Item 5: Fees and Compensation
We are required to describe our brokerage, custody, fees, and fund expenses so you will know how
much you are charged and by whom our advisory services provided to you. Our fees are negotiable.
Unless otherwise noted in writing, our firm bills on cash.
A. Description of how we are compensated for our advisory services provided to you.
(i) Asset Management:
Assets Under Management Annual Percentage of Assets Charge:
$0 to $1,000,000 1.00%
$1,000,001 to $5,000,000 0.90%
$5,000,001 to $10,000,000 0.80%
$10,000,000 and over 0.70%
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.
(ii) Retirement Plan Consulting:
We charge a fee based on the percentage of Plan assets under management for our Retirement
Plan Consulting service. 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 annual fee
charged for this service will not exceed 1.00% of Plan assets under management. The fee-
paying arrangements will be determined on a case-by-case basis and will be detailed in the
signed consulting agreement.
B. Description of whether we deduct fees from clients’ assets or bill clients for fees incurred.
(i) Asset Management:
Fees will be automatically deducted from your managed account. We do not offer direct
invoicing. As part of this process, you understand and acknowledge the following:
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a) Your independent custodian sends statements at least quarterly to you showing all
disbursements for your account, including the amount of the advisory fees paid to us;
b) You provide written authorization permitting us to be directly paid by these terms;
c) We send a copy of our invoice to the independent custodian at the same time we send the
invoice to you;
d) This invoice from us will indicate the amount of the fee charged, the value of the assets
the fee is based on, the formula used to calculate the fee, and the time period covered by
the fee. We urge the client to verify the accuracy of the fee calculation by comparing the
invoice received from us with the statement received from the custodian. Any
discrepancies should be reported to us promptly.
C. Description of any other types of fees or expenses clients may pay in connection with our advisory
services, such as custodian fees or mutual fund expenses.
Clients will incur transaction charges for trades executed by their custodian. These transaction
fees are separate from our fees and will be disclosed by the account custodian. Schwab, Inc.
(“Schwab”), does not charge transaction fees for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the 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 (e.g., fund management fees, distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, 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). We do not receive a portion of
these fees.
D. Client’s advisory fees are due quarterly in arrears.
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 the Advisory Agreement. Upon receipt
of your letter of termination, pro-rata fees for advisory services rendered to the point of
termination will be charged. If advisory fees cannot be deducted, we will send you an invoice for
due advisory fees.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation
occurs within 5 business days of signing an agreement. After 5 business days from initial signing,
either party must provide the other party 30 days written notice to terminate billing. Billing will
terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis,
which takes into account work completed by our firm on behalf of the client. Clients will incur
charges for bona fide advisory services rendered up to the point of termination (determined as
30 days from receipt of said written notice) and such fees will be due and payable.
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E. Commissionable securities sales.
We do not sell securities for a commission. In order to sell securities for a commission, we would
need to have our associated persons registered with a broker-dealer. We have chosen not to do
so.