Item 5 Fees and Compensation
Separately Managed Accounts for Individual Client Investment Objectives and Momentum Strategy
Regent offers a percentage of assets under management fee structure for its accounts
separately managed for your investment objectives and for accounts managed using
the momentum strategy. We generally receive an annual management fee equal to
0.95% of the closing value of the assets in your account, payable as set forth below.
Currently, for balanced accounts and for certain advisory relationships, the annual
fee is reduced to within a range of 0.40% to 0.925%. The fee is payable quarterly in
advance (relating to the future time period) within the first thirty days after the end
of each quarter and is equal to one-fourth of the applicable annual fee percentage
multiplied by the closing value of your assets for the last full monthly period
immediately preceding the last month of the quarterly period (i.e., the second month
of the quarterly period). Your assets will be priced as reported on the statement sent
to you by your custodian bank, trust company or brokerage firm, or as published by
Interactive Data Corporation, Bloomberg, Yahoo! ® Finance, The Wall Street
Journal or such other source we may determine in good faith in our sole discretion
on a consistent basis. Certain clients, by agreement, pay management fees quarterly
in arrears (relating to the past time period). You may select whether you prefer fees
to be deducted directly from your account or to be billed for fees incurred.
Although we have established the aforementioned fee schedules, we retain the
discretion to negotiate alternative fees on a client-by-client basis. Client facts,
circumstances and needs are considered in determining the fee schedule. These
include the complexity of the client, assets to be placed under management,
anticipated future additional assets, related accounts, portfolio style, and account
composition, among other factors. From time to time, we may waive our
management fees for principals and officers of our firm as well as their family
members, and/or other clients in certain circumstances. As a result of the above,
similarly situated clients could pay different fees. Conflict Of Interest. A small number
of clients (fewer than five clients), by agreement, pay reduced annual management
fee for certain asset classes versus other asset classes. In these cases, we can earn
higher compensation by allocating more assets to higher-fee asset classes, which
presents a conflict of interest. To mitigate this risk, we invest client accounts
according to their investment objectives, as stated at the onset of our relationship
with them and as updated from time to time.
Cash and Cash Equivalents. Included in the closing value of the assets in your account, upon which
our management fee is applied, is the value of cash and cash equivalents in your account.
Depending on the rate of interest paid on cash and cash equivalents by your custodian bank, trust
company or brokerage firm, our management fee may be more than the interest paid. We may from
time to time and on a temporary basis exclude the value of all or a portion of uninvested cash and
cash equivalents from our management fee calculation, when such cash and cash equivalent is being
reserved for eventual withdrawal, payment of external expenses, or such other circumstance as we
agree upon with you.
If your assets are invested in mutual funds or exchange-traded funds you will pay both a direct
management fee to Regent and indirect fees to the fund managers through the funds.
If your assets are invested in an unaffiliated private fund, you will pay both a direct management fee
to Regent and indirect fees to the fund sponsor through the unaffiliated private fund.
Fees for the quarter in which the account is opened or terminated will be prorated. For new
accounts, the prorated fee will be calculated based on the closing value of your assets on the date the
account was opened and funded, priced as reported by your custodian bank, trust company, or
brokerage firm, or as published by Interactive Data Corporation, Bloomberg, Yahoo! ® Finance,
The Wall Street Journal or such other source we may determine in good faith in our sole discretion
on a consistent basis.
You may also incur any custodial fees and brokerage and other transaction costs related to trading in
your account (for further explanation, please see Item 12 Brokerage Practices).
Retirement Rollovers and Employer-Sponsored Retirement Accounts
A client or prospective client is under no obligation to engage Regent as the investment adviser for
their retirement rollover and/or employer-sponsored retirement accounts. If a client does not
engage Regent as the investment adviser and continues to self-direct their retirement account at their
employer, the client will not incur a separate management fee as discussed above.
Termination. Under Regent’s current form of investment advisory agreement, either party can
terminate the agreement upon 30 days’ prior written notice to the other party. If you have paid any
management fees in advance, upon termination of the investment advisory agreement, we will
refund to you a pro rata portion of the management fee as of the termination date. For example, if
you pre-pay your fee for a three month billing period but terminate at the end of two months, one-
third of your fees will be refunded.