ITEM 5: FEES AND COMPENSATION
A. Fees Charged
Kinloch Capital offers services on a fee basis, which includes fixed fees, hourly fees, and fees based
upon assets under management.
Asset Management
Kinloch Capital’s asset management fees range from 0.35% to 2.0% per annum of the gross market
value of a client’s assets managed by Kinloch Capital, as shown in the schedule below. Fees are
negotiable and could be higher or lower than this range, based on the nature of the account, and the
origin of the client. Factors affecting fee percentages include the size of the account, complexity of
asset structures, the extent of the anticipated financial planning work to be included with the
engagement, and other factors. All clients, but especially those with smaller accounts, should be
advised they may receive similar services from other professionals for higher or lower overall costs.
Portfolio Value Annual Fee
$0 - $500,000 2.00%
$500,001 - $750,000 1.50%
$750,001 - $1,000,000 1.25%
$1,000,001 - $2,000,000 1.00%
$2,000,001 – $5,000,000 0.85%
$5,000,001 - $10,000,000 0.65%
$10,000,001 - $25,000,000 0.50%
Over $25,000,000 0.35%
There may be special circumstances in which Kinloch Capital arranges a fixed fee for asset
management with a client. This fixed fee is determined by Kinloch Capital and the client, factoring the
nature and size of the account and complexity of asset structures.
Advisory Fees for “Held Away” Assets
For services we provide on Held Away Accounts (accounts other than those held with our primary
custodian, Charles Schwab), Kinloch Capital will be paid a fee based upon the fair market value of
your account. This fee will be calculated and billed/invoiced monthly in advance. Fees are pro-rated
based on the number of days service is provided during the billing period. Pontera does not have trading
authority on the held away account and will be paid by Kinloch Capital directly. Pontera does not bill
nor invoice Kinloch Capital clients. Kinloch Capital bills clients directly. As it is impossible to directly
debit the fees from these accounts, those fees will either be assigned to the client’s taxable accounts.
If the client does not have a taxable account, those fees will be billed directly to the client.
Financial Planning
Clients who are engaging Kinloch Capital for financial planning services without asset management
services will do so on will do so on an hourly basis. The hourly fee is not expected to exceed $250 per
hour. Fees are negotiable and will depend on the anticipated complexity of the financial plan. If Client
engages Kinloch Capital under separate agreement for asset management services, asset management
fees shall be offset for the first year that Client receives such asset management services effective upon
execution of the asset management agreement and expiring one year later. The amount of the fee offset
shall be limited to the amount of planning fees accrued by Client in accordance with the planning
agreement. Upon completion of the first year of asset management services the agreed upon fee as
disclosed in the asset management agreement shall be reinstated and applied to the assets under
management for the immediately following billing period.
Divorce Planning
Clients who are engaging Kinloch Capital for divorce planning services will do so on an hourly basis.
The hourly fee is not expected to exceed $250 per hour. Fees are negotiable and will depend on the
complexity of the services to be provided. If Client engages Kinloch Capital under separate agreement
for asset management services, asset management fees shall be offset for the first year that Client
receives such asset management services effective upon execution of the asset management agreement
and expiring one year later. The amount of the fee offset shall be limited to the amount of planning fees
accrued by Client in accordance with the planning agreement. Upon completion of the first year of asset
management services the agreed upon fee as disclosed in the asset management agreement shall be
reinstated and applied to the assets under management for the immediately following billing period.
B. Fee Payment
Asset Management
For clients whose assets are managed by the firm, investment advisory fees will be debited directly
from each client’s account. The advisory fee is paid monthly, in advance, and the value used for the
fee calculation is the balance of the gross assets under management within client accounts for the
immediately preceding month. For example, if your annual fee is 1.00%, each month we will multiply
the ending value of your account for the immediately preceding month by 1.00%, then divide by the
number of days in that calendar year and multiply that number by days in the month to calculate our
fee. To the extent there is cash in your account, it will be included in the value for the purpose of
calculating fees only if the cash is part of an investment strategy. No adjustments are made to the
advisory fee for inflows or outflows made during a billing month. Once the calculation is made, we
will instruct your account custodian to deduct the fee from your account and remit it to Kinloch Capital.
Clients whose fees are directly debited will provide written authorization to debit advisory fees from
their accounts held by a qualified custodian chosen by the client. Each month, the client will receive
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