon termination, you are responsible for
monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those
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