Item 5 Fees and Compensation
Private Account Strategies
Our annual fees for our Private Account direct clients are based upon a percentage of assets
under management for equity accounts is from 0.35% to 2%. Direct Clients with accounts over
$100 million may be less than 0.35%. This fee includes both portfolio management and advisory
services and can vary based on services provided. The fee does not include any account charges
from the custodian including but not limited to annual account fees. Account size and family
account bundling may reduce management fees. The maximum fee charged to a client from all
sources will be 2%.
The advisory fee is payable quarterly in advance, based on the balance in the Account at the
close of the market on the last business day of the prior quarter. The initial billing of the account
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when it is first opened will be based on the starting value of the account. Bronson may use a
third-party reporting system for billing services. The fees are debited by the custodian as per the
Advisor. Client authorizes custodian to deduct from this account and pay to Adviser the advisory
fee for each applicable period. Custodian will send the client a statement showing all amounts
paid from the account, including all additional custodial fees. Direct payment of fees from Client
shall not be accepted.
A minimum of $10,000,000 of assets under management is required for our Private Account
service. This account size may be negotiable under certain circumstances. Bronson may group
certain related client accounts for the purposes of achieving the minimum account size and
determining the annualized fee.
Institutional Management Services ("IMS")
Bronson also provides portfolio management services to independent investment advisors and
managed account platforms through independent broker-dealers. Bronson’s annual institutional
management fee is 0.35% for private account management. This fee is for portfolio management
services only. The fee does not include any account charges from the custodian including but not
limited to ticket charges or annual account fees.
Generally, the independent advisor will include an investment advisor fee in addition to our
portfolio management fee.
The advisory fee is payable quarterly in advance, based on the balance in the Account at the
close of the market on the last business day of the prior quarter. In any partial calendar quarter,
the advisory fee will be prorated based on the number of days that the account was open during
the quarter. Bronson may use a third-party reporting system for billing services. The Institutional
Client is invoiced for the fees and are due on receipt.
Limited Negotiability of Advisory Fees: Although Bronson has established the aforementioned
Private and Institutional fee schedules, we retain the discretion to negotiate alternative fees,
which may be higher or lower than 0.35%, on a client-by-client basis. Client facts, circumstances
and needs are considered in determining the fee schedule. These include the complexity of the
client, assets to be placed under management, anticipated future additional assets; related
accounts; portfolio style, account composition and reports amongst other factors. The specific
annual fee schedule is identified in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum account
size requirements and determining the annualized fee. Discounts, not generally available to our
advisory clients, may be offered to direct family members and associated persons of our firm.
General Information
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by
either party, for any reason upon receipt of written notice. As disclosed above, certain fees are
paid in advance of services provided. Upon termination of any account, any prepaid, unearned
fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate
the reimbursement according to the number of days remaining in the billing period.
Mutual Fund Fees: All fees paid to Bronson for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders.
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These fees and expenses are described in each fund's prospectus. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest
in a mutual fund directly, without our services. In that case, the client would not receive the
services provided by our firm which are designed, among other things, to assist the client in
determining which mutual fund or funds are most appropriate to each client's financial condition
and objectives. Accordingly, the client should review both the fees charged by the funds and our
fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate
the advisory services being provided.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for
the fees and expenses charged by custodians and imposed by broker dealers, including, but not
limited to, any transaction charges imposed by a broker dealer with which an independent
investment manager effect transaction for the client's account(s). Please refer to the "Brokerage
Practices" section (Item 12) of this Form ADV for additional information.
ERISA Accounts: Bronson is deemed to be a fiduciary to advisory clients that are employee
benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986
(the "Code"), respectively. As such, our firm is subject to specific duties and obligations under
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