Item 5 Fees and Compensation
Investment Management Fees
Fees: Our asset management fees are generally assessed quarterly based upon a percentage of the
client's assets under management as of the close of business on the predetermined business day.
Clients may request fees be assessed on a monthly basis. Asset management fees may be assessed
in advance, arears or other timeframes based on the fund billing processes. The initial asset
management fee is due at the beginning of the quarter following the inception date and is based on the
client's initial investment in the account prorated for the number of days assets have been deposited in
a client's account before a fee is assessed (arrears billing). Therefore, the first asset management fee
billing will include a prorated fee based on arrears billing. Additionally, certain of our Associated
Persons, in their individual capacities, may offer securities brokerage services and insurance products
under a separate commission arrangement.
For Plan services, we charge either a fixed annual fee ranging up to $200,000 or an annual fee ranging
between 0.01% and 1% of the value of the Plan's assets. Our fees are negotiable, based on the scope
and complexity of the services provided. Our fees may be paid directly by the Plan sponsor, out of the
Plan's assets, or automatically deducted from the Participants' accounts.
Clients may incur transaction charges for trades executed in their accounts. These transaction charges
are separate from our fees and will be disclosed by the brokerage firm through which the trades are
executed. These transaction charges vary based on the type of investment (e.g., stock, mutual fund,
ETF, etc.) and are paid to the custodian of client assets. We do not receive any portion of the
transaction charges.
Clients may also pay separately incurred expenses such as charges imposed directly by a mutual
fund, index funds or ETFs, all of which are disclosed in the fund's prospectus (i.e., fund management
fees and other fund expenses, such as 12b-1 fees). We do not receive any portion of the transaction
charges.
If we utilize the services of a Platform Provider or Independent Manager, clients will also pay those
parties' separate fees, either under the Client Agreement or the Provider Agreement.
Fee Payment: Fees are generally automatically deducted from a client's account, or the plan
participant’s account, either by the Firm or by the Platform Provider. As part of this process, clients
must understand and acknowledge the following:
The client provides authorization permitting fees to be directly paid by the terms outlined in
either or both of the Client Agreement and the Provider Agreement;
The custodian, or in certain cases the Firm or the Platform Provider, calculates the advisory
fees and the custodian or the Platform Provider deducts advisory fees from the client's account;
Where a Platform Provider or Investment Manager is used, the Platform Provider will cause the
custodian to deduct a single fee from the client's account and pay the Investment Manager's
fee, the Firm's fee, and retain the balance; and
The custodian sends statements at least quarterly to the client showing all disbursements for
his or her account, including the amount of the advisory fees paid to the Firm.
A client may request the Firm invoice the client directly for Fees. The client is responsible for sending
payment in a timely manner to the address of record provided on the invoice.
Retirement Plan Consulting Fees
For Plan services, we charge either a fixed annual fee ranging up to $200,000 or an annual fee ranging
between 0.01% and 1% of the value of the Plan's assets. Our fees are negotiable, based on the scope
and complexity of the services provided. Our fees may be paid directly by the Plan sponsor, out of the
Plan's assets, or automatically deducted from the Participants' accounts. Fees are based on the value
of the Plan's assets and are charged according to the established fund billing processes. In the event
that we act as an "investment manager" as defined by ERISA 3(38), an additional five bps will typically
be assessed. For more information, please refer to the Client Agreement.
Commissions for Sale Charges for Recommendations of Securities
Clients can engage certain persons associated with the Firm (but not the Firm) to render securities
brokerage services under a separate commission-based arrangement. Clients are under no obligation
to engage such persons and may choose brokers or agents not affiliated with us.
Under this arrangement, our Associated Persons, in their individual capacities as registered
representatives of a third party broker-dealer ("Broker"), may provide securities brokerage services
and implement securities transactions under a separate commission-based arrangement. Our
Associated Persons may be entitled to a portion of the brokerage commissions paid to the Broker, as
well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. We may
also recommend no-load or load-waived funds, where no sales charges are assessed. Prior to
effecting any transactions, clients are required to enter into a separate account agreement with the
Broker. We do not receive any portion of the commissions or transactional fees charged by any Broker.
A conflict of interest exists to the extent that we recommend the purchase of securities where our
Associated Persons receive commissions or other additional compensation as a result of the
Associated Person 's recommendations.
We have procedures in place to ensure that any recommendations made by such Associated Persons
are in the best interest of clients. For certain accounts covered by ERISA and such others that we
deem appropriate, we may provide our investment advisory services on a fee-offset basis. In this
...