Item 5: Fees and Compensation
We base our fees on a percentage of assets under management or hourly which are described
below.
Compensation – Investment Management Services
Investment Management fees are typically charged as follows:
Assets Under Management Annual Fee
First $1,000,000 1.10%
Next $2,000,000 1.00%
Next $2,000,000 0.80%
Next $5,000,000 0.60%
Next $15,000,000 0.50%
Over $25,000,000 Negotiable
Fees are billed in one of two ways, each of which is disclosed in the client agreement:
• Quarterly in arrears based on the amount of assets managed, including cash as of the
close of business on the last business day of the previous quarter as valued by the
custodian, or
• Quarterly in arrears based on the average daily balance, including adjustments for
deposits and withdrawals during the quarter, including cash as valued by the custodian.
Compensation – Tax Preparation Services
Tax Preparation fees are charged based on hourly rates, depending on the experience of the
employee providing the service and the nature and complexity of each client’s circumstances.
Compensation – Business Consulting
Business Consulting fees are charged based on hourly rates, depending on the experience of
the employee providing the service and the nature and complexity of each client’s
circumstances.
Calculation and Payment
The specific manner in which we charge fees is established in a client’s written agreement with
us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees
from client accounts.
In no case will more than $1,200 be collected from the client more than 6 months in advance.
Agreement Terms
Either party may terminate an agreement at any time by notifying the other in writing.
If the client made a payment in arrears, we would collect any earned yet unpaid fees.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients.’
Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give
prudent advice);
• never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
• follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
a written explanation of the advantages and disadvantages of both account types and
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