ITEM 5: FEES AND COMPENSATION
Describe how the firm is compensated for its advisory services. Provide the fee schedule.
Disclose whether the fees are negotiable. Describe whether the firm deducts fees from
clients’ assets or bills client for fees incurred. Explain how often the firm bills clients or
deducts its fee.
GWM is primarily a fee based financial advisory and portfolio management firm.
Fee Structure
The annual fee for Portfolio Management Services will be based on a percentage of
assets under management, according to the schedule below:
Portfolio Value Maximum Fee
≤ $1,000,000 2.00%/year
≥ $1,000,001 to $5,000,000 1.75%/year
> $5,000,000 1.50%/year
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General Information on Services and Fees
In certain circumstances, fees may be negotiable. GWM may charge different clients
receiving the same services different fees. The above are the firm's standard fee
schedules.
Fees may be negotiable based on the amount of assets under management or the length
or scope of the client relationship. The annual fee for portfolios will be determined on a
sliding scale and based on the amount of assets under management and the level of
client services. Depending on the custodial platform, either GWM or the custodian will
calculate the advisory fee based on the value of the assets held in the client's account
and the annual rate.
GWM generally uses Interactive Brokers, LLC (IB) as custodian for client assets. For
clients who utilize IB the advisory fee will be calculated and deducted by Interactive
Brokers based on the value of the assets held in the client's account at the end of each
business day. The daily fee will be equal to the annual fee divided by the number of
business days in the calendar year.
Fees for Retirement Plan (401(k) and similar) Investment Advisory Services
Plan Assets Annual Fee
$0 - $1,000,000 0.75% of Plan Assets
$1,000,001-$10,000,000 0.55% of Plan Assets
$10,000,000+ 0.50% of Plan Assets
The advisory fees charged by Greenwich Wealth Management, LLC cover all the
investment advisory services provided to the plan sponsor, including investment advice,
educational materials, educational support and plan review services.
Investment Advisory fees are included in the expense ratio of the funds selected by the
Plan sponsor and are paid directly to Greenwich Wealth Management, LLC by the
custodian. Unless otherwise negotiated, our fee is payable quarterly on all plan assets in
arrears and is exclusive of fund expenses, third party administration and execution
costs. For the purpose of calculating advisory fees, we request for plan
custodians/TPA’s to bill on the quarter as defined by the plan and the custodian/TPA.
GWM does not perform the calculations or actual fee deductions on defined
benefit/contribution plan assets. The fee billing information is believed to be valid and
true with respect to fee billings as performed by the custodians utilized. Fees are
negotiated by Greenwich Wealth Management, the Plan Sponsor and the Plan
custodian/TPA.
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Other Custodial Platforms
For clients who direct the use of a custodial platform other than IB, the method by
which the fee will be calculated and charged will depend on the platform and on client
preference. GWM will endeavor to accommodate the billing preferences of the client
within the options available on any such platform and will afford the client the option of
paying the advisory fee separately from the custodian.
Schwab
Investment management fees will be automatically deducted from the client account by
the custodian. The advisor shall send an invoice to the custodian indicating the amount
of fees to be deducted.
The following method will be used for invoicing: monthly billing in arrears based on the
average daily balance of the account for the corresponding month.
Client’s will be provided with a statement directly from the custodian at least quarterly
reflecting deduction of the management fee. Clients are also able to view their accounts
daily online.
Clients provide written authorization permitting GWM to be paid directly from their
accounts held by the custodian as part of their client agreement and account opening
documents provided by the custodian.
Third Party Investment Manager and Monitoring Services
GWM may provide Third Party Investment Management and Monitoring Services. The
client will be billed directly on an annual basis after services are rendered. The fee for
this service is 0.25%, this fee is negotiable. Third party managers may charge a separate
fee, which will be disclosed to the client in the third-party managers ADV.
Data Licensing Royalties Received by Greenwich Wealth Management from Interactive Advisors
Interactive Advisors has agreed to compensate the GWM portfolio manager under the
Portfolio Manager License Agreement for licensing this trading data to Interactive
Advisors. Interactive Advisors charges its clients an advisory fee of 0.75% (75 basis
points) of assets under management for the U.S. Equity All Cap Undervalued strategy.
In connection with the use of this strategy, GWM receives an ongoing royalty from
Interactive Advisors equal to two- thirds of the advisory fee, or 0.50% (50 basis points)
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