Item 5 Fees and Compensation
Diversified Portfolio Development/Management/Ongoing Monitoring and Private Wealth
Services
Advisory fees are negotiable depending upon your individual facts and circumstances (i.e., size of
account, length of time with our firm, etc.) and at our sole discretion.
The client’s advisory fee is generally payable directly to us, and we share a portion of the total
advisory fee with the client’s primary investment professional. The fee is based on a percentage
of your assets we manage, and the portion of the advisory fee that we retain, after payment to
your primary investment professional, will range up to, but will not exceed, 1.1% of assets under
management. The highest advisory fee rate charged may be higher than the rates charged by
other advisers for comparable services. However, fees shall vary depending upon various
objective and subjective factors, including but not limited to: the amount of assets to be managed;
account composition; the scope and complexity of the engagement; the anticipated number of
meetings and servicing needs; related accounts; future earning capacity; anticipated future
additional assets; the professional(s) rendering the service(s); and negotiations with the client. As
a result of these factors, similarly situated clients could pay different fees, and the services to be
provided by us to any particular client could be available from other advisers at lower fees.
The advisory fee will be based upon the total asset value of the securities under management in
the account. Fees will be charged according to the Advisory Agreement. Your annual advisory fee
is generally billed monthly in advance, calculated as a percent of the value of your account at the
close of the last business day of the previous month. Exceptions to this general practice (e.g.,
granting allowances for quarterly billing or collecting fees in arrears) may be made at our sole
discretion. We will deduct our fee directly from your account through the qualified custodian holding
your funds and securities. We will deduct our advisory fee only when you have given our firm
written authorization permitting the fees to be paid directly from your account. Further, the qualified
custodian will deliver an account statement to you at least quarterly. These account statements
will show all disbursements from your account. It is your responsibility to verify the accuracy of the
fee calculation.
Advisory fees may be negotiable under certain circumstances, at our sole discretion. Depending
on individual arrangements made, fees paid by one client may be higher or lower than fees paid
by another client under similar circumstances.
There may be transaction charges involved with the purchasing or selling of securities which are
separate and distinct from advisory fees paid to our firm.
Termination of Advisory Relationship
You or our firm may terminate these services at any time and for any reason, upon thirty (30) days
written notice to the other party. We will cease assessing our advisory fee upon receipt of your
termination notice, but you will continue to receive our services until the effective date of
termination. Upon notice of termination, we will await further instructions from you as to what steps
you request to liquidate and/or transfer the portfolio and remit the proceeds. Upon instructions
received, we will instruct brokers, dealers, mutual fund sponsors, and others to liquidate and/or
transfer the portfolio and remit proceeds to you. To the extent applicable, we will promptly refund
any unearned advisory or management fees (prorated through the effective date of termination)
following a written request from you to do so. Clients are advised that, because we collect fees on
a monthly basis, require thirty (30) days advance notice of termination, and continue to provide
our services through the thirty (30) day termination period, clients will generally not be owed a
refund. Clients may terminate our services within five (5) business days of signing the Advisory
Agreement without incurring any charges.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest,
in mutual funds and exchange traded funds. The fees that you pay to our firm for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds
or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees
will generally include a management fee and other fund expenses. You may also incur transaction
charges and/or brokerage fees when purchasing or selling securities. These charges and fees are
typically imposed by the broker-dealer or custodian through whom your account transactions are
executed. We do not share in any portion of the brokerage fees/transaction charges imposed by
the broker-dealer or custodian. To fully understand the total cost you will incur, you should review
all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information
on our brokerage practices, please refer to the "Brokerage Practices" section of this brochure.
Please Note: Cash Positions. We believe that cash and cash equivalents are a material
component of a client’s investment allocation. As a result, at any specific point in time, depending
upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), we may maintain cash or cash equivalent
positions for defensive, liquidity, or other purposes. All cash and cash equivalent positions (money
markets, etc.) shall be included as part of assets under management for purposes of calculating
the client’s advisory fee, unless otherwise agreed, in writing. Clients are advised that, at any given
time, our advisory fee may exceed the yield earned on cash and cash equivalent holdings.
Self-Directed Brokerage Window
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