Item 5 Fees and Compensation
A. The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis.
INVESTMENT ADVISORY SERVICES
The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis. The Registrant’s annual investment advisory fee is based
upon a percentage (%) of the market value of the assets placed under the Registrant’s
management as per the following fee schedule:
Tiers Tier Chargeable Assets Annual Rate
1 First $500,000 1.35%
2 Plus, additional assets up to $1,000,000 0.85%
3 Plus, additional assets up to $2,000,000 0.70%
4 Plus, additional assets up to $4,000,000 0.45%
5 Plus, additional assets up to $8,000,000 0.35%
6 Amount over $8 million negotiable
As indicated at Item 7 below, the Registrant, in its discretion, may charge a lesser or higher
investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts, account
composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, courtesy accounts,
competition, negotiations with client, etc.).
TAX PREPARATION SERVICES
The Registrant may determine to provide tax preparation services on a stand-alone separate
fee basis for select clients as set forth in a separate engagement letter. Registrant’s typical
tax preparation fee for a simple tax return is $250 per return. However, Registrant’s fee
could be substantially more for more complex returns. No client is under any obligation to
engage the Registrant for tax preparation services.
Please see additional disclosure at Item 7 below regarding advisory fees.
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant's Investment Advisory Agreement and the custodial/ clearing
agreement may authorize the custodian to debit the account for the amount of the
Registrant's investment advisory fee and to directly remit that management fee to the
Registrant in compliance with regulatory procedures. In the limited event that the
Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
The Registrant shall deduct fees and/or bill clients monthly in advance, based upon the
market value of the assets on the last business day of the previous month. Clients who
purchase insurance products from representatives of the Registrant will be provided with
the terms of such products pursuant to state insurance laws. Additional disclosure
documents may be provided directly by an unaffiliated insurance company.
C. As discussed above and below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Charles Schwab and
Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets. As indicated above, broker-dealers such as Schwab charge transaction
fees for effecting certain types of securities transactions. In addition to Registrant’s
investment management fee and transaction fees, clients will also incur, relative to all
mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g.,
management fees and other fund expenses).
D. Registrant's annual investment advisory fee shall be prorated and paid monthly, in advance,
based upon the market value of the assets on the last business day of the previous month.
The Registrant does not generally require an annual minimum fee or asset level for
investment advisory services. The Registrant, in its sole discretion, may charge a lesser
investment management fee based upon certain criteria (i.e. anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, negotiations with client, etc.).
The Investment Advisory Agreement between the Registrant and the client will continue in
effect until terminated by either party by written notice in accordance with the terms of the
Investment Advisory Agreement. Upon termination, the Registrant shall refund the pro-
rated portion of the advanced advisory fee paid based upon the number of days remaining
in the billing month.
E. Insurance Commission Transactions. In the event that the client desires, the client can
engage the Registrant and its representatives to purchase insurance products on a
commission basis. The commissions and fees charged by the Registrant may be higher or
lower than those charged by other insurance producers.
1. Conflict of Interest: The recommendation that a client purchase an insurance
commission product presents a conflict of interest, as the receipt of commissions
may provide an incentive to recommend insurance products based on commissions
to be received, rather than on a particular client’s need. No client is under any
obligation to purchase any commission products from Registrant’s representatives.
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