Item 5 Fees and Compensation
Selection of Other Advisers
We do not charge you a separate fee for selecting other advisers. We will share in the advisory fee you
pay directly to the TPMM. The total advisory fee charged will not exceed 3% annually. The advisory fee
you pay to the TPMM is established and payable following the brochure provided by each TPMM to
whom you are referred. The annual advisory fee is billed and payable quarterly in advance, based on the
value of your account on the last day of the previous quarter. If the portfolio management agreement is
executed on a day other than the first day of the calendar quarter, our fees will be applied on a pro-rata
basis. This means you will only be charged for the portion of the quarter during which you are a client.
The Program fee is negotiable based on individual client circumstances. You may withdraw account
assets by providing notice to our firm, subject to the standard securities settlement procedures. However,
our portfolios are designed for long-term investments, and withdrawing assets may hinder your ability to
achieve your specific investment objectives.
The TPMM directly debits the advisory fee from your account through the qualified custodian holding your
funds and securities. The TPMM will deduct the advisory fee only when the following requirements are
met:
• You provide our firm with written authorization permitting the fees to be paid directly from your
account held by the qualified custodian;
• We send the qualified custodian written notice of the amount of the fee to be deducted from your
account;
• We send you an invoice showing the amount of the fee, the value of the assets on which the fee
is based, the time period covered by the fee, and the specific manner in which the fee was
calculated, including any formulae used to calculate the fee; and
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts
dispersed from your account, including the amount of the advisory fee paid directly to our firm.
Upon receiving an invoice and/or billing statement, we encourage you to reconcile our invoices with the
statement(s) you receive from the qualified custodian. If you find any inconsistent information, please call
our main office number on this disclosure brochure's cover page.
Our compensation may differ depending on our specific agreement with each TPMM. As such, a conflict
of interest exists where our firm or persons associated with our firm are incentivized to recommend one
TPMM over another TPMM with whom we have more favorable compensation arrangements or other
advisory programs offered by TPMMs with whom we have less or no compensation arrangements.
However, the TPMMs custody fees through RBC range between 5 basis points and 35 basis points
annually, depending on the size and nature of the account and the RBC platform used. One basis point
is equal to 1/100th or 0.01% of 1%. Envestnet charges a sponsor fee of between 5 basis points and 18
basis points annually, depending on the size and nature of the account.
You must sign an agreement directly with the recommended TPMM(s). You may terminate your advisory
relationship with the TPMM according to the terms of your agreement with the TPMM. You should review
each TPMM brochure for specific information on how to terminate your advisory relationship with the
TPMM and how to receive a refund, if applicable. You should contact the TPMM directly for questions
regarding your advisory agreement with the TPMM.
Additional Fees and Expenses
The TPMM may recommend investing in mutual funds and exchange-traded funds. The fees you pay the
TPMM 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.
Absent any agreement to the contrary, you will also incur transaction charges and/or brokerage fees when
purchasing or selling securities through a brokerage firm. These charges and fees are typically imposed
by the broker-dealer or custodian through whom your account transactions are executed. We do not share
any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully
understand your total cost, 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.
State of California Required Disclosures
While our firm always endeavors to offer clients specialized services at reasonable costs, the fees
charged by other investment advisers for comparable services may be lower than those our firm charges.
Clients will not be charged a management fee over the 3% industry average.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm may also be registered representatives with our
firm in its dual role as a securities broker-dealer and member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. These registered representatives will receive
commission-based compensation for purchasing and selling securities, including 12b-1 fees for selling
investment company products. Compensation earned by these persons in their capacities as registered
representatives is separate and in addition to our advisory fees. This practice presents a conflict of interest
because persons providing investment advice on behalf of our firm, who are registered representatives,
are incentivized to effect securities transactions to generate commissions rather than solely based on your
needs. In the case of mutual funds, we primarily recommend no-load or load-waived funds. However, you
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