FEES & COMPENSATION
Portfolio Management Fee
Portfolio management is provided on an asset-based fee arrangement. Our management fee is
calculated based on the aggregate market value of your account on the last business day of
the previous calendar month multiplied by one-twelfth of the corresponding annual
percentage rate (e.g., 3.00% ÷ 12 = 0.25%). Portfolio management fees are non-discretion. As
your portfolio value exceeds the tier level, either through additional deposits or asset growth,
a fee break will occur. The tier breaks are as follows:
Annual Fee
Portfolio Value
Rate
Up to $5,000,000 ............................................... 3.00%*
Over $5,000,000................................................ 2.00%
* Fees of 3.00% or higher are generally considered excessive and higher than fees charged by the majority of
investment advisors. Therefore, it is possible that you could contract with another investment advisor and receive
equivalent service and performance at a lower cost.
We generally require a minimum initial investment of $100,000 to open a managed account;
however, we retain the right to waive or reduce this minimum if we feel circumstances are
warranted.
Form ADV: Part 2A
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DISCLOSURE BROCHURE
Protocols for Portfolio Management
The following protocols establish how we handle our portfolio management accounts and what
you should expect when it comes to: (i) managing your account; (ii) your bill for investment
services; (iii) deposits and withdrawing funds from your account(s); and (iv) other fees charged
to your account(s).
Discretion
We will establish discretionary trading authority on all management accounts to execute
securities transactions at anytime without your prior consent or advice.
At anytime however, you may impose restrictions, in writing, on our discretionary authority
(i.e., limit the types/amounts of particular securities purchased for your account, exclude
the ability to purchase securities with an inverse relationship to the market, limit our use of
leverage, etc.).
Billing
Your account will be billed monthly in arrears. For new managed accounts opened in mid-
month, our fee will be based upon a pro-rated calculation of fair market value of the
assets managed for the current monthly period. For existing management accounts, pro-
rated adjustments will be made for deposits between billing cycles.
Advisory fees will be deducted first from any money market funds or balances. If such assets
are insufficient to satisfy payment of such fees, a portion of the account assets will be
liquidated to cover the fees. Such liquidation may affect the relative balances of the
account.
Fee Exclusions
The above fees for all of our portfolio management services are exclusive of any charges
imposed by the custodial firm who has custody of your account; including, but not limited to:
(i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such
as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit
balances, margin interest, certain odd-lot differentials and mutual fund short-term
redemption fees; and (iv) brokerage and execution costs associated with securities held in
your managed account. There can also be other fees charged to your account that are
unaffiliated with our management services.
In addition, all fees paid to us for portfolio management services are separate from any fees
and expenses charged on mutual fund shares by the Investment Company or by the
investment advisor managing the mutual fund portfolios. These expenses generally include
management fees and various fund expense, such as 12b-1 fees. Redemption fees, account
fees, purchase fees, contingent deferred sales charges, and other sales load charges may
occur but are the exception within managed accounts at institutional custodians. A complete
explanation of these expenses charged by the mutual funds/ETFs is contained in each mutual
fund’s or ETF’s prospectus. You are encouraged to carefully read the fund prospectus.
For more information on the custodial firm that we will recommend to custody your portfolio
accounts, see Item 12, “Brokerage Practices”.
Form ADV: Part 2A
© eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com
DISCLOSURE BROCHURE
Termination of Portfolio Management Services
To terminate our portfolio management services, either party (you or us) by written
notification to the other party, may terminate the Investment Advisory Agreement at any
time, provided such written notification is received at least 24-hours prior to the date of
termination. Such notification should include the date the termination will go into affect along
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