Item 5. Fees and Compensation
GAVIN offers its services on a fee basis, which may include fixed fees, as well as fees based upon assets
under management.
Financial Planning and Consulting Fees
GAVIN may charge a fixed fee and/or hourly fee for financial planning and consulting services. These fees
are negotiable, but generally range from $5,000 to $30,000 annually on a fixed fee basis, depending upon
the level and scope of the services and the professional rendering the financial planning and/or the
consulting services. If the client engages GAVIN for additional investment advisory services, GAVIN may
offset all or a portion of its fees for those services based upon the amount paid for the financial planning
and/or consulting services.
Prior to engaging GAVIN to provide financial planning and/or consulting services, the client is required to
enter into a written agreement with GAVIN setting forth the terms and conditions of the engagement.
Generally, GAVIN requires one-half of the financial planning and/or consulting fee (estimated fixed) payable
upon entering the written agreement. The balance is generally due upon delivery of the financial plan or
completion of the agreed upon services.
Investment Management Fee
GAVIN provides investment management services for an annual fee based upon a percentage of the
market value of the assets being managed by GAVIN. GAVIN’s annual fee is exclusive of, and in addition
to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by
the client. GAVIN does not, however, receive any portion of these commissions, fees, and costs. GAVIN’s
annual fee is prorated and charged monthly, in arrears, based upon the market value of the assets being
managed by GAVIN on the last day of the month. The annual fee varies (between 0.25% and 1.00%)
depending upon the market value of the assets under management and the type of investment
management services to be rendered.
GAVIN, in its sole discretion, may negotiate to charge a lesser management fee 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, pre-existing client, account retention, pro bono activities,
etc.).
Fees Charged by Financial Institutions
As further discussed in response to Item 12 (below), GAVIN recommends that clients utilize the brokerage
and clearing services of Pershing Advisor Solutions (“Pershing”) for investment management accounts.
GAVIN may only implement its investment management recommendations after the client has arranged for
and furnished GAVIN with all information and authorization regarding accounts with appropriate financial
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Disclosure Brochure
institutions. Financial institutions include, but are not limited to, Pershing, any other broker-dealer
recommended by GAVIN, broker-dealer directed by the client, trust companies, banks etc. (collectively
referred to herein as the “Financial Institutions”).
Clients may incur certain charges imposed by the Financial Institutions and other third parties such as
custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund or
ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other
fund expenses), expenses associated with investments in the Fund, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Additionally, clients may incur brokerage commissions and
transaction fees. Such charges, fees and commissions are exclusive of and in addition to GAVIN’s fee.
GAVIN’s Agreement and the separate agreement with any Financial Institutions may authorize GAVIN
and/or certain Independent Managers to debit the client’s account for the amount of GAVIN’s fee and to
directly remit that management fee to GAVIN. Any Financial Institutions recommended by GAVIN have
agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the
account including the amount of management fees paid directly to GAVIN.
Fees for Management During Partial Months of Service
For the initial period of investment management services, the fees are calculated on a pro rata basis.
The Agreement between GAVIN and the client will continue in effect until terminated by either party
pursuant to the terms of the Agreement. GAVIN’s fees are prorated through the date of termination and
any remaining balance is charged or refunded to the client, as appropriate.
Clients may make additions to and withdrawals from their account at any time, subject to GAVIN’s right to
terminate an account. Additions may be in cash or securities provided that GAVIN reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients
may withdraw account assets on notice to GAVIN, subject to the usual and customary securities settlement
procedures. However, GAVIN designs its portfolios as long-term investments and the withdrawal of assets
may impair the achievement of a client’s investment objectives. GAVIN may consult with its clients about
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