Item 5 Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
The Registrant’s annual investment advisory fee shall be based upon a blended percentage
(%) rate, calculated using the market value and of assets placed under the Registrant’s
management and the following fee schedule:
Market Value of Portfolio % of Assets
On the First $1,000,000 1.00%
From $1,000,001- $3,000,000 0.75%
Greater than $3,000,000 0.65%
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Fee Dispersion. Registrant, in its discretion, may charge a lesser 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.). Please Note: As result of the above, similarly situated clients could pay different fees.
In addition, similar advisory services may be available from other investment advisers for
similar or lower fees. ANY QUESTIONS: Registrant’s Chief Compliance Officer remains
available to address any questions that a client or prospective client may have regarding
advisory fees.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Registrant’s planning and consulting fees are
negotiable, but generally range from $5,000.00 to $25,000.00 on a fixed fee basis and
$500.00 per hour on an hourly rate basis, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s).
Consulting Engagement Fee
Consulting fees are negotiable, based upon the nature and amount of services to be
provided. Clients are generally engaged on an hourly basis, at a rate of $500.00 per hour
and are invoiced directly on a quarterly basis based upon the services provided.
Zoe Financial Wealth Platform for referred clients
Zoe will charge a referral and subadvisory fee (“Referral Fee”) of 0.05% to 0.35% to the
Registrant for all referred client assets on the Zoe Wealth Platform. The Referral Fee will
be calculated based on the end of period balance of assets under management on the
Platform and billed quarterly, in arrears. The Registrant covers this fee and does not charge
any additional fee to the client.
For Registrant’s clients who have not been referred by Zoe Financial, Zoe Securities will
charge a 0.15% “Platform Fee” on Client Accounts for which Zoe Financial provides a
brokerage and custodial platform, along with certain sub-advisory services. The Platform
Fee will be calculated based on the end of quarter balance of assets under management in
Client Accounts for which Zoe Securities provides platform and sub-advisory services and
billed quarterly, in arrears, unless agreed upon for a different schedule between Zoe
Financial and the Advisory Firm. Zoe Securities will instruct the Custodian to invoice the
Registrant for the applicable platform fees paid on behalf of the client. Clients do not pay
any additional fee in connection with program participation.
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant’s 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 advisory fee to the Registrant in compliance with regulatory
procedures.
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In the event that the Registrant bills the client directly, payment is due upon receipt of the
Registrant’s invoice. Consulting clients are invoiced on a quarterly basis for services
provided.
C. As discussed above, unless the client directs otherwise or an individual client’s
circumstances require, Registrant shall generally recommend that Charles Schwab &
Company (“Schwab”) and Zoe Securities serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab and Zoe Securities charge
transaction fees for effecting certain securities transactions, in accordance with its
brokerage commission and transaction fee schedule. The types of securities for which
transaction fees, commissions, and/or other type fees (as well as the amount of those fees)
shall differ depending upon the broker-dealer/custodian. While certain custodians,
including Schwab, generally (with the potential exception for large orders) do not currently
charge fees on individual equity transactions (including ETFs), others do.
There can be no assurance that Schwab will not change its transaction fee pricing in the
future.
Schwab may also assess fees to clients who elect to receive trade confirmations and account
statements by regular mail rather than electronically.
In addition to the Registrant’s investment management fee and/or transaction fees, clients
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