ITEM 5: FEES AND COMPENSATION
Clients will be assessed an advisory fee based on total managed assets for all qualifying accounts
across the relationship. Effective as of 7/1/2025, CGPCS generally will invest client assets in
(1) SMA Programs, pooled funds and other vehicles and services for which CGPCS or an
affiliate of CGPCS serves as investment adviser or Sub-adviser (the “affiliated services”), and
(2) services managed by an unaffiliated Sub-adviser or other third party (“unaffiliated services”).
In addition to the advisory fee, clients are assessed a fee based on separately managed assets
such as those in the SMA Programs (see “Separately Managed Service Fee” below), and there
are additional fees associated with the affiliated and unaffiliated services, which vary by service
and are set forth in the prospectus or other governing instrument.
In addition to the fee schedules outlined below, different fee schedules apply for certain long-
standing clients of CGPCS and its affiliates as well as clients with customized mandates or
special service needs. Generally, fees are not negotiable.
Certain CGPCS professionals, including private wealth advisors and consultants, as well as
relationship managers (“CGPCS Advisory Professionals”) receive, in addition to their base
salary, additional compensation based on CGPCS assets under management of (i) new clients of
the CGPCS Advisory Professional and (ii) existing clients serviced by the CGPCS Advisory
Professional. CGPCS Advisory Professionals also have quantitative annual sales goals that
affect the amount of compensation for servicing existing clients. In addition, CGPCS Advisory
Professionals are eligible to receive a qualitative bonus which includes as a factor the number of
new clients of the CGPCS Advisory Professional. This additional compensation presents
conflicts of interest as such associates are incentivized to: (i) recommend CGPCS’ services, and
(ii) encourage their clients to increase the assets in their accounts.
With respect to any investments held in an account, CGPCS will have a preference for, and will
primarily use and invest in, affiliated services. As described more fully below, CGPCS expects
the proportion of such affiliated services held in the account relative to holdings of other
unaffiliated services to be high, usually 100%, and even where similar unaffiliated services may
have lower fees or better historical returns. Any unaffiliated funds or services must meet
CGPCS’s investment criteria.
CGPCS and its affiliates are compensated for investment advisory and other services they
provide in connection with affiliated services. These fees vary by the portfolio and are set forth
in the prospectus or other governing instruments. As a result, CGPCS and its affiliates will
receive more total revenue when investments managed by CGPCS or its affiliates are held in the
account than when assets are allocated to unaffiliated services. This creates an incentive for
CGPCS to recommend affiliated products and services.
The foregoing conflicts of interest are mitigated by (i) CGPCS policies that require CGPCS
Advisory Professionals to act in their clients’ best interests, in accordance with SEC Rule 3a-4
and inclusive of training, and on-going supervision and compliance monitoring; and (ii) the fact
that the compensation received by CGPCS Advisory Professionals does not vary based upon
their investment recommendations.
Finally, clients have the right to terminate CGPCS and separately arrange for the provision of
advice by another adviser that does not recommend funds or services affiliated with the adviser.
Advisory fees
Clients are assessed an advisory fee based on total managed assets for all qualifying accounts
across the relationship, according to the following schedule:
Total Relationship Assets Advisory Fee
Assets from $5 (i.e., not including) up to
0.650%
$10 Million
From $10 up to $15 Million 0.500%
From $15 up to $20 Million 0.450%
From $20 up to $25 Million 0.400%
From $25 up to $35 Million 0.350%
From $35 up to $45 Million 0.300%
From $45 up to $55 Million 0.275%
From $55 up to $75 Million 0.250%
From $75 Million up to 500 Million 0.225%
$500 Million + 0.200%
Separately Managed Service Fee
In addition to the advisory fees described above, clients are assessed a “Separately Managed
Service Fee” on assets invested in the respective SMA program, according to the following
schedules:
U.S. Equity: 0.345%
International Equity/ Global Equity: 0.385%
Core Plus Bond: 0.290% 1
Intermediate/ Core Bond: 0.250%
Municipal Income: 0.250%1
Municipal Bond: 0.150%
The Separately Managed Service Fee includes fees charged by: (1) CGPCS affiliates for
investment management, operational and systems integration, and ongoing service support; and
(2) unaffiliated Sub-advisers and platform providers. Please refer to our affiliates’ and Sub-
advisers’ respective ADVs for further details about their services.
1. Anticipated launch November 18, 2025
Certain legacy CGPCS relationships, and relationships where our legacy platform may be better
suited for the Client, may be eligible for a different separately managed service fee schedule
with breakpoints.
Minimum Account Size
There is a minimum managed relationship size of $5 million. The minimum managed
relationship size may be waived from time to time, based on certain factors. In such cases, for
relationships below $5 million, advisory fees will be assessed based on the following schedule:
1.00% up to $1 million; 0.90% from $1 million up to $3 million; and 0.80% from $3 million up
to $5 million.
Calculation Methodology and Billing
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