Item 5 – Fees and Compensation
The specific way management fees are charged by Palladium is established in your
Investment Counsel Agreement. We bill our fees on a quarterly basis on the first day
following the calendar quarter. These fees are charged in arrears based on a percentage of
the market value of your assets under management with us on the last day of the previous
billing quarter (i.e., 10/1 invoice based on the 6/30 market value). Advisory services begin
on the date you sign the Investment Counsel Agreement. Billing begins on the day the
account is released for trading. You may elect to be billed directly for fees or authorize
Palladium to directly debit fees from your account(s) at the custodian. You should verify the
accuracy of the fee calculation. Your custodian will not determine whether the fee has been
properly calculated. Accounts initiated during a calendar quarter will be charged a prorated
fee.
Proper valuations are necessary for accurate fee billing purposes and performance
calculations, among others. Palladium utilizes qualified custodians for timely valuation
information for client securities. Whenever valuation information for specific illiquid,
foreign, private, or other investments is not available through pricing services or custodians,
Palladium’s Valuation Committee and/or portfolio manager(s) will obtain and document
price information when possible, from at least one independent source, whether it be a
Palladium Registered Investment Advisors Page 4 March 2022
Form ADV 2A
broker-dealer, bank, or other source. Any securities for which we are unable to obtain
market valuation information are priced at $0 per unit by the Valuation Committee.
Either you or your Advisor may terminate the Agreement for any reason upon 30 days
written notice to the non-terminating party. Accounts terminated during a calendar quarter
will be charged a prorated fee. Upon termination of any account, any earned, unpaid fees
will be due and payable. You may cancel the Agreement without penalty within the first five
days after signing the Agreement.
Palladium’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by you. You may incur certain charges imposed
by custodians, brokers, other third parties such as fees charged by managers, custodial fees,
deferred sales charges, mark-ups, transfer taxes, wire transfers and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. Mutual funds and
exchange-traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus. To reduce fees, when possible, we will exchange mutual fund shares for share
classes with lower expense ratios. Such charges, fees and commissions are exclusive of and
in addition to Palladium’s fee. We do not receive any portion of these commissions, fees, or
costs. You should review all fees charged by Palladium, the custodian, broker and others to
fully understand the total amount of fees incurred.
Item 12 describes the factors that we consider in selecting or recommending broker-dealers
for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
The compensation for Palladium’s Advisory services is as follows:
Assets Under Management Annual Fee Quarterly Fee
On the first $5,000,000 0.90% 0.225 %
On the next $5,000,000 0.70% 0.175%
Above $10,000,000 0.50% 0.125%
At our discretion, we may charge a lesser investment advisory fee, impose or waive an asset
minimum, charge a flat fee, or waive its fee entirely based upon certain criteria (i.e.
anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, complexity of the engagement,
anticipated services, grandfathered fee schedules, Palladium employees and family
members, courtesy accounts, competition, negotiations with client, etc.) Please Note: As a
result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower fees.
Compensation for the additional services Palladium offers is as follows:
Palladium Registered Investment Advisors Page 5 March 2022
Form ADV 2A
Consulting & Financial Planning – For those clients who do not retain Palladium for
investment management, an hourly consulting or financial planning fee of $150 - $250 per
hour will apply.