ITEM 5 – FEES AND COMPENSATION
SAM’s standard management fees for individual discretionary Managed Account Client accounts
are between 1%- 2% subject to negotiation. The agreed upon fees depend on a variety of factors
including, but not limited to, the complexity and/or size of such Managed Account Client’s account
and the history of such Managed Account Client’s relationship with SAM.
SAM’s fees could be higher than those of other investment advisers providing comparable services
to Managed Account Clients.
Investment advisory fees for the management of accounts are billed in arrears at the end of each
quarter and are prorated for assets deposited or withdrawn in the middle. Managed Account
Clients may elect to have their fees paid directly from their accounts or to pay the fees from other
sources.
To the extent that Clients invest in mutual funds or ETFs, the Clients also pay the expenses of
these vehicles. The impact of mutual fund or ETF expense ratios is reflected in their investment
performance. SAM attempts to invest Clients only into mutual funds and ETFs whose potential
investment performance warrants incurring the expense ratio.
In addition, Clients whose accounts trade in options pay transaction costs to options brokers at
various rates. SAM attempts to negotiate the most favorable rates for its Clients.
In its capacity as investment adviser to Funds, SAM charges management fees ranging from 1.5%
to 2.0% of assets annually (0.375%-0.5% per quarter, billed in arrears), depending on the nature
and methodology of the Fund. Fees and other material terms regarding an investment in a
particular Fund are set forth in such Fund's Memorandum.
Managed Account Clients in variable annuities must also pay the insurance company’s mortality
benefit and expense ratio, in addition to the expenses of the mutual funds offered within each
annuity.
The amount and whether to charge fees for SAM’s financial planning consultations is negotiable.
Systems and Forecasts subscribers pay annual subscription fees, generally $99 per year. This fee
is occasionally reduced or eliminated during special promotions or at the discretion of SAM, and
free trial subscriptions are available. If a subscriber cancels his or her subscription before the end
of the subscription period, he or she will receive a pro-rata refund of the subscription fee based on
the amount of time remaining in the period.
Each Managed Account Client has the right to terminate its advisory agreement with SAM upon
written notice as set forth in such Client’s advisory agreement. Upon termination of any Managed
Account Client account, any prepaid, unearned fees will be promptly refunded and any earned,
unpaid fees will be due and payable. Withdrawals or redemptions by SRM Fund Investors from a
Fund can be made on the terms described in the Fund’s Memorandum.
SAM’s fees do not include brokerage and transaction fees, costs and charges, and other related
costs and expenses that will be incurred by Clients regarding the trading and maintenance of Client
accounts. Clients will incur certain charges imposed by custodians, brokers and other third parties
such as commissions, custodial fees, and other fees and taxes on brokerage accounts and securities
transactions. Such charges, fees and commissions are exclusive of and in addition to SAM’s fees,
and SAM does not receive any portion of these commissions, fees, and costs. Mutual funds and
ETFs also charge investment management fees, which are disclosed in a mutual fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to SAM’s fee, and SAM does
not receive any portion of these commissions, fees, and costs.
SAM does not receive any sales commissions or referral fees from any source.
Item 12 describes the factors that SAM considers in selecting broker-dealers for Client transactions
and determining the reasonableness of their compensation (e.g., commissions).