Item 5. Fees and Compensation
SteelPeak offers services on a fee basis, which includes fixed, as well as fees based upon assets under
management. In addition, SteelPeak Capital I, LLC, SteelPeak Capital II, LLC, SteelPeak Investments,
LLC, and Alpha Summit Tax Optimization Fund, LP receive performance-based compensation for
investments in the Fund. Additionally, certain of the Firm’s Supervised Persons, in their individual
capacities, offer insurance products under a separate commission-based arrangement.
Financial Planning and Consulting Fees
SteelPeak charges a fixed fee for providing financial planning and consulting services under a stand-alone
engagement. These fees are negotiable, but range from $500 to $5,000, depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, SteelPeak may offset
all or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and SteelPeak requires one-half of the fee payable upon execution of the Advisory
Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the
agreed upon services. The Firm does not, however, take receipt of $1,200 or more in prepaid fees in
excess of six months in advance of services rendered.
Investment Management Fees
SteelPeak offers investment management services for an annual fee based on the amount of assets under
the Firm’s management. This management fee varies between 75 and 175 basis points (0.75% – 1.75%),
depending upon the size and composition of a client’s portfolio and the type of services rendered.
The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets
being managed by SteelPeak on the last day of the previous quarter. Because the various custodians that
hold and value client accounts may have different methods of calculating accrued income of certain
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Disclosure Brochure SteelPeak Wealth, LLC
securities, the Firm utilizes an independent third party reporting company for all calculations of accrued
income for billing purposes.
If assets in excess of $10,000 are deposited into or withdrawn from an account after the inception of a
billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in
portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. Where
the Firm is not doing the billing directly, but instead relies upon a third-party (such as Apex, as described
in Item 12, below), the Firm will defer to the billing procedures of that third-party as long as it is in the
best interest of the client. In the event the advisory agreement is terminated, the fee for the final billing
period is prorated through the effective date of the termination and the outstanding or unearned portion of
the fee is charged or refunded to the client, as appropriate.
The Firm’s Agreement will authorize SteelPeak to debit its clients’ accounts for the amount of the
advisory fee and to directly remit that fee to SteelPeak. Any Financial Institutions recommended by
SteelPeak have agreed to send statements to clients not less than quarterly indicating all amounts
disbursed from the account, including the amount of advisory fees paid directly to SteelPeak. Clients will
be required to open an account with the Firm’s primary custodial relationship, Charles Schwab & Co.,
Inc. (“Schwab”), Fidelity Brokerage Services LLC (“Fidelity”), or TradePMR in order to allow the Firm
to withdraw its quarterly fee.
The Firm includes cash in a clients account in determining the valuation for billing purposes. The Firm
may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
percentage of cash for reasons other than the Firm's investment management decision. Additionally, for
asset management services the Firm provides with respect to certain client holdings (e.g., held-away
assets, accommodation accounts, alternative investments, etc.), SteelPeak may negotiate a fee rate that
differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to
recommend that clients engage SteelPeak for additional services for compensation, including rolling over
retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion
over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.
If a valuation for private securities is not available through the custodian or administrator, the Firm will
typically rely on the valuation provided by the issuer. Because valuations may only be provided
periodically (including monthly, quarterly or even annually), the Firm can be billing on a valuation that
would be different if updated. That valuation can be higher or lower depending on the increase or
decrease in value of the private investment. This includes the valuation of the Firm’s the affiliated Funds
which leads to an additional conflict of interest. All of the Funds are audited an annual basis and most
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