Fees and Compensation — Form ADV Part 2A (3/25/2021)
[Brochure]
ITEM 5: FEES AND COMPENSATION
A. METHODS OF COMPENSATION AND FEE SCHEDULE
1. Fees for Sub-Advisory Services
For its services as a sub-advisor to investment advisors, GSAM charges a negotiable Sub-
Advisory Fee (the “Fee”) not exceeding 0.55% of assets under management, annually. The Fee
arrangement is established directly with the investment adviser. The Fee may be billed and
payable in arrears or in advance on a monthly or quarterly basis and will be stated in the sub-
advisory agreement between GSAM and the investment adviser.
A client in a Wrap Program typically pays the sponsor of the program an annual fee typically
ranging from 1% to 2.5% of the client’s annual assets under management. If GSAM is engaged
by a Wrap Program sponsor to provide investment sub-advisory services to clients of the
program, GSAM’s sub advisory agreement with the sponsor will specify the amount of the firm’s
sub-advisory fee.
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In general, we receive the same annual fee(s) described above, regardless of whether the sub-
advisory services are provided for wrap accounts versus non-wrap accounts. The specific fee
amount will be negotiated between GSAM and the program sponsor and will depend on several
factors, including the size of the Wrap Program and the GSAM investment strategy that the
program will offer to clients.
The Wrap Program client does not pay any fees directly to GSAM; instead, the sponsor pays
GSAM’s fee out of the proceeds of the “wrap fee” paid by the client. If GSAM’s service to the
Wrap Program is terminated, any pre-paid advisory fee will be refunded to the client on a pro
rata basis by the Wrap Program sponsor. Wrap Program fees collected by a sponsor typically
cover all brokerage commissions on trades that are executed with the sponsor.
2. Fees for Stella Nova™
Under the Stella Nova program, client fees will be calculated across all assets within the
enrolled account, including cash positions. Enrolled accounts are responsible for paying Stella
Nova an annual wrap advisory fee of 0.25% to 0.40% billed on a pro-rata basis quarterly in
advance based on the value of the account(s) on the last day of the previous quarter. The fee
referenced may be waived at the Firm’s discretion. Stella Nova Mutual Fund Portfolios are
charged a $100 yearly account fee to be billed at $25/quarter. Fees under the program may be
waived or reduced at the firm’s discretion. Refer to the Stella Nova Program Brochure for more
information.
B. TERMINATION OF AGREEMENT - REFUNDS
GSAM’s advisory contracts with clients may typically be terminated at any time by either party
upon written notice to the other party. If an advisory contract is terminated, we will refund to the
client any unearned and pre-paid advisory fees.
C. PORTFOLIO VALUES FOR FEE CALCULATIONS
For purposes of calculating the amount of any asset-based fee owned and payable to Golden
State Asset Management, LLC, GSAM utilizes the independent pricing services and/or qualified
custodians to obtain timely valuation information for advisory client securities.
D. EXTERNAL COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
GSAM does not receive any consideration or fees beyond those paid by the client. Fees paid to
GSAM are exclusive of all custodial and transaction costs paid to the client’s custodian, brokers,
or other third-party consultants. Please see Item 12 below for additional information.
Fees paid to GSAM are also separate and distinct from the fees and expenses charged by
mutual funds, ETFs, or other investment pools (generally including a Management fee and fund
expenses, as described in each fund’s prospectus or offering materials). The client should
review all fees charged by funds, brokers, and others to fully understand the total amount of
fees paid by the client for investment and financial-related services.
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Account Minimums and Types of Clients — Form ADV Part 2A (3/25/2021)
[Brochure]
ITEM 7: TYPES OF CLIENTS
Our investment management services are open to all retail clients, including individuals, high
net worth individuals, trusts, estates, charitable organizations, and limited liability companies.
With the exception that Stella Nova accounts must be maintained at TD Ameritrade, we
currently impose no other requirements for enrolling and maintaining accounts in our
program(s). There is currently a $20,000 minimum to participate in the Stella Nova ETF models
but no minimums for the Stella Nova Mutual Fund models or the GSAM sub-advisory services.
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
751
112.5
(b) Individuals (high net worth individuals)
233
105.8
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
7
0.0
(h) Charitable organizations
1
0.0
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above