Item 5: Fees and Compensation
First Growth Capital LLC generally charges a flat annual fee to its clients based on the scope of
services and size of the client’s relationship with First Growth Capital. Generally, these advisory fees
range from 0.50% to 2.00% of assets under management, but the fee can be higher or lower than
this range. In all cases, the scope of the Firm’s fees are specified in its agreement with the client.
Fees for First Growth Capital’s Consultation Service
For its Consultation Service, First Growth Capital charges fees based on the complexity and time
requirement of each client’s individual needs. Fees may be negotiated at a fixed annual rate (retainer),
computed as a percentage of assets under management, charged hourly, or some combination of the
above depending on the services rendered. First Growth Capital intends to charge retainer fees of
between $3,000 and $50,000 annually, depending on services rendered. Generally, hourly fees range
between $250 and $500 depending on services rendered and the experience level of the professional
performing the service.
First Growth Capital’s Consulting Service fee generally includes the following services in addition to
others specifically agreed upon by First Growth Capital and its clients: the collection and analysis of
the client’s financial data, the compilation of comprehensive financial projections and
recommendations designed to accomplish client goals, tax and estate planning services, risk
management evaluations, real estate and other services as needed, and limited asset management
services.
Fees for Advisory Services: Investment Accounts
First Growth Capital offers a Core Portfolio Management (PM) service to its clients. First Growth
Capital's Core PM offering includes such services as implementation of asset allocation plans, security
selection, and periodic review and rebalancing of client accounts. For this service, First Growth
Capital charges its clients an advisory fee that is separate from the fee First Growth Capital charges
for its Consultation Service. Details on this fee are available below (under the heading “Schedule of
Fees”).
First Growth Capital offers supplementary portfolio management solutions to clients in addition to
its Core PM service. These services are boutique in nature and may cost more or less than First
Growth Capital’s Core PM service. Clients may elect to participate any or all of First Growth Capital’s
offered services.
Clients are separately responsible for the cost of trade commissions and other costs (such as those
incurred on margin accounts and custody fees) charged by the custodian and/or broker for the use
of its brokerage and custodial services. These costs are outlined in the client’s separate agreement
with the broker/custodian. First Growth Capital neither shares in the proceeds of, nor affects the
cost of activity in the clients’ account on the custodian or broker’s platform.
Schedule of Fees
First Growth Capital charges fixed fees for its PM service based on the value of the client’s account
as well as the scope of the client’s total relationship with First Growth Capital. First Growth
Capital’s fees generally range between 0.50% and 2.00 % of the client’s account per annum. Please
note that this schedule of fees is a broad outline and fees are determined on a client-by-client basis
and outlined in an addendum to the client’s agreement with First Growth Capital. (For more
information on how First Growth Capital calculates and deducts these fees, please see the next
section, “Calculation and Deduction of Fees”).
Calculation and Deduction of Fees
Clients are required to authorize the client's custodian to calculate and deduct First Growth Capital’s
advisory fees from the client's custodial account. For clients who maintain their custodial accounts
at Interactive Brokers, the custodian calculates the fees based on the agreed-upon fee schedule that
is confirmed by the client when opening the account with the custodian. For clients who do not
maintain their custodial account at Interactive Brokers, the firm calculates the fee based on the
ending account value either monthly or quarterly, as specified in the client agreement; the client is
sent a fee letter and, unless the client objects within 15 days after the close of the billing period, the
firm instructs the custodian to debit the fee and remit it to the Firm.
Other Fees and Expenses
For advisory accounts at an unaffiliated custodian or broker, the custodian or broker may impose
execution charges for Equities, Fixed Income, and other securities, which will be charged to the
client in addition to the fees charged by First Growth Capital and outlined above. First Growth
Capital does not share in execution charges imposed by unaffiliated third parties, and
clients may pay more or less than similar clients are charged for identical transactions
executed by other brokerage services. A description of the different types of execution charges
that clients may pay is provided in the chart below:
Execution Charge Description and Applicability
Commissions The amount charged by a broker for purchasing or selling securities
or other investments, as an agent for the client, as disclosed on the
client’s trade confirmations. Commissions may be charged in
connection with transactions involving equities, fixed income
securities, master limited partnerships, exchange-traded funds, listed
options on equities, and any other securities traded as an agent.
Commission The amount charged by a dealer for purchasing or selling securities
Equivalents or other investments in certain riskless principal transactions—
transactions in which a dealer, after receiving an order to buy or sell
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