Item 5: Fees & Compensation
We are required to describe our brokerage, custody, fees and fund expenses so you will know how
much you are charged and by whom our advisory services provided to you. Our fees are
generally negotiable. Pursuant to CCR Section 260.238(j), our Firm hereby discloses that lower fees
for comparable services may be available from other sources.
A. Description of Fees.
(i) Comprehensive Portfolio Management:
Assets Under Management Annual Percentage of Assets Charge*
$1 to $5,000,000 1.25%
$5,000,001 to $10,000,000 1.00%
Over $10,000,001 0.75%
*Our Firms’ fees are billed on a pro-rata annualized basis quarterly in advance based on the
value of your account on the last business day of the previous quarter.
(ii) Pension Consultations:
We charge on an hourly fee basis for pension consultation services. The total estimated fee,
as well as the ultimate fee that we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fees are $250 for pension consulting services.
B. Deduction of Fees.
(i) Comprehensive Portfolio Management:
Our fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last business day of the previous quarter. Fees will generally be
automatically deducted from your managed account*. As part of this process, you understand
and acknowledge the following:
a) Your independent custodian sends statements at least quarterly to you showing all
disbursements for your account, including the amount of the advisory fees paid to us;
b) You provide authorization permitting us to be directly paid by these terms;
c) We send a copy of our invoice to the independent custodian at the same time we send
the invoice to you;
d) If we send a copy of our invoice to you, our invoice includes a legend as required by
paragraph (a)(2) of Rule 206(4)-2 under the Investment Advisers Act of 1940.**
*We do not offer direct billing as an option to our comprehensive portfolio management
clients.
**The legend urges the client to compare information provided in their statements with those
from the qualified custodian in account opening notices and subsequent statements sent to
the client for whom the adviser opens custodial accounts with the qualified custodian.
(ii) Pension Consultations:
We require a retainer of fifty percent (50%) of the ultimate pension consultation fee with
the remainder of the fee directly billed to you and due to us within thirty (30) days of your
pension consultation being delivered or consultation rendered to you. In all cases, we will
not require a retainer exceeding $500 when services cannot be rendered within 6 (six)
months.
C. General Information.
Clients will incur transaction charges for trades executed in their accounts. These transaction
fees are separate from our fees and will be disclosed by the firm trades are executed through.
Also, clients will pay the following separately incurred expenses, of which we do not receive any
part: charges imposed directly by a mutual fund, index fund, or exchange traded fund which
shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund
expenses).
D. Client’s Advisory Fees Are Due Quarterly in Advance.
We charge our advisory fees quarterly in advance. In the event that you wish to terminate our
services within 5 days of the signing of the agreement, there will not be any penalty and any
advisory fees paid will be refunded in full. Thereafter, if you wish to terminate our services, we
will refund the unearned portion of our advisory fee to you. You need to contact us in writing
and state that you wish to terminate our services. Upon receipt of your letter of termination,
we will proceed to close out your account and process a pro-rata refund of unearned advisory
fees.
E. Commissionable Securities Sales.
We do not sell securities for a commission. In order to sell securities for a commission, we would
need to have our associated persons registered with a broker-dealer. We have chosen not to
do so.