Item 5 Fees and Compensation
Description of Fee Calculations and Schedule for Wealth and Investment Management Services
The Firm generally bases its fees on a percentage of assets under management as described in the
client’s investment management agreement. NEIRG’s current fee schedule for investment
management accounts is as follows:
Account Size Standard Tiered Annual Fees
First $250,000 ..........1.25%
Next $1,250,000 ..........1.00%
Next $3,500,000 ..........0.75%
Balance over $5,000,000 ..........0.65%
Fees are negotiable and may be waived in the sole discretion of the Firm. The Firm, in its sole
discretion, may charge a different investment advisory fee based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition, negotiations with
clients, etc.). The Firm may negotiate hourly fees and/or fixed fees in certain circumstances for its
Investment advisory fees and Financial Planning services.
For Plan Account Allocation Services, the Firm assesses an annual fee ranging from 0.30% to 0.60%
(depending on the complexity and size of the account) of the value of the retirement plan account
balance billed on a quarterly basis, but such fees may be modified or waived depending upon certain
criteria at the Firm’s sole discretion, as noted above.
For Retirement Plan Services, the Firm assesses an annual fee ranging from .20% to 1.00%
(depending on the complexity and size of the plan as well as the scope of services provided),
determined and billed monthly or quarterly depending on the plan.
Although a client has the right to make withdrawals from his account at any time, the Firm may
terminate an account that falls below its minimum portfolio size of $200,000. If assets are deposited to
or withdrawn from an account after the inception of a quarter that exceed $50,000, per transaction, the
management fee payable with respect to the assets will be pro-rated based on the number of days
remaining in the quarter.
Fee Billing for Wealth and Investment Management Services
Investment management fees are billed quarterly, in advance, meaning that NEIRG charges its fee
before the three-month billing period has begun. Fees are usually deducted from a designated client
account to facilitate billing. The client must consent in advance to direct debiting of their investment
account. Clients will be provided with an account statement by the custodian which will detail the
amount of the advisory fee deducted from the client’s account. Clients have the option of paying as
invoiced by NEIRG or through a direct debit from their account. Clients may make arrangements to
pay management fees for a qualified account through a direct debit from their non-qualified account, if
necessary.
If the account does not contain sufficient funds to pay the advisory fees, NEIRG has limited authority to
sell or redeem securities in sufficient amounts to pay advisory fees.
Fees for Plan Account Allocation Services, financial planning services or other wealth management
consulting services are to be paid directly to the Firm as negotiated between NEIRG and the client (the
Firm may in some cases deduct such fees from other investment management accounts the client has
with the Firm, if applicable, through direct debiting as described above if authorized by the client).
Other Fees for Wealth and Investment Management Services
The Firm’s investment management fees are exclusive of brokerage commissions, transaction fees,
and other related costs and expenses which may be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers and other third parties such as fees charged by managers,
custodial fees, deferred sales charges, transfer taxes, wire transfer and electronic fund fees, and other
fees and taxes on brokerage accounts and securities transactions.
Oftentimes, an unmanaged security that was held in a client account may begin to accrue
management fees if the security becomes actively managed, either due to a corporate action or at the
request of a client.
The Firm recommends that clients establish accounts with TD Ameritrade Institutional, a division of TD
Ameritrade, Inc. (“TD Ameritrade”), Fidelity Brokerage Services LLC ("Fidelity"), or Charles Schwab &
Co., Inc. (“Schwab”) (generally and collectively, “Custodian(s)”), to maintain custody of clients' assets
and to effect trades for their accounts. Although the Firm may recommend that clients establish
accounts with a Custodian, it is the Client's decision where to custody assets. NEIRG is independently
owned and operated and not affiliated with TD Ameritrade, Fidelity, or Schwab. The client does not
pay a custody fee to TD Ameritrade, Fidelity or Schwab, although the client will incur transaction
charges and other expenses, such as a custody fee for certain non-standard assets.
The Firm generally purchases shares of mutual funds at net asset value; however, any mutual fund
shares held in a client account may be subject to deferred sales charges, 12b-1 fees, short-term
redemption fees, and other mutual fund annual expenses. The fees and expenses are fully described
in the fund’s prospectus. All fees paid to the Firm for our services are separate and distinct from the
fees and expenses charged by mutual funds. Mutual funds pay advisory fees to their managers and
such fees are therefore indirectly charged to all holders of the mutual fund shares. If a client has
mutual fund shares in their account, the client is effectively paying both the Firm and the mutual fund
manager for the management of these assets. Please refer to the fund’s prospectus or other offering
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