Item 5 – Fees and Compensation
Accounts can be established on either a Wrap or Non-Wrap Basis. Wrap account fees cover:
investment advisory services, asset management, trading costs, and other services provided in
the management of the account. Non-wrap accounts might not include trading costs and other
services fees covered by the annual fee, and they will be charged separately to the account on
an as-used basis. Lower fees for comparable services may be available from other sources.
Cambria does not manage accounts differently based on their establishment as Wrap or Non-
Wrap.
Cambria’s annual fee for investment management services provided under this Agreement shall
be based on the market value of the Assets under management and be calculated as follows:
Assets Under Management Annual Fee for non-wrapped fee accounts, Representative as
Advisor, Envestnet.
Accounts to $49,999…………………………..1.50%
$50,000 to $249,999…..…………...………….1.45%
$250,000 to $499,999..………………......……..1.35%
$500,000 to $999,999........…………………...1.20%
Over $1,000,000..…………..…………….....….1.00%
In the case of an account established with Axos Clearing where Envestnet is the sub-adviser,
fees are paid to portfolio managers on their platform. The fees paid to the portfolio managers
ranges between .35% and .5% and is based on the manager and strategy selected. Customers
will be given a clear breakdown of all costs prior to engaging in any advisory agreement with
Cambria. In addition, Envestnet charges a fee for access to their platform. The fees paid to
Envestnet for access ranges between .09 percent and .58 percent which includes custody and
clearing charges with Axos Clearing, reporting costs and other administrative/clerical costs.
Customers will be given a clear breakdown of all costs prior to engaging in any advisory
488 E Winchester Street, Suite 200, Salt Lake City, UT 84107
Tel: 801-320-9606 Toll Free: 877-226-0477 Fax 801-320-9610
agreement with Cambria. This annual fee shall be negotiable in certain cases, and be pro-rated
and paid in advance on a monthly or quarterly basis. No increase in the annual fee shall be
effective without prior written notification to the Client. Clients are responsible for verifying the
accuracy of the custodial fees and transaction costs charged by the custodian and/or the
Adviser.
Assets Under Management Annual Fee for Cambria Armor Series Strategies, Envestnet,
Actively Managed Global ETF Strategy, and Zacks wrapped fee accounts.
Accounts to $49,999…………………………..2.00%
$50,000 to $249,999…..…………...………….1.90%
$250,000 to $499,999..………………......……..1.80%
$500,000 to $999,999........…………………...1.65%
Over $1,000,000..…………..…………….....….1.45%
The Cambria Armor Series Strategies fee amount includes a sub-advisory fee of 0.30 percent
which is paid to Equity Armor Investments, LLC, a SEC Registered Investment Adviser under the
Investment Advisers Act of 1940, and a 0.15 percent fee which is paid to Folio Investments, LLC
for custody, clearing, and performance reporting services. Cambria’s fee can be derived by
subtracting the sum of the sub-advisory ‘EAI’ fee (0.30) and the Folio fee (0.15) which equals
0.45 percent, and subtracting it from the fee schedule above. At no time will the total advisory
fees exceed 2 percent. This annual fee shall be negotiable in certain cases, and be pro-rated
and paid in arrears on a monthly basis.
The Zacks portfolio fee amount includes a sub-advisory fee of 0.28 percent for stock portfolio
strategies and 0.18 for ETF portfolio strategies which is paid to Zacks Investment Management,
Inc, a SEC Registered Investment Adviser under the Investment Advisers Act of 1940, and a 0.15
percent fee which is paid to Folio Investments, LLC for custody, clearing, and performance
reporting services. Cambria’s fee can be derived by subtracting the sum of the sub-advisory
‘Zack’s’ fee (0.18-0.28) and the Folio fee (0.15) which ranges from 0.33 and 0.43 percent, and
subtracting it from the fee schedule above. At no time will the total advisory fees exceed 2
percent. This annual fee shall be negotiable in certain cases, and be pro-rated and paid in
arrears on a monthly basis.
Billing for accounts referred to The Pacific Financial Group, Inc.
Separately Managed Accounts; Core Retirement Optimization; and Variable Annuity Optimization -
For Separately Managed Accounts, Core Retirement Optimization and Variable Annuity Optimization
Programs, Clients pay a management fee to TPFG and a fee is paid to the Adviser for referring the Client
to TPFG and for other services provided to the Client by the Adviser. The fee schedule is as follows:
488 E Winchester Street, Suite 200, Salt Lake City, UT 84107
Tel: 801-320-9606 Toll Free: 877-226-0477 Fax 801-320-9610
Assets Under Management Annual Fee To TPFG Annual Fee to Adviser
$0 to $500,000 1.00% 1.00%
$500,001 to $3,000,000 0.75% 0.75%
$3,000,001 to $5,000,000 0.50% 0.50%
$5,000,001 to $10,000,000 0.40% 0.40%
$10,000,001 and Up Subject to Negotiation Subject to Negotiation
Under certain circumstances, a custom fee schedule may be applied as agreed to by TPFG, the Adviser
and Client. All fees are based on the value of the Client’s account at the beginning of each calendar
quarter and are billed one quarter in advance. Fees are deducted from the Client’s account on a
quarterly basis, though the Client has the option of paying the quarterly fees from other sources.
In addition, TPFG assesses a $40.00 annual administrative fee (deducted at the rate of $10.00 per
quarter) on all Separately Managed, Core Retirement Optimization and Variable Annuity Optimization
...