Fees and Compensation — Form ADV Part 2A (2/9/2021)
[Brochure]
Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
Total Assets Under Management Annual Fees
All Assets 1.50%
FCML uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals, for purposes of determining the market
value of the assets upon which the advisory fee is based.
The final fee schedule is attached as Exhibit II of the Investment Advisory Contract.
Clients may terminate the agreement without penalty for a full refund of FCML's fees
within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the Investment Advisory Contract immediately upon written notice.
Performance-Based Fees for Portfolio Management
Qualified clients will pay an annual fee of 1.50% of assets under management along with
a 20.00% performance fee based on capital appreciation. If the client's portfolio rises in
value, the client will pay 20.00% on that increase in value, but if the portfolio drops in
value, the client will not incur a new performance fee until the portfolio reaches the last
highest value, adjusted for withdrawals and deposits, which is generally known as a “high
water mark.”
The high water mark will be the highest value of the client’s account on the last day of any
previous year, after accounting for the client’s deposits or withdrawals for each billing
period.
The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. This
service may be canceled immediately upon written notice. Clients must pay the prorated
performance-based fees for the billing period in which they terminate the Investment
Advisory Contract up to and including the day of termination.
Subadviser Services Fees
FCML may also act as a subadviser to unaffiliated third-party advisers and FCML would
receive a share of the fees collected from the third-party adviser’s client. The fees charged
will not exceed any limit imposed by any regulatory agency. The notice of termination
requirement and payment of fees for subadviser services will depend on the specific third-
party investment adviser engaging FCML as subadviser. This relationship will be
memorialized in each contract between FCML and each third-party adviser. The fees will
not exceed any limit imposed by any regulatory agency.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees will be invoiced and billed directly to the client,
payable by bank transfer, on a quarterly basis. Fees are paid in arrears.
Payment of Performance-Based Portfolio Management Fees
Performance-based portfolio management fees may be invoiced and billed directly to the
client on a annual basis. Fees are paid in arrears.
Payment of Subadviser Fees
Subadviser fees may be withdrawn from clients’ accounts or clients may be invoiced for
such fees, as disclosed in each contract between FCML and the applicable third-party
adviser.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by FCML. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
FCML collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation For the Sale of Securities to Clients
Neither FCML nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
Account Minimums and Types of Clients — Form ADV Part 2A (2/9/2021)
[Brochure]
Item 7: Types of Clients
FCML generally provides advisory services to the following types of clients:
❖ High-Net-Worth Individuals
❖ Pooled Investment Vehicles
❖ Other Investment Advisers
There is no account minimum for any of FCML’s services.