Item 5 Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
If a client determines to engage the Registrant to provide discretionary investment advisory
services on a fee basis, the Registrant’s annual investment advisory fee shall vary, from
negotiable up to 1.00%, based upon various factors, including the total amount of assets
placed under management/advisement.
FAMILY OFFICE SERVICES
As discussed above, each Family Office engagement is separately negotiated based on the
size, complexity and breadth of each Family Office client’s needs. The Registrant’s annual
investment advisory fee shall vary from 0.25% up to 1.10%.
Annual Fixed Fee. Although the Registrant’s annual investment advisory fee shall
generally be based upon a percentage of assets under management, in certain limited
circumstances, the Registrant may agree to provide its Investment Advisory and/or Family
Office services on an annual fixed fee basis.
Fee Differentials. Because the Registrant shall generally price its advisory services based
upon various objective and subjective factors, our clients could pay diverse fees based upon
a combination of factors, including but not limited to the market value of their assets, the
complexity of the engagement, the level and scope of the overall investment advisory
services to be rendered, and negotiations. Therefore, similarly situated clients could pay
diverse fees, and the services to be provided by the Registrant to any particular client could
be available from other advisers at lower fees.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Registrant’s planning and consulting fees are negotiable, but generally range from $2,500
to $100,000 on a fixed fee basis, depending upon the level and scope of the service(s)
required and the professional(s) rendering the service(s). Prior to engaging the Registrant
to provide planning or consulting services, clients are generally required to enter into a
Financial Planning and Consulting Agreement with Registrant setting forth the terms and
conditions of the engagement (including termination), describing the scope of the
services to be provided, and the portion of the fee that is due from the client prior to
Registrant commencing services.
REPORTING SERVICES
The Registrant may be engaged to provide reporting services, which can incorporate all of
the client’s investment assets, including Excluded Assets. The Registrant’s reporting
service fee is negotiable and will generally be based upon the complexity of the client’s
portfolio and the level of reporting required by the client.
RETIREMENT PLAN CONSULTING SERVICES
The Registrant’s retirement plan consulting services fee is generally calculated based upon
a percentage of assets maintained within the plan. The terms and conditions of the
engagement shall generally be set forth in a Retirement Plan Services Agreement between
the Registrant and the plan sponsor. The Registrant’s retirement plan consulting services
fee generally ranges from negotiable up to 0.75%.
B. Clients may elect to have the Registrant’s advisory and planning and consulting fees
deducted from their custodial account. Both Registrant's Investment Advisory Agreement
and the custodial/clearing agreement may authorize the custodian to debit the account for
the amount of the Registrant's investment advisory fee and to directly remit that
management fee to the Registrant in compliance with regulatory procedures. In the limited
event that the Registrant bills the client directly, payment is due upon receipt of the
Registrant’s invoice.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Fidelity Investments
(“Fidelity”) serve as the broker-dealer/custodian for client investment management assets.
Broker-dealers such as Fidelity charge brokerage commissions and/or transaction fees for
effecting certain securities transactions.
In addition to Registrant’s investment management fee, brokerage commissions and/or
transaction fees, clients will incur, relative to all mutual fund and exchange traded fund
purchases, private investment funds and independent managers, charges imposed at the
fund, account or partnership level (e.g. management fees and other fund expenses).
Tradeaway/Prime Broker Fees. If, in the reasonable determination of the Registrant that
it would be beneficial for the client, individual equity and/or fixed income transactions may
be effected through broker-dealers other than the account custodian, in which event, the
client generally will incur both the fee (commission, mark-up/mark-down) charged by the
executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by
the account custodian (i.e., Fidelity).
Asset-Based Pricing Arrangements and Limitations. Registrant may recommend that
clients enter into an “Asset-Based” pricing agreement with the account broker-
dealer/custodian. Under an “Asset-Based” pricing arrangement, the broker-dealer/
custodian charges the client a fixed percentage fee for all account commissions/transactions
based on the amount of assets placed in custody and/or on the broker-dealer/custodian’s
platform, and not based upon the number of transactions executed. Generally in an
Asset-Based pricing arrangement, the applicable fixed percentage fee decreases as the
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