Fees and Compensation — Form ADV Part 2A (3/3/2021)
[Brochure]
Item 5: Fees and Compensation
client’s investment options may be limited in certain of these programs to those mutual funds
and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments,
and the client should be aware that the firm is not selecting from among all mutual funds
available in the marketplace when recommending mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds:
Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and
generally, all things being equal, cause the fund to earn lower rates of return than those mutual
funds that do not pay revenue sharing fees. The client is under no obligation to utilize such
programs or mutual funds. Although many factors will influence the type of fund to be used, the
client should discuss with their investment adviser representative whether a share class from a
comparable mutual fund with a more favorable return to investors is available that does not
include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs
and priorities and anticipated transaction costs. In addition, the receipt of such fees can create
conflicts of interest in instances (i) where our adviser representative is also licensed as a
registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue
sharing fees as compensation – such compensation creates an incentive for the investment
adviser representative to use programs which utilize funds that pay such additional
compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue
sharing fees and takes the receipt of such fees into consideration in terms of benefits it may
elect to provide to the firm, even though such benefits may or may not benefit some or all
of the firm clients.
Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or
recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow
our investment adviser representatives to select mutual fund classes that either have no
transaction fee costs associated with them but include embedded 12b-1 fees that lower the
investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer),
or (ii) allow the use of mutual fund classes that have transaction fees associated with them but
do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the
mutual fund sponsor). Wrap fee programs offer investment services and related transaction
services for one all-inclusive fee (except as may be described in the applicable wrap fee program
brochure). The trading costs are typically absorbed by the firm and/or the investment
representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its
investment adviser representative avoids paying the transaction fees charged by other mutual
fund classes, which in effect decreases the firm’s costs and increases its revenues from the
account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate
of return on the specific mutual fund. This creates an incentive for the firm or investment adviser
representative to utilize such funds as opposed to those funds that may be equally appropriate
for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does
not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its
wrap fee programs. Clients should understand and discuss with their investment adviser
representative the types of mutual fund share classes available in the wrap fee program and the
basis for using one share class over another in accordance with their individual circumstances
and priorities.
Part 2A of Form ADV: Clear Perspective Advisors Brochure
Account Minimums and Types of Clients — Form ADV Part 2A (3/3/2021)
[Brochure]
Item 7: Types of Clients
Clear Perspective offers its investment services to various types of clients, including individuals
and high-net-worth individuals, trusts, pension and profit sharing plans, charitable
organizations, corporations, partnerships, retirement and 401(k) plans, tax exempt, and other
legal entities. Although Clear Perspective provides investment services to the various types of
clients mentioned, the services are conditioned upon meeting certain minimum criteria
established by the firm for each of the investment programs it offers.
Clear Perspective generally requires a minimum account value of $250,000 for accounts it
manages on a discretionary basis. Clients may be able to find comparable services at more
favorable pricing elsewhere. Clear Perspective, in its sole discretion, may waive the required
minimum.
Part 2A of Form ADV: Clear Perspective Advisors Brochure