Item 5 – Fees and Compensation
Our annual advisory fee is generally based upon a percentage of the market value of assets
placed under our management. The annualized fee (the “Fee”) for the advisory services to be
provided by Bristlecone Advisors is set forth in the agreement we have with you. Client’s actual
fee may be higher or lower than the standard fee schedules below, based on a number of
factors including but not limited to the number of accounts / portfolios, size of the aggregate
assets under management, relationship to other clients or accounts, complexity and scope of
arrangement, or the potential for additional contributions or assets managed, among others.
Our advisory fee is inclusive of all our investment and wealth management services. Our standard
annual client advisory Fee Schedule is as follows:
Assets Managed Annual Advisory Fee
First $3.0 million 1.00%
Next $2.0 million (up to $5 million) 0.80%
Next $5.0 million (up to $10 million) 0.60%
Assets over $10 million 0.50%
Assets over $100 million Negotiated on all assets
If a client requests extensive family office services, additional fees may apply.
For certain larger accounts comprised only of fixed income assets, the following Fixed Income
Fee Schedule may apply:
Assets Managed Annual Advisory Fee
First $5.0 million 0.45%
Next $5.0 million (up to $10 million) 0.35%
Assets over $10 million 0.25%
These fee schedules are “tiered.” As an example, for a non-fixed income account or relationship,
a $4 million portfolio would be charged 1.00% on the first $3 million of assets and 0.80% on the
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next $1 million. For fixed income only accounts / relationships, the fee is 0.45% on the first $5
million, 0.35% on the amount over $5 million, etc.
Some clients may be grandfathered under a lower fee structure or have been provided with
material discounts from the fee schedule.
Billing: Fees are generally billed quarterly in advance using the average daily account value
based on the previous quarter and are billed on the first day of the new calendar quarter.
For newly engaged client households, who are not added to an existing or established family
billing group, the first full quarterly fee is also billed in advance but calculated using the last day
quarter end balance since there is no previous quarter data for which to calculate an average
daily account value.
For new financial accounts opened after engaging our advisory services, such as opening a
second IRA or other brokerage account, fees are charged in arrears based upon the inception
value of the accounts. We determine the inception date when we believe, in our best judgment,
that the account(s) are fully funded, nearly fully funded or being actively managed and traded.
The fee is pro-rated for the number of days remaining in the opening calendar quarter that we
provide our services to you. This methodology is also used to pro-rate the first partial fee for
newly engaged client households. In this scenario we may also consider the inception date to
be the date we entered into an Advisory Agreement with you.
Upon termination of an Advisory Agreement, we will calculate the pro-rated refund of pre-paid
and un-earned fees based upon the average of the daily balance of the account(s) through the
date of termination. This refund of pre-paid and unearned fees is delivered promptly (within 30
days or less) after the termination date.
Fee Payment; Direct Debit of the Advisory Fee: In the Advisory Agreement with us, you authorize
Bristlecone to directly debit our advisory fees from your custodial accounts. We typically send the
debit request to your independent, qualified custodian, within 15 days following the end of each
calendar quarter. If requested, we will provide you with an itemized statement following each
direct debit request we make to your custodian. The Advisory Agreement also gives us the
authority and discretion to create liquidity sufficient to pay these fees. Upon client request, we
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may household accounts for the purpose of calculating fees. For multi-account relationships, fees
may be paid out of a designated account.
Termination: An advisory relationship with us can be revoked at any time, by either party, for any
reason upon written notice (as documented in our written agreement with you). Upon termination
of any agreement, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid
fees will be due and payable.
Valuation: Bristlecone charges our advisory fees and reports performance on your accounts
based upon the total value of your accounts as follows:
1. For marketable securities, the prices provided by a leading vendor, which provides our
portfolio accounting system) are used for client reporting and fee calculations.
2. If your account(s) include illiquid private securities (e.g., real estate, equity, or hedge
funds) the investment value for the current quarter is based upon the most recent valuation
data provided to us by our client (through statements) or as provided directly to us by the
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