ITEM 5 - FEES AND COMPENSATION
A. Fees for Advisory Services
Investment Management Services
Investment management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of
the investment management agreement. Investment management fees are based on the market value of assets
under management at the end of the prior calendar quarter. Investment management fees range from 0.20% to
2.00% annually based on several factors, including: the complexity of the services to be provided, the level of assets
to be managed, and the overall relationship with the Advisor.
The investment management fee in the first quarter of service is prorated from the inception date of the account[s]
to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will
take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by EAM will be independently valued by the Custodian. EAM will conduct periodic reviews of the
Custodian’s valuations.
Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s
investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor
does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory
fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint
schedule which will reduce the fee with an increased level of assets placed under management with an
Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure
brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s
fee and the Independent Manager’s fee, will not exceed 2.50% annually.
Private Fund Advisor Services
Fees for the Fund are paid monthly, at the end of each month, pursuant to the terms of the Offering Documents.
Fees are at an annual rate of 1.00%, based on the net asset value of the Fund. For more detailed information on
the fees and compensation received by the Advisor and its affiliates, please refer to the Fund’s Offering
Documents.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50%. Fees may be
negotiable depending on the size and complexity of the Plan.
Financial Institution Consulting Services
EAM receives a consulting fee based on the Assets Under Management from Brokerage Customers who have
provided written consent to a broker/dealer to receive the investment consulting service from EAM and have
entered into a written advisory contract with EAM. The consulting fee is calculated from the Assets Under
Management as of the end of a calendar quarter period multiplied by the annualized rate up to 75 basis points.
The initial fee is paid only after the completion of one full calendar quarter period following the date of the
executed agreement with broker/dealers.
B. Fee Billing
Investment Management Services
Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s
account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the
amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The
7 Empirical Asset Management, LLC Part 2A of Form ADV: Disclosure Brochure
amount due is calculated by applying the quarterly rate (annual rate divided by 365 multiplied by the number
days in the billing period) to the total assets under management with EAM at the end of the prior quarter. Clients
will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment
advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage
statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written
authorization permitting advisory fees to be deducted by EAM directly from their account[s] held by the
Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian.
Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s
overall fees will include EAM’s investment advisory fee (as noted above) plus investment management fees and/or
platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for
calculating the Client’s fees and deducting all fees from the Client’s account[s].
Private Fund Advisor Services
The amount due for management to the Fund is calculated by applying the monthly rate (annual rate divided
by 12) to the net asset value of the Fund. For more detailed information on the billing and methodology, please
refer to the Fund’s Offering Documents.
Retirement Plan Advisory Services
Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the
terms of the retirement plan advisory agreement.
Financial Institution Consulting Services
EAM shall be compensated for its consulting services on or before thirty (30) days past the end of the calendar
quarter.
C. Other Fees or Expenses
Clients may incur certain fees or charges imposed by third parties, other than EAM, in connection with
investments made on behalf of the Client’s account[s]. For Clients in the EAM Wrap Fee Program, securities
transaction fees are included in the Client’s investment advisory fee as noted above. For Clients not in the EAM
Wrap Fee Program, Clients are responsible for all custody and securities execution fees charged by the
Custodian. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity
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