Fees and Compensation — Form ADV Part 2A (7/12/2024)
[Brochure]
Item 5: Fees and Compensation
We are compensated for our advisory services by charging a percentage of assets under management
according to the asset value in each account on the last day of the previous quarter. The asset value is the
fair market value of the securities listed by the custodian. If there are trades which have been placed but not
yet settled, billing will be based on the value of pending trades which have not yet settled. Fees are to be
paid on a quarterly basis billed in arrears and calculated according to the following Advisory Fee Schedule:
Value of All Managed Accounts with Firm Per Quarter Annualized
First $500,000 0.3750% 1.50%
Next $500,000 ($500,001 to $1,000,000) 0.3125% 1.25%
Next $1 million ($1,000,001 to $2,000,000) 0.2500% 1.00%
Next $3 million ($2,000,001 to $5,000,000) 0.1875% 0.75%
Amounts over $5 million 0.1250% 0.50%
As authorized in writing, we may directly debit our fees from any managed account maintained at a
qualified custodian provided the client receives at least quarterly statements from the custodian reflecting
all debits from the account. Sanctuary may permit negotiated fees in certain circumstances.
Outside of accounts opened with Betterment, fees paid to Sanctuary for investment advisory services are
separate and distinct from the expenses charged to the client in connection with any transaction to purchase
or sell an investment, or any expense directly associated with management of the portfolio. Clients may
incur brokerage and other transaction costs, which are further explained in Item 12: Brokerage Practices of
this ADV. Furthermore, Item 10: Other Financial Industry Activities and Affiliations of this ADV details
other compensation earned by Principals or other representatives of our firm.
Betterment’s asset-based wrap fee includes the services provided by Betterment and Betterment Securities
through the Betterment for Advisors platform.
We do not charge our fees in advance for the services provided.
Important note regarding the valuation of private funds. Private investment funds are valued no less
than annually by their sponsor. For those private funds for which we charge an advisory fee, our fee
will be based upon the most recent value provided to us or to the custodian by the plan sponsor. The
actual value of the private fund may be more or less than what is reported to us because the value of
its underlying investments will fluctuate after the dissemination of the valuation. This will result in
clients paying a fee that is higher or lower than it would have been had the underlying assets of the
fund been valued daily, providing us with a quarter-end value.
Item 6: Performance-Based Fee and Side-By-Side Management
We do not charge performance-based or side-by-side management fees.
Account Minimums and Types of Clients — Form ADV Part 2A (7/12/2024)
[Brochure]
Item 7: Types of Clients
We typically provide advisory services to individuals, trusts and estates, corporations or business entities,
and pension and profit-sharing plans. For individuals, we generally require a minimum aggregated portfolio
size of $1,000,000, or a minimum annual fee of $10,000 for wealth management services. We require a
minimum aggregated portfolio size of $100,000 for investment management services. For trusts and
estates, corporations and business entities, or pension and profit-sharing plans, we generally require a
minimum portfolio size of $50,000. Exceptions to these account sizes and minimum fees may occasionally
be made at our discretion.
Offered $1,800,000 · Filed 2022-10-14 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $100,000 · Duration One year or less · Revenue Decline to Disclose
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
384
50.0
(b) Individuals (high net worth individuals)
169
179.0
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above