Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Asset Management:
Our firm’s fees for Asset Management shall be based on a negotiated percentage of the market value
of the assets under management not to exceed 1.25%. Asset management fees are listed on Schedule
A of the client agreement.
Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the value of
your account on the last day of the quarter. Fees will generally be automatically deducted from your
managed account. Further, it is important to note that our firm will assess advisory fees on cash and
cash equivalents held in client accounts. As part of this process, you understand and acknowledge
the following:
a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the Assets and all disbursements in your account
including the amount of the advisory fees paid to us;
b) You provide authorization permitting us to be directly paid by these terms. We send our
invoice directly to the custodian;
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
CWIG Total Return Fund, LLC:
Please see the funds Offering Memorandum for more information on applicable fees charged by our
firm for the management of the assets of the CWIG Total Return Fund, LLC. Clients will not be charged
an advisory fee by our firm on the assets invested in the offered private fund.
Other Fees:
Clients will incur transaction fees for trades executed by their chosen custodian via individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be
disclosed by the chosen custodian. Raymond James & Associates, Inc. member New York Stock
Exchange/SIPC, will not charge transaction fees for U.S. listed equities and exchange traded funds as
of January 21, 2020.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified
retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Refunds Following Termination:
We charge our advisory fees quarterly in arrears. If you wish to terminate our services, you need to
contact us in writing and state that you wish to cancel this Agreement. Upon notice of termination
pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory
ADV Part 2A – Firm Brochure Page 5 CW Investment Group
fees cannot be deducted, our firm will send an invoice for due advisory fees to the client. Clients
entering into an agreement will not be billed for the initial partial quarter of services, nor for fund
infusions performed intra-quarter. The normal billing cycle will take place at the beginning of the
first full quarter where assets are managed.
Commissionable Securities Sales:
Representatives of our firm are licensed insurance agents and as such, they are able to accept
compensation for the sale of insurance products such as fixed annuities. Clients should be aware that
the practice of accepting commissions for the sale of insurance products presents a conflict of interest
and gives our firm and/or our representatives an incentive to recommend insurance products based
on the compensation received. Our firm generally addresses commissionable sales conflicts that arise
when explaining to clients these sales create an incentive to recommend based on the compensation
to be earned Our firm does not prohibit clients from purchasing recommended investment products
through other unaffiliated insurance agency or agent.