Smart Portfolio LLC

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Smart Portfolio LLC
CRD #324633
SEC #801-127212
CIK #
AUM 44.1 M (2026-02-16)
Employees 2 (50% Investors, 0% Brokers)
Fees
Minimum
Phone858-898-8000
Address3230 E Imperial Highway
Brea, CA 92821
Source [IAPD] [Website]
Total AUM ($M)
504030201002010201520212027
Fees and Compensation — Form ADV Part 2A (2/25/2026) [Brochure]
Item 5 Fees and Compensation

Asset Management Fees
Clients of Smart Portfolio agree to compensate the Advisor for investment advisory services
pursuant to an executed investment advisory agreement. The standard fee schedule is outlined
below and is calculated as an annual percentage of assets under management (AUM). Fees are
charged quarterly in arrears based on the portfolio value as of the last business day of each calendar
quarter. For new accounts, fees are prorated from the account’s inception date through the end of
the initial billing period. These fees apply to the asset management of clients invested in PPLI.

Assets Under Management:               Annual Fee:
Up to $249,999                            1.25%
$250,000 – $2,999,999                     1.00%
$3,000,000 – $4,999,999                   0.80%
$5,000,000 and Over                       0.60%

Fees are applied to the entire account balance, not tiered. For example, a client with a $3 million
portfolio would be charged 0.80% on the entire amount, and the fee for one quarter would be
calculated as: $3,000,000 X (0.80%/4) = $6,000. Fees are deducted directly from the client’s
investment account by the qualified custodian. Clients authorize this deduction in writing at the
time the advisory agreement is signed. Clients will receive quarterly account statements directly
from the custodian showing fee withdrawals, portfolio holdings, and transaction activity.

In addition, Smart Portfolio may send its own invoices, which include the calculation
methodology, time period covered, and the specific amount to be withdrawn. Smart Portfolio does
not hold client funds or securities, and custody is limited solely to fee deduction authority, as
permitted under applicable regulations. All advisory fees may be negotiable at the sole discretion
of Smart Portfolio. Factors influencing negotiated rates may include portfolio size, client
relationship, or specific service requirements.

In accordance with California Code of Regulations, Rule 260.238(j), Smart Portfolio discloses that
clients may obtain comparable advisory services from other sources at potentially lower cost.

Smart Portfolio                             Page 6

Additional Fees and Expenses
Smart Portfolio’s advisory fee is exclusive of other fees charged by third parties, including: (a)
mutual fund or ETF expenses. Clients may incur internal fund expenses as described in each fund’s
prospectus, including management fees and operating costs.

Custodial and brokerage fees: Clients are responsible for all custodial fees and transaction costs
charged by the custodian or executing broker. These fees are separate from and in addition to the
Firm’s advisory fee.

Insurance Products Compensation and Conflict Disclosure
In addition to acting as investment advisor representatives (IARs), certain individuals associated
with Smart Portfolio may be licensed insurance agents. In that capacity, they may earn customary
commissions for insurance product sales. This dual role creates a potential conflict of interest, as
there may be an incentive to recommend insurance products based on compensation rather than
client need. However, clients are not required to purchase insurance products through Smart
Portfolio or its IARs. Commissions earned through insurance sales are not the primary form of
compensation for investment adviser representatives of the Advisor. No advisory fees are charged
on assets invested in insurance products where Smart Portfolio’s IARs receive commissions on
the sale of the insurance. As noted in Item 4, advisory fees are charged on certain insurance
products that contain securities, but in those cases the IARs do not receive commissions on those
products. Clients are always encouraged to compare product pricing and services independently
and may elect to purchase products directly from other providers without engaging Smart
Portfolio. Smart Portfolio has implemented a Code of Ethics to address and manage potential
conflicts of interest. (See Item 11 for more information.)
Account Minimums and Types of Clients — Form ADV Part 2A (2/25/2026) [Brochure]
Item 7 Types of Clients

The Advisor will offer its services to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations and other business entities.

The Advisor’s cumulative minimum account requirement for opening and maintaining an account
is $50,000. However, the Advisor may at its sole discretion accept accounts with a lower value.
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 9 1.1
(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 50 41.0
(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 0 2.0
(n) Other 0 0.0
Total 60 44.1
By Discretionary
Discretionary 60 44.1
Non-Discretionary 0 0.0
Total 60 44.1
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 44.1
Total 60 44.1
Firm Profile (Form ADV)
ServesInstitutional, Retail
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