Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Wealth Management:
The fees for this service are described in the table below:
Assets Under Management Annual %
$0 to $500,000 1.50
$500,001 to $1,000,000 0.80
$1.000,001 to $3,000,000 0.75
$3,000,001 to $5,000,000 0.70
$5,000,001 to $10,000,000 0.60
$10,000,001 to $15,000,000 0.45
$15,000,001+ 0.40
Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized
fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last
day of the month. Fees are negotiable and will be deducted from client account(s). Unless otherwise
agreed to in writing, advisory fees shall be applicable on cash and cash equivalents. In rare cases, our
firm will agree to directly invoice. As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
ADV Part 2A – Firm Brochure Page 6 Vinoble Group
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.
The fees for third-party managers will be separate and in addition to the fees described above for our
services. These fees will be set forth in separate disclosure documents outlining the scope of the sub-
advisory arrangements. It should be noted that sub-advisors may recommend the use of their own
proprietary funds in the portfolios they help us construct. This creates a conflict of interest where they
receive greater compensation when client portfolios are invested in their proprietary funds. These
conflicts are discussed in greater detail in the sub-advisor’s Form ADV 2A which will be provided to all
clients using these models.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $450. Flat fees
range from $1,500 to $10,000. Financial Planning is provided free of charge for clients with over
$1,000,000 in our Comprehensive Portfolio Management Service. The fee-paying arrangements will
be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Our
firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on a flat fee basis or a fee based on the percentage
of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based
on the scope and complexity of our engagement with the client. Our flat fees range from $750 to
$10,000. Fees based on a percentage of managed Plan assets will not exceed 1.00%. The fee-paying
arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
agreement.
Other Types of Fees & Expenses
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. 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.
Fidelity Brokerage Services (“Fidelity”) has eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at least
$1 million in assets at Fidelity.
Termination & Refunds
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Either party may terminate the advisory agreement signed with our firm for Asset Management and
Comprehensive Wealth Management services in writing at any time. Upon notice of termination pro-
rata advisory fees for services rendered to the point of termination will be charged. If advisory fees
cannot be deducted, our firm will send an invoice for due advisory fees to the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
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